Avio

Governance roles

Reference: pages 66-71 (ESRS 2 GOV-1), cross-referenced from the G1 chapter (page 164).

Avio follows the traditional Italian administration and control model: Shareholders' Meeting, Board of Directors and Board of Statutory Auditors (page 66). The Board was appointed on 28 April 2023 and has 11 members, six of whom are independent under Article 148 CFA and the Corporate Governance Code; the report states "55% of the members of the Board of Directors are independent" (pages 66, 68). Roberto Italia is Chairperson, Giovanni Gorno Tempini Vice-Chairperson and Giulio Ranzo Chief Executive Officer and General Manager (page 68). Board committees are the Appointments and Remuneration Committee, the Control and Risks Committee and the Sustainability Committee (page 71).

Gender diversity (page 71). Board of Directors 5 male / 6 female (54.5% female); Board of Statutory Auditors 3 male / 2 female; Appointments and Remuneration Committee 2/1; Control and Risks Committee 1/2; Sustainability Committee 1/2. Across all administrative, management and supervisory bodies: 12 male (48%) and 13 female (52%), 25 in total. The Group notes "the ratio of women to men is 83%" for the Board (footnote 75, page 71).

Information provided to the administrative, management and supervisory bodies

Reference: pages 71-72.

Beyond the Sustainability Committee, the parent company's sustainability function comprises (page 71):

• a Corporate Sustainability Director, who "coordinates and oversees the entire corporate sustainability initiative, ensuring compliance and supervising the overall process of publishing" the statement;
• a Sustainability Steering Committee of "key corporate figures with specific responsibilities for defining appropriate policies and targets, conducting specific projects, and reporting on the relevant results";
• a Sustainability Office of employees with ESG skills, which "takes the operational actions defined in the Sustainability Plan and reports on the results";
• an Executive Officer, who provides the statement of compliance on the Sustainability Statement with the ESRS and Article 8 of the Taxonomy Regulation. Avio confirms that "the Executive Officer for Sustainability Reporting is the same as the Executive Officer for Financial Reporting (as per Article 154-bis of the CFA)".

The results of the double materiality assessment "were validated by the Sustainability Committee and approved by the Board of Directors on January 29, 2026" (page 86). The disclosure does not give a list of the specific sustainability matters addressed by the bodies during the year, nor the dates or frequency of those discussions.

Sustainability performance in incentive schemes

Reference: pages 72-73, and the E1 restatement on page 113.

Avio's incentive offering comprises short-term variable remuneration (MBO) and long-term variable remuneration (LTI). The 2026-2028 Performance Share Plan is addressed to the CEO/General Manager, Senior Executives and other Managers in strategic roles, with a three-year performance period and delivery of shares subject to Board verification of the performance targets (page 72).

ESG indicators carry a 20% overall incentive determination weighting and are (page 72):

• Gender diversity, the ratio of female employees to total employees - 5%
• Gender pay gap, ratio of average female to male remuneration - 5%
• Energy efficiency, reduction over the three-year period in the ratio of electricity consumption (kWh) to manpower hours - 5%
• Employee training, average annual hours of training provided over the three-year period - 5%

Climate link is explicitly denied. "The AVIO Group has incentive systems linked to improvements in environmental impacts; however, at present they are not specifically related to climate change" (page 73), restated in the E1 chapter as "not specifically related to the reduction of GHG emissions. The Group nevertheless indirectly contributes to reducing GHG emissions through incentive schemes linked to energy efficiency" (page 113).

Statement on due diligence

Reference: pages 73-74.

Avio maps the core components of due diligence to the paragraphs of its statement (page 74):

• Integrating due diligence into governance, strategy and business model - ESRS 2 GOV-2, GOV-3 and SBM-3
• Engaging stakeholders in all key phases - ESRS 2 GOV-2, SBM-2, IRO-1, MDR-P and the topical ESRS chapters
• Identifying and assessing actual and potential negative impacts - ESRS 2 IRO-1 and SBM-3
• Taking action to address negative impacts - the topical ESRS chapters
• Tracking the effectiveness of actions and reporting - the metrics and targets sections of the topical chapters

The narrative anchors due diligence in the Human Rights Policy, which "confirms the AVIO Group's commitment not to establish or continue business relationships with any party that expressly refuses to respect human rights", and in the requirement that suppliers and subcontractors comply with the Code of Ethics, the 231 Model and the Supplier Code of Conduct both at qualification and throughout the contract (page 73).

Certified management systems carry much of the process: EMS to ISO 14001:2015, QMS to ISO 9001:2015 and AS 9100D/EN 9100:2018, the integrated occupational safety and major accident hazard system to UNI ISO 45001 (certified since 2010), and a Gender Equality Management System to UNI/PdR 125:2022, certified on 21 February 2025 (pages 73-74).

Risk management and internal controls over sustainability reporting

Reference: pages 74-75.

The Internal Control and Risk Management System (ICRMS) is built on the ERM - Integrated Framework and set out in Avio's Internal Control and Risk Management System Guidelines, which subsidiaries must comply with to the extent applicable (page 74). Avio has "a cross-functional ERM structure, dedicated specifically to the management of the Group's overall strategic risks", coordinating the Control and Risks Committee, Sustainability Committee, Board of Statutory Auditors, Supervisory Board and Internal Audit (page 74). Internal Audit provides an independent assessment of the ICRMS.

For reporting specifically, the Group has a procedure for "Preparing the Sustainability Statement Included in the Annual Financial Report" and an "Internal Control Model on Sustainability Reporting", both introduced in line with CSRD requirements. The Sustainability Disclosure Internal Control System ("SCIIS") sits inside the overall ICRMS and "establishes specific procedures to provide reasonable assurance on the reliability of sustainability statements" (page 75). Following the CSRD, Avio updated the "Executive Officer Regulation" to incorporate the sustainability reporting responsibilities assigned by Legislative Decree No. 125/2024 to the Executive Officer for Financial Reporting (page 75).

Strategy, business model and value chain

Reference: pages 75-77.

Avio designs, develops and produces solid and liquid propulsion systems for launchers, solid propulsion for tactical missiles, complete light space launchers (the VEGA family), and new propulsion and satellite attitude-control engines. Named programmes are Vega, Ariane, Aspide, Aster, CAMM-ER, MARTE and TESEO; customers are ESA, Arianespace, Europropulsion (the Avio-ArianeGroup joint venture), the Italian Space Agency (ASI) and MBDA (page 75).

Headquarters are in Italy (1,297 employees), with offices in France (16), French Guiana (109) and the USA (4) (page 76). Net revenue for 2025 was Euro 583,690 thousand (page 118).

Value chain (pages 76-77). Upstream is procurement of raw materials, semi-finished products, subsystems and finished components, plus inbound logistics; own operations cover product design and development, manufacturing and integration, warehouse management and outbound logistics; downstream covers customers of space development and production programmes and of defence products, plus "use of AVIO Group products by customers" and "end-of-life product disposal and waste management". The subsidiary Se.Co.Sv.Im manages the Group's real estate at Colleferro, including permitting and remediation.

Interests and views of stakeholders

Reference: pages 77-80.

Stakeholders are classified under ESRS 1 (AR 6, paragraphs 22-23) into "Users" of sustainability statements and "Affected" parties (page 77). The table on pages 77-80 sets out, for each category, the engagement activities, the responsible corporate functions and the stated expectations. Categories covered include shareholders/investors/financial analysts (User), government institutions (User), oversight and control authorities (User), local communities (Affected) and trade unions (User/Affected).

"In general, corporate bodies are periodically informed of key stakeholder engagement initiatives and their outcomes, so that strategies and planning can be established consistent with what emerges in these channels" (page 80). During 2025 the undertaking "deepened its understanding of the interests and perspectives of key stakeholders as part of its double materiality assessment, a process that involved both internal and external stakeholders" (page 80). One limitation is disclosed in the E2 chapter: "Local communities were not directly involved in the stakeholder engagement process for this reporting year, but their perspective was taken into account during the company's internal assessments" (page 124).

Material impacts, risks and opportunities

Reference: pages 80-85, with per-topic restatements in each chapter.

Avio renewed its double materiality assessment during 2025. Material IROs are presented in two tables - Impact Materiality (pages 81-82) and Financial Materiality (pages 83-84) - each row carrying a type, a value chain position (direct, indirect upstream, indirect downstream) and a time horizon. Counting the rows gives 31 impacts and 25 risks and opportunities, 56 in total, across ESRS E1, E2, E3, E4, E5, S1, S2, S3, S4, G1 and the entity-specific topic "Research, development and innovation" (page 81). No total is stated by the company.

Changes versus 2024 (pages 83-84). New material impacts on air pollution (E2), on depletion of natural resources (E5) and on R&D (entity-specific); SVHC integrated into the substances-of-concern impact (E2). The impact on disposal of materials not used in production (E5) and the impact relating to lack of inclusion of persons with disabilities (S1) were deemed not material. New material risks: steam supply (E5, identified through ERM) and three S4 risks on product quality and testing processes. G1 non-compliance risks "were deemed not material following the update of ERM assessments due to the mitigation actions implemented", and some risks previously under G1 were reclassified to the entity-specific topic.

Processes to identify and assess material IROs

Reference: pages 85-86.

The process follows the EFRAG IG 1 materiality guidance, in four phases:

1. Understanding the organisational context and value chain mapping - benchmarking of peer sustainability practices from public documentation, review of institutional reports and aerospace-sector publications, and mapping of the upstream and downstream value chain (page 85).
2. Identification of IROs - a long list built against "the list of ESRS topics, sub-topics, and sub-sub-topics indicated in ESRS 1 - AR 16", integrated with ERM findings, with each IRO assigned a prevailing time horizon and a position in the value chain (page 85).
3. IRO assessment - impact materiality assessed by stakeholders on scale, scope, irremediable character (negative impacts only) and likelihood (potential impacts only); financial materiality calculated from ERM as the product of impact and likelihood, with opportunities assessed qualitatively on the same ERM severity and probability scales (page 85).
4. Finalisation and approval - "the IROs exceeding the materiality threshold were identified", material if the final score "met or exceeded a materiality threshold of 10, on a scale of 1 to 25" (page 86). Results were validated by the Sustainability Committee and approved by the Board on 29 January 2026.

Disclosure requirements covered by the sustainability statement

Reference: pages 86-92 (ESRS content index).

Avio prints a full ESRS content index listing each disclosure requirement against the section that carries it, running from ESRS 2 BP-1 through G1-6. Nine disclosure requirements are marked "Subject to phase-in" with no section reference: E1-9, E2-6, E3-5, E4-6, E5-6, S1-7, S1-11, S1-12 and S1-15 (pages 88-90). Two further partial phase-ins are flagged inside otherwise reported rows: S1-8 "Phase-in applied to non-EEA workers" and S1-14 "Phase-in applied to non-employees" (page 90). G1-5 (political influence and lobbying) does not appear in the index at all and no corresponding section exists in the statement.

Two defects in the index are worth recording. First, its introduction says the table "lists the ESRS disclosure requirements that informed the preparation of the AVIO Group's 2024 Sustainability Statement", in a document whose data "refer to the fiscal year ending December 31, 2025" (pages 65, 86). Second, the section references it gives (2.2.2, 3.1.1, 11.1.2 and so on) follow the numbering of the 2024 statement, not the numbering used in this document, where climate is 2.2, pollution 2.3 and business conduct 4.1 (page 64). E5-4 Resource inflows is absent from the index, yet the statement discloses it in full with a materials table on page 134.

Transition plan for climate change mitigation

Reference: pages 113-114.

Avio has no transition plan. "The AVIO Group does not currently have a transition plan for climate change mitigation in place; however, in line with the above, it has set itself the goal of adopting a transition plan in the near future" (page 113). The plan's development "will also need to be managed in synergy with Termica Colleferro and is expected to be finalised shortly, along with its implementation timeline based on the decarbonisation levers that will be identified".

Termica Colleferro is the adjacent company in which Avio holds a 40% stake, generating electricity and thermal energy for the Colleferro facility from an on-site methane-fuelled cogeneration plant, "which ensures a continuous energy supply, necessary for processing aerospace propulsion explosives" (page 113).

Two carbon-sink studies were carried out through Se.Co.Sv.Im: an "analysis of carbon removals in the Se.Co.Sv.Im - AVIO Group's area (Colleferro)" under ISO 14064-1, and "proposals for forest management and reforestation for carbon sequestration and climate adaptation on AVIO-Se.Co.Sv.Im-owned land" (page 113).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 in the E1 chapter (pages 114-115). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (page 114). Climate risks were mapped in the ERM, and Avio "has identified both physical risks and transition risks. The former relate to possible damage at production sites caused by extreme events, including the risk of plant downtime or product loss, while the latter relate to the considerable thermal constancy required in some processing rooms". The E1 IRO table carries three risks and one opportunity (page 114).

No ESRS scenario analysis was performed. "In the course of the analysis of physical risks, transition risks and opportunities, AVIO did not consider high-emission climate scenarios that could entail specific climate-related hazards, nor was a specific assessment carried out to determine how the Group's assets and business activities may be exposed to climate change-related hazards" (page 115). No 1.5°C-aligned transition scenario is named and no temperature projection is given. The EU Taxonomy section confirms no Climate Risk and Vulnerability Assessment has been conducted (page 110).

Instead Avio discloses a business risk plan covering two climate risks: changing external climate conditions affecting energy consumption, and plant shutdowns or product losses from extreme weather (page 115).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 strategy section (pages 80, 114-115). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No resilience analysis was performed. At Group level: "In 2025, no specific resilience analysis of the strategy and business model was conducted" (page 80). For climate specifically: "To date, the Group has not conducted a specific analysis of the resilience of its strategy and business model with regard to climate change, but it does possess an integrated context analysis in accordance with ISO 14001 and ISO 45001" (page 114). That is the finding; Avio does not claim otherwise.

The integrated context analysis is the substitute disclosed. It "identifies the main environmental and safety-related factors and events that could impact the Company's activities and/or performance, including risks, threats, opportunities and the associated countermeasures", is updated annually, and covers the Colleferro, Airola and Sardinia sites (page 114). Scenarios tested for plant shutdowns or product loss were "climate-induced fires, earthquakes, flooding and tornadoes", each judged remote, with "a plan ... underway to improve the structural resilience of buildings". An Internal Emergency Plan covers them all (pages 114-115).

No areas of uncertainty are quantified and no assessment of capacity to adjust or adapt is given (page 115).

Policies related to climate change mitigation and adaptation

Reference: pages 115-116.

Avio relies on its long-standing Environmental Policy, which "formalises the commitment to continuously improving its environmental performance while minimising the impact of its production site and facilities" and is "an essential aspect of the Environmental Management System (EMS)" certified to ISO 14001 (page 115). At the French Guiana subsidiary Regulus, the Charter of Ethics makes explicit "its commitment to pursuing eco-efficiency", and the company has adopted a Quality, Occupational Health and Safety and Environmental Policy inspired by ISO 14000, with an annual environmental and energy management report to the DGTM authority, which then audits Regulus on specific environmental areas (page 115).

The gap is stated plainly by the company: "To date, the Environmental Policy does not define specific management methods relating to climate change mitigation, climate change adaptation, energy efficiency or the promotion of renewable energy" (page 115). No dedicated climate policy exists, and the E1 policy disclosure therefore covers none of the four areas ESRS E1-2 asks about directly.

Actions and resources in relation to climate change policies

Reference: page 116.

Climate change initiatives carried out in 2025 (page 116):

• "Enhancement of the energy consumption monitoring system to provide more granular details across AVIO S.p.A. buildings";
• "Installation of electric charging stations for executive vehicles";
• "Energy efficiency improvements through the installation of LED lighting".

To support the Environment Manager, senior management created a Health, Safety and Environment (HSE) Department coordinating Health & Safety, Environment and Management Systems, and Seveso Law Compliance (page 116).

Three limitations are disclosed by Avio itself (page 116): "AVIO does not categorise its climate change mitigation actions by decarbonisation lever, including nature-based solutions"; "when describing the outcomes of climate change mitigation actions, GHG emission reductions achieved or projected are not included"; and "the Company does not report whether and to what extent its ability to implement actions depends on the availability and allocation of resources".

Resources. "The aforementioned interventions are included within the general CapEx/OpEx item of the Group. In addition, the amount of CapEx/OpEx related to actions implemented in 2025 is not significant compared to the total" (page 116).

Targets related to climate change mitigation and adaptation

Reference: page 116.

"The Group has not set quantitative targets" (page 116). There is no base year, no absolute or intensity reduction target for Scopes 1, 2 or 3, no 2030 milestone and no net-zero date. Avio does not claim alignment with a 1.5°C pathway and does not report an SBTi commitment or validation.

What is disclosed instead are three qualitative "improvement targets relating to its main environmental impacts, with the intention of governing and minimising them" drawn from the Sustainability Plan (page 116):

• improvements to facilities producing atmospheric emissions;
• improvement in energy consumption management;
• improved efficiency of the Environmental Management System.

Avio states the work is under way: "The Group is currently in the process of defining specific quantitative targets for the reduction of GHG emissions and/or other quantitative objectives. Specific targets are also being developed for the planned decarbonisation levers and their overall quantitative contributions to achieving GHG emission reduction targets" (page 116).

The absence of targets should be read alongside the incentive scheme, where an energy efficiency metric - reduction over three years in the ratio of electricity consumption (kWh) to manpower hours - carries 5% of the 2026-2028 Performance Share Plan weighting, but no GHG metric does (page 72).

Energy consumption and mix

Reference: pages 116-118.

Colleferro, the Group's main production facility, draws electricity and steam from the adjacent Termica Colleferro cogeneration plant, "which operates exclusively on methane combustion" (pages 116-117). French Guiana adds electricity and diesel for fleets and a generator.

"In 2025, in continuity with 2024, 100% of the Group's energy consumption came from non-renewable sources", with total consumption up approximately 22% "mainly due to the expansion of production and business" (page 117).

Avio confirms it "operates in the manufacturing sector, and therefore within a high environmental impact". Energy intensity in high climate impact sectors was 0.17 MWh per Euro thousand of net revenue in both 2024 and 2025, on net revenue of Euro 480,420 thousand and Euro 583,690 thousand respectively (page 118).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 118-122.

2025 (tCO2e): Scope 1 1,226; Scope 2 location-based 25,994; Scope 2 market-based 31,373; Scope 3 333,874. Total Scope 1+2 location-based 27,219 and market-based 32,599. Total including Scope 3: 365,769 (location-based) and 371,149 (market-based) (pages 118-120).

"Compared to 2024, total (LB) emissions decreased by about 38%. This decrease, mainly attributable to Scope 3, is due to methodological refinements and, in particular, regarding the emissions of Category 1 'Purchased goods and services', to the limitation of the spend-based approach to the purchase of goods and services, other than raw materials" (page 118). Scope 2 2024 figures were restated "following a change due to the unit of measurement" (footnotes 85-86, page 119).

Scope 3 by category, 2024 to 2025 (tCO2e): Cat 1 441,198 to 289,718 ("approximately 87% of Scope 3"); Cat 2 39,575 to 21,230; Cat 3 "Not reported" to 4,682; Cat 4 75,881 to 6,727; Cat 5 134 to 148; Cat 6 1,521 to 4,698; Cat 7 6,494 to 6,671 (pages 119-120).

Categories 11 and 12 "cannot currently be reported" because Avio's propulsion emissions "cannot be converted according to any of the applicable tables, as they generate completely different chemical species", pending standards set with ESA (page 120). GHG intensity fell from 1.23 to 0.63 tCO2e per Euro thousand (location-based) and 1.27 to 0.64 (market-based) (page 122).

GHG removals and mitigation projects financed through carbon credits

Reference: page 122.

A nil return. "To date, the AVIO Group does not implement activities aimed at permanently absorbing or actively supporting the absorption of greenhouse gas (GHG) emissions from the atmosphere. However, AVIO has set itself the goal of analyzing and evaluating these initiatives following the completion of systematic and detailed monitoring activities of its consumption and environmental footprint, so that it can identify and prioritize areas of intervention in the environmental and energy fields" (page 122).

No GHG removals are reported in own operations or the value chain, no carbon credits were cancelled in the reporting year, none are planned to be cancelled in future, and no net-zero or carbon-neutrality claim is made.

Related work sits under E1-1 rather than here: through Se.Co.Sv.Im, Avio commissioned an "analysis of carbon removals in the Se.Co.Sv.Im - AVIO Group's area (Colleferro)" measuring carbon absorption within its operational boundaries in compliance with ISO 14064-1, and a study on "proposals for forest management and reforestation for carbon sequestration and climate adaptation on AVIO-Se.Co.Sv.Im-owned land" (page 113). Avio states it "will measure the degree of offsetting through carbon absorption and sustainable forest management of green areas within its Colleferro area" (page 114), but no quantified removals figure is disclosed for 2025.

Internal carbon pricing

Reference: page 122.

A nil return. "AVIO does not currently apply internal carbon pricing systems. As with the matter of the previous section, the Group aims to develop its efforts in this regard downstream of the activities necessary to complete the timely monitoring of its consumption and environmental footprint" (page 122).

No shadow price, internal fee, implicit price or carbon-price scheme is in operation, so none of the E1-8 datapoints - type of scheme, scope of application, carbon price per tonne, share of emissions covered, or how the price is used in decision-making - arises. Avio makes no claim that internal carbon pricing informs capital allocation or investment appraisal.

The position is consistent with the rest of the E1 chapter: no transition plan (page 113), no quantitative GHG targets (page 116) and no categorisation of mitigation actions by decarbonisation lever (page 116). The Group frames all three as sequenced after the completion of footprint monitoring rather than as decisions taken against internal carbon pricing.

Policies related to pollution

Reference: pages 123-124.

Two instruments carry the topic. The Environmental Policy and ISO 14001 Environmental Management System commit Avio "to improving facilities that generate atmospheric emissions and rationalising the use of environmentally hazardous and harmful substances and preparations" (page 124). Separately, the Major Accident Hazard Prevention Policy under Legislative Decree No. 105/15 as amended (Seveso Ter) forms part of the SSl-PRI Management System and "declares the actions and objectives to protect the environment and safety, maximizing prevention against the occurrence of possible accidental scenarios related to work activities, which may result in pollution". Its site of application is Colleferro, "involving its local community and relevant authorities, including the Regional Technical Committee (RTC)" (page 124).

Because Colleferro falls under the Seveso upper threshold, Avio maintains an Internal Emergency Plan with quarterly training and periodic drills, and an External Emergency Plan under the prefecture, "the latest edition of which was issued by prefectural decree in December 2024" (page 124). A Safety Report is prepared and reviewed every five years under Articles 15 and 16 of Legislative Decree No. 105/15.

Actions and resources related to pollution

Reference: pages 123-125.

Two ongoing actions are named (page 124):

• Issuance and review of the Safety Report under Articles 15 and 16 of Seveso Ter, which "analyses qualitatively and quantitatively industrial processes and accident scenarios for both safety and environmental aspects and reports prevention measures", with the Public Administration acting as control body through approval of the report and inspection of the mandatory management system under Article 27.
• The Internal Emergency Plan, which "puts in place all measures for immediate action in the event of an industrial accident, both of a major event under Seveso Ter and of an environmental event". Its stakeholders are the Municipalities of Colleferro, Segni and Artena, the National Fire Department, the CTR, the Prefecture, the Lazio Region, the Civil Protection, ARPA, the Metropolitan City of Rome and the ASL.

The largest activity is soil remediation by Se.Co.Sv.Im in the River Sacco Basin Site of National Interest, inherited from the site's previous owner: safety works at the Pozzolana Quarry; ARPA 1 remediation; construction of a permanent storage site; ARPA 2 safety works run by the Lazio Region since 2019; aquifer emergency safety works using a hydraulic dam with pre-treatment plants; approval decrees for six land hot-spots; and the MISP ARPA 2 project begun in 2024, "with completion scheduled for 2027" (pages 123-124).

Targets related to pollution

Reference: page 125.

No quantitative targets are set. "The AVIO Group has set as a high-level target the rationalization of the use of environmentally hazardous and harmful substances and preparations" (page 125). There is no base year, no reduction percentage, no target year and no split by pollutant.

Supporting statements (page 125):

• "AVIO always works in the prevention and control of air pollutants related to industrial production, through the adoption of BAT where possible and the implementation of the Environmental Management System and Safety Report in accordance with Seveso Ter."
• Industrial effluents "are treated by a sewage treatment plant operated by the Colleferro Municipality Consortium Company, which is subject to Integrated Environmental Authorisation (IEA) and authorized through Regional regulation (PAUR)."
• "SVHC substances are kept under control by the environment and Seveso management system. The goal is minimization of their use, limiting them only to must-have applications and the absence of alternative materials, for space qualification and/or thruster performance."
• "New systems are being developed to reduce the use of SHC and SVHC materials, such as the MPGE thruster for upper stages."

Pollution of air, water and soil

Reference: page 125. The report heads this section "E2-4 - Pollution of air and soil".

"Given AVIO's type of business and following the double materiality assessment, air and soil pollution were found to be significant" (page 125). Under the Underground Water and Soil Characterization Plan adopted in January 2018, which "provides for soil monitoring on a 10-year basis", Avio states that "for the biennium 2024-2025, there are no emissions of pollutants into the soil" (page 125).

Air emissions "refer exclusively to the activities of Avio S.p.A., while for the other companies of the Group, no pollutant emissions are recorded". The figures "are derived from point measurements made annually at individual chimneys and documented through the relevant Test Reports" (page 125).

"Compared to 2024, there is an 8% increase in emissions due to increased production and business expansion" (page 125).

No microplastics figure is given, and no emissions to water are quantified here; industrial effluent is described under E2-3 and E3-1 (pages 125, 127-128).

Substances of concern and substances of very high concern

Reference: pages 125-126.

Inflow limb (ESRS E2 paragraph 34, first limb). "During 2025, the substances of concern used by Avio S.p.A. and Avio Guyane amount to about 294 tons. For the remaining companies of the Group, no use of concerning substances is recorded. The decreasing difference from 2024 is due to a refinement of the methodology for calculating utilization data" (page 125). A 43-line table on page 126 names every substance with its weight, totalling 2,029,916 kg in 2024 and 294,431 kg in 2025. Named entries include ammonium perchlorate (1,959,284 kg to 236,932 kg), isophorone diisocyanate, MAPO, toluene, xylole and RESIN HXE-23.

Substances of very high concern. "For the Avio Group, there is no use of substances of very high concern during production" (page 126). That is a complete nil return for the limb ESRS E2 paragraph 35 requires to be presented separately.

Outflow limb (paragraph 34, second limb) is not answered. No amounts of substances of concern leaving Avio's facilities as emissions, as products, or as part of products are given, and there is no split by hazard class. The impact sits in own operations - the E2 IRO table records "Use and potential release of polluting, hazardous and substances of very high concern during the production process" as a direct, potential negative impact (pages 81, 123) - so the ESRS 1 value chain relief does not reach it.

Policies related to water and marine resources

Reference: pages 127-128.

"Through its Environmental Policy, the AVIO Group is committed to rationalizing water resources and reducing water consumption" (page 127). The policy is the same instrument used for E1, E2 and E4; the statement cross-refers to the MDR-P table for its content and governance.

Italian companies withdraw water for three purposes (page 127):

• Industrial water - "Output water from the consortium purification facility is analysed and fed into the industrial water network if it meets legal limits. This helps limit water withdrawals from natural sources." Not required at Airola, Turin or the Rome registered office; sourced from the public network at Perdasdefogu. Colleferro has a chemical sewer system for industrial effluent "completely separate from the stormwater conveyance system".
• Fire-fighting water - public network at Perdasdefogu, TTA industrial district network at Airola.
• Drinking water.

Through Se.Co.Sv.Im the Group "owns all plant and regulatory assets, allowing full independence from the use of water from public aqueducts", and these assets "also provide industrial water supply to third parties". On 1 January 2025 "the supply of potable water to AVIO was transferred from CSAP to Se.Co.Sv.Im" (page 127).

Actions and resources related to water and marine resources

Reference: page 128.

Actions concentrate on the Colleferro area, "which is classified as a water-stressed area" (page 128):

• periodic monitoring of industrial water supply and fire-prevention networks;
• recurrent monitoring of the industrial water network;
• maximising the recirculation of industrial water;
• recurring monitoring of the stormwater network, with treatment of the first rainwater, carried out by Se.Co.Sv.Im for the former industrial areas under its control;
• treatment and continuous monitoring of groundwater and MISE (emergency safety enhancement), again the responsibility of Se.Co.Sv.Im.

Resources. "AVIO's CapEx and OpEx for 2025 fall within the maintenance activities of the Facility and the land", with no separable amount disclosed. Avio frames water action as an indirect consequence of process improvement: it "pursues in fact as its primary goal the reduction of the environmental impacts of its industrial activities as an indirect positive effect of improving production processes, along with timely maintenance controls" (page 128). No action is reported for the value chain and none for marine resources.

Targets related to water and marine resources

Reference: page 128.

No quantitative targets. "The AVIO Group includes water protection and the rationalisation of water resources across all its sites among its environmental goals. To date, these goals have not included the formalisation of specific quantitative monitoring indicators" (page 128). The goals "are aligned with the risk and opportunity analysis of the integrated analysis of the Environment and Occupational Health and Safety Management System and Major Accident Hazards".

Avio scopes the topic narrowly: "AVIO does not use public drinking water or marine resources. In fact, AVIO's processes do not involve water use except for plant cleaning operations and fire mains" (page 128). Industrial water is supplied through Società Consortile per Azioni Servizi Colleferro from adduction plants owned by Se.Co.Sv.Im, each processing room is connected to a chemical sewer entirely separate from stormwater conveyance, and effluent goes to a consortium treatment plant "which treats it and, after compliance verification, most of it is fed back into the industrial network". "This process to recover and reuse industrial water actually rationalises the use of this resource" (page 128).

No target is set for water consumption, withdrawal, discharge or recycling, and none for water-stressed areas specifically, although Colleferro is identified as water-stressed under E3-2 (page 128).

Water consumption

Reference: page 129.

"In 2025, the AVIO Group's water consumption was 535,243 m3" (page 129). The figure is presented both for all areas and for areas at water risk, including areas of high water stress - the two are equal, consistent with Colleferro being classified as water-stressed (page 128). The report states "The figure entered is actual as it is derived from verifiable measurements and readings" (footnote 103, page 129), with consumption at the commercial companies Avio USA, Avio France and the Avio Branch estimated "using a proxy that values the office activities performed" (footnote 102).

Consumption rose about 13% while recycled and reused volume fell roughly 40%, from 157,159 m3 to 94,644 m3. The statement does not explain the fall in recycled volume, and no water withdrawal or discharge figures are given alongside consumption.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: page 129.

Avio has no biodiversity transition plan and explains why. "Through its environmental policy, AVIO pays close attention to ecosystems and the protection of biodiversity" (page 129). The Colleferro site "as an industrial site pre-existed decades before Avio's operations began. These are therefore from the outset perfectly integrated and totally compatible with the environmental substrate, including the ecosystems present and biodiversity, since, as discussed these have settled since the beginning of the last century with the factory."

The conclusion drawn: "By the nature of its business, AVIO has no impacts on such ecosystems except through its industrial activities, for which, the environmental policy establishes clear objectives of compliance, prevention and protection. Compared to the implementation of a dedicated transition plan, therefore, the best action turns out to be the pursuit of the aforementioned environmental policy objectives with special reference to preservation and protection, since the concept of 'transition' is not applicable" (page 129).

No alignment with the Kunming-Montreal Global Biodiversity Framework, no biodiversity targets tied to a plan, and no plan milestones or resources are disclosed.

Policies related to biodiversity and ecosystems

Reference: page 131.

The Environmental Policy is the framework instrument, applying Group-wide "thus also affecting sites defined as biodiversity-relevant". In relation to the E4 impacts it commits Avio to (page 131):

• rationalisation of the use of harmful and environmentally hazardous substances and preparations;
• improved effectiveness of the Environmental Management System;
• protection and control of all environmental matrices.

Three limitations are stated by Avio itself (page 131):

• "In view of the Group's activities and impacts, it was not deemed necessary to implement a dedicated policy on the use of sea water or oceans."
• "since the only direct impact turns out to be potential, the consequences of the latter are not explicitly addressed through the policies the Group has in place, as is the issue of materials procurement, the impact of which is not attributable to the Group directly."
• "this policy also does not discuss possible transition risks related to the issue of biodiversity."

Avio also confirms it "has not currently assessed as necessary the drafting of specific policies related to the protection of ecosystems and biodiversity", the topic sitting instead within the Environmental Policy and the Major Accident Prevention Policy (page 132). No reference to the Convention on Biological Diversity, deforestation policy or traceability commitments is made.

Actions and resources related to biodiversity and ecosystems

Reference: page 131.

Actions run through Se.Co.Sv.Im:

• "several remediation projects were underway in 2025, two of which were approved by decree at the end of the year". These concern the Colleferro site, with the local community and the environmental authorities (MiTE, Lazio Region, ARPA, ISPRA, Metropolitan City, Municipality of Colleferro) as stakeholders. "Remediation activities are multi-year in nature and depend on the implementation of the ARPA2 project, the responsibility of the Lazio Region."
• "Certification of successful reclamation was also obtained in 2025 in one of the areas owned by Se.Co.Sv.Im., achieving the goal that had been set for the Company in 2023."
• Following 2024 VINCA clearance for the preventive plan for industrial expansion at the Test Center, "AVIO submitted the application for the Strategic Environmental Assessment (SEA) of the initiative in order to obtain environmental compatibility."
• An audit of the ISO 14001 management system to verify operational control of environmentally impactful activities, "capable of preventing disturbances in environmental matrices and ecosystems".

Biodiversity offsets are not used: "Given the nature of the Group's operations and the impacts discussed, and in particular the positive impact identified, resorting to biodiversity offsets is not relevant" (page 131). No monetary resources are quantified for E4 actions.

Targets related to biodiversity and ecosystems

Reference: pages 131-132.

Qualitative only. Avio "has therefore prepared a high-level target related to the protection of biodiversity, referring to the protection of the areas in which the Group operates, further broken down into the following sub-target: to promote and encourage the protection of the natural resources of the areas in which the Group operates through the management and maintenance of areas and greenery with respect for biodiversity, in line with the Environmental Policy adopted by the Group" (page 131). No base year, no measurable value and no target date are given.

Effectiveness tracking. "Group processes are managed and monitored by the functions that have day-to-day responsibility for ensuring compliance with our policies and applicable regulations. Environmental aspects are also managed on an ongoing basis through ISO 14001 certification. The effectiveness of the actions taken and thus the progress of these goals are evaluated and disclosed annually through the Annual Report under the AIA [Integrated Environmental Authorisation]" (page 132). Related actions are disclosed in the same document and through the sustainability statement, "which the Group has been publishing since 2017".

No ecological-threshold-based target, no biodiversity offset target and no target on land-use change, freshwater use or sea-use change is disclosed.

Impact metrics related to biodiversity and ecosystems change

Reference: page 132, with the site descriptions on pages 129-130.

The metric disclosed is land area under management rather than a species or condition indicator: "part of the area hosting the Group's activities are located in the municipalities of Colleferro, Segni and Artena, which is a biodiversity-sensitive area. Specifically, more than 910 hectares is owned by Se.co.sv.im, whose work nevertheless brings positive impacts from a biodiversity point of view not only in the areas affected by reclamation activities, but also in the protection and land management of all other areas not dedicated to industrial activities" (page 132).

Two protected designations are identified (pages 129-130):

• The AVIO Test Center in the municipality of Segni sits in a Natura 2000 Site of Community Interest (SCI).
• Part of the Colleferro industrial area "is also located in a protected area under the Birds Directive, which has 31 protected species for European Union and 9 protected habitats for European Union."

Concluding statements: "There are no negative impacts related to AVIO's activities on threatened species" (page 130), and "the Group does not contribute through its activities to changes in land, freshwater or sea use in a direct way" (page 132). No hectare figures for land-use change, no species-population metric and no ecosystem-condition metric are reported.

Policies related to resource use and circular economy

Reference: pages 132-133.

The Environmental Policy applies to all Group companies and serves "as the basis for evaluating environmental performance, particularly regarding waste management improvements" (page 132). Since 2010 an Environmental Management System certified to ISO 14001 has been in place for Avio S.p.A., encompassing "the set of procedures and instructions for the operational control of all the company's environmentally impactful activities, also with the aim of realizing an operational control of industrial processes, designed to ensure the proper management of waste, starting from its production and ending with its disposal. Through internal self-control audits and external control audits, the proper implementation of procedures related to the waste cycle is verified" (pages 132-133).

The policy commitment on resource use: "Through the adoption of its Environmental Policy, AVIO seeks to optimise resource use, including the use of virgin resources, reduce consumption and enhance efficiency, starting from the process design phase, taking into account the entire product lifecycle" (page 133).

No policy addressing sustainable sourcing of renewable resources, waste hierarchy prioritisation or the phase-out of virgin non-renewable materials is disclosed separately; the statement cross-refers to the MDR-P table for policy details (page 133).

Actions and resources related to resource use and circular economy

Reference: page 133.

Four actions are named (page 133):

• Separate collection of waste closely linked to production. "Separate collection has been implemented at all AVIO sites, which has come to recognise many different EWC codes in order to be able to facilitate sending waste to different recovery destinations. The activity is recurring and is updated annually with new waste characterization where necessary."
• Maximising waste sent for recovery. "In 2025, a waste diverted from disposal percentage of 65% was achieved, of which 20% was through recycling operations and 80% through recovery operations. The success of the process depends in part on the availability of firms that carry out waste treatment."
• Sending excess materials not used in the production cycle to new use. "Space materials are particularly valuable and belong to the high quality range, and in view of these characteristics, they are difficult to reuse."
• Developing new products using reused or non-hazardous materials, with procurement logic that minimises excess. These developments "concern the Colleferro and Sardinia sites, with a time horizon of several years".

Resources. "AVIO's CapEx and OpEx for 2025, although not significant, are included within the general CapEx/OpEx item of the Group" (page 133).

Targets related to resource use and circular economy

Reference: pages 133-134.

"The Group has not set quantitative targets" (page 133). What is disclosed are the macro-areas of the Sustainability Plan, "broken down into the qualitative objectives 'Minimise Impact of Waste' and 'Develop New Products and Technologies', which seek to guide the Group's actions" (page 133). "The targets related to resource use and circular economy refer to the inflows and outflows of materials with the intention of reducing, in future products and technologies, the inflow and outflow of materials."

Two constraints are stated (pages 133-134):

• "There are no specific targets related to the sustainable sourcing and use of renewable resources", although "a number of products from renewable plant sources are used within the production processes, and at the same time Se.Co.Sv.Im. carries out cultivation on an area of about 60 hectares of sunflowers intended for oils and fuels for industrial use."
• "As an entity not authorised to process waste (an activity concerning a specific category framed under Legislative Decree No. 152/06, as amended), AVIO cannot treat or recycle any waste internally, but only optimise the use of materials before they become waste, and this is done through waste reduction, which, however, is not explicitly reportable, nor does it allow for more virtuous percentages to be computed in waste recycling indicators."

Resource inflows

Reference: page 134. Note that E5-4 does not appear in Avio's ESRS content index (page 89), yet the statement discloses it in full under its own heading with a complete materials table.

"there was an inflow of resources of approx. 740 tons of material in 2025, an increase of about 39% from 2024. The increase is mainly due to the inclusion of composite propellant quantities for the first time in 2025, reflecting an extension of the indicator coverage" (page 134). The table totals 533,144 kg in 2024 and 739,600 kg in 2025.

Largest 2025 entries (kg): composite propellant 271,300 (nil in 2024); ammonium perchlorate 189,300 (down from 292,781); pre-impregnated carbon fibre 123,365 (up from 65,573); Kevlar matrix tires 69,000; aluminium powder 44,200; polymers 30,400; LINER 2,953; Vestanat IPDI 2,850; metallic powder 3,320; acetone 1,500 (page 134).

Composition. "all materials used fall within the category of technical materials; therefore, no information is provided regarding biological materials or secondary components. ... Estimates were not used to calculate incoming resources" (page 135). On secondary content: "quality constraints imposed by the industry objectively limit this action and make the amount of secondary components reused or recycled, secondary intermediates and secondary raw materials, not material for reporting purposes" (page 135).

Resource outflows

Reference: pages 135-136.

Avio reports resource outflows entirely through waste. Total waste produced rose from 707 t in 2024 to 1,057 t in 2025 (page 135).

Preparation for reuse is nil in both years. Hazardous waste totalled 215 t in 2024 and 398 t in 2025, "of which radioactive" nil in both years; "No radioactive waste was generated in 2025" (page 136).

No product-level durability, reusability, repairability or recyclability rates are disclosed, and no recycled content of outflowing products is given. "It is specified that estimates are not used to calculate outgoing resources" (page 136). The 2025 scope excludes the share of waste from Servizi Colleferro that was included in 2024 (footnote 107, page 135).

Waste

Reference: pages 135-136, with the recovery action on page 133.

Total waste produced was 1,057 t in 2025, up from 707 t in 2024. Of that, 700 t was diverted from disposal (70 t hazardous, 630 t non-hazardous) and 357 t was directed to disposal (327 t hazardous, 30 t non-hazardous). Non-recycled waste was 920 t, or 87% of the total, up from 529 t and 75% in 2024 (page 135).

Within the diverted stream, recycling accounted for 13 t hazardous and 124 t non-hazardous, and other recovery operations for 57 t hazardous and 506 t non-hazardous; preparation for reuse was nil in both years. Within the disposal stream, incineration took 33 t hazardous and 20 t non-hazardous, landfill 1 t non-hazardous, and other disposal operations 294 t hazardous and 9 t non-hazardous (page 135). Total hazardous waste was 398 t in 2025 against 215 t in 2024, none of it radioactive (page 136).

Under E5-2, Avio reports that "In 2025, a waste diverted from disposal percentage of 65% was achieved, of which 20% was through recycling operations and 80% through recovery operations" (page 133).

One caveat on comparability: 2024 figures include waste generated by Servizi Colleferro, while 2025 figures cover Avio S.p.A., Spacelab, Se.Co.Sv.Im, Regulus and Avio Guyane (footnote 107, page 135).

Policies related to own workforce

Reference: pages 138-142.

Avio lists ten policy instruments covering all workers: Diversity policy; Gender Equality Policy; Human Rights Protection Policy; Welfare plans; Remuneration policy - Talent development; Flexible working policy; Occupational Health and Safety and Major Accident Prevention Policy; the Code of Ethics; Charter of Ethics; and the Quality, Occupational Health and Safety and Environmental Policy applied at Regulus (page 138).

Health and safety (page 139). An Occupational Health and Safety and Major Accident Prevention Policy sits on the integrated management system certified to ISO 45001 by an independent external body; the HSEIS Organisational Unit "has overall responsibility for the implementation and control of the integrated OHS-MAP management system". Regulus operates the Manuel Qualité, Sécurité, Environnement.

Diversity and inclusion (pages 139-140). The Diversity Policy was approved by the Board. The Code of Ethics lists grounds of discrimination as "sex, gender, geographic origin, religion or other personal characteristics". Inclusion of vulnerable categories runs "through the activation of the agreement with the Labor Office for the purpose of hiring a target number of people from vulnerable categories". Avio holds UNI/PdR 125:2022 Gender Equality certification, obtained 21 February 2025, with a Gender Equality Steering Committee and Gender Equality Policy (pages 73-74).

Processes for engaging with own workers and workers' representatives

Reference: page 142.

"Regarding the involvement of the company's own workforce in impact materiality assessments, we note that key representatives and their teams from the AVIO Group's core areas and functions were engaged in the process" (page 142).

In 2025, "regular meetings were held with the General Workers' Representative Body (RSU) to involve and inform union representatives on Company developments, temporary employment contract renewals, and new initiatives" (page 142).

Operational responsibility sits with the Human Resources and Organisation Department, which reports directly to the Chief Executive Officer (page 142).

Three limitations are stated by Avio itself (page 142):

• "There are no specific agreements with worker representatives regarding human rights", the Group relying instead on the Human Rights Protection Policy, the Code of Ethics and the Regulus Charter of Ethics.
• "The Company does not directly evaluate the effectiveness of its own workforce engagement or any resulting agreements or outcomes."
• "No specific measures have been adopted to understand the perspectives of particularly vulnerable worker categories, as all measures equally involve all AVIO employees."

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 142-143.

For the one material negative impact - work-related injuries and accidents - "AVIO has a specific procedure in place that describes the processes, activities and controls put in place to remedy in the event that the impact in question occurs" (page 142). Its steps are: injury detection; injury analysis and reporting to INAIL; recording the injury; injury monitoring; collection and consolidation of injury data; and reporting of work-related injury data.

The grievance channel is the Whistleblowing Procedure, adopted in compliance with the Italian Whistleblowing Decree and "allowing reports to be submitted electronically" (page 143). Protections cited are "the prohibition of retaliation and safeguards against it, in addition to support measures, assistance and free advisory services from third-sector organisations for both the whistleblower and the person involved".

Corrective actions are handled through "periodic internal meetings organised by the relevant company functions, within which any recorded injuries and corrective actions taken are discussed, as well as the status of progress about their implementation" (page 144). No figure for reports received is disclosed under S1-3; the S1-17 tables report nil incidents and nil complaints for 2025 (page 154).

Taking action on material impacts on own workforce

Reference: pages 143-144.

Actions disclosed for 2025 (pages 143-144):

• Training. "In 2025, training courses saw an expansion of soft skills", including "Mindfulness and Work-life balance courses, introduced for the first time at AVIO in support of the HR Project 'AVIO People Caring'".
• Diversity and inclusion. "a STEM career day dedicated to women", initiatives with Valore D, the AEROSPACE JOB TALK with ASI and Adecco, and "a voluntary course ... with the goal of mitigating Bias".
• Well-being agenda on four pillars: Physical, Social, Emotional (coaching and mentoring) and Financial (retirement and pension courses, a loans advice desk).
• Variable Bonus system linked to the FY2025 Target Plan, where "the weight of individual goals increased from 50% to 70%".
• Occupational health and safety, including Ministry of the Interior control of explosive and comburent substances at Colleferro and the Internal Emergency Plan under Legislative Decree No. 105/2015.
• Collective agreements with RSUs, an annual Merit and Development Policy, and exit interviews for leavers.

Resources: "The above interventions are included within the Group's general CAPEX/OPEX item and are not significant". Avio adds "There are no impacts from transition plans on the Company's own workforce as there a plan to transition to a green economy has not yet been prepared" (page 144).

Targets related to own workforce

Reference: page 144.

No measurable targets are disclosed. Avio "has prepared a set of objectives related to its own workforce, which are set out within the Sustainability Plan", and "issues and adopts an improvement programme which constitutes the framework for defining the organisation's goals, targets and, therefore, action to ensure ongoing improvement in performance related to its workforce, including through continuous dialogue with union and employee representatives" (page 144).

The two objectives given are qualitative (page 144):

• "Become a European leader for aerospace talent";
• "Fostering corporate growth geared towards diversity and appreciating people's worth".

Quantified workforce commitments do exist elsewhere in the report but are not presented as S1-5 targets. The 2026-2028 Performance Share Plan attaches 5% of the incentive weighting to gender diversity, defined as the ratio of female employees to total employees; 5% to the gender pay gap, the ratio of average female to male remuneration; and 5% to employee training, measured as average annual hours of training over the three-year period (page 72). Under S3-5, the Group states a target of "zero events with potential risk of major accidents", which bears on worker as well as community safety (page 160).

Characteristics of the undertaking's employees

Reference: pages 144-146.

"In line with the Group's ambition to create safe jobs, during 2025 the number of employees increased by 5% compared to 2024, consistent with business growth" (page 144). Headcount is reported "also taking into account employees whose last day of employment was on December 31, 2025" (footnote 108, page 145).

"From 2025, employees from French Guiana have been considered in Reporting as employees belonging to the European Economic Area" (footnote 109, page 145), which explains the movement between the Europe and non-EU rows.

By contract type (page 145). Permanent 1,404 (1,184 male, 220 female); fixed-term 22 (15 male, 7 female); non-guaranteed hours nil. By working time: full-time 1,424; part-time 2 (1 male, 1 female).

Turnover (pages 145-146). Outgoing employees rose from 99 in 2024 to 119 in 2025, and the turnover rate from 7% to 8% (107 male at 9%, 12 female at 5%). The rate "is calculated by taking into consideration the total number of departures divided by the total number of employees as of December 31, 2025" (footnote 110, page 145).

Collective bargaining coverage and social dialogue

Reference: pages 146-147. The index flags a partial phase-in on this row: "Phase-in applied to non-EEA workers" (page 90).

"Seeking to ensure strict compliance with the legislation, AVIO's employment contracts with its employees comply with applicable national and international standards" (page 146). The Group "undertakes to promote the ongoing exchange of information and advice with trade unions on issues of common interest", conducted "through constant liaison in order to promote a participatory corporate culture" (page 146).

The 2024 figures were identical in percentage terms: 1,351 of 1,355 employees, 99.7% (page 146).

The four uncovered employees are at AVIO USA Inc., "to which collective bargaining agreements are not applicable" (footnote 111, page 146). "Agreements are negotiated directly with national or local unions representing the company's workers, where applicable" (footnote 112). From 2025 French Guiana employees are counted within the European Economic Area (footnote 113).

Diversity metrics

Reference: pages 146-148.

"Executives" are defined as "employees whose qualification ranks one and two levels below the governing and supervisory bodies" (footnote 114, page 146). The 2024 comparatives were Executives 49 (44 male, 5 female), Managers 350 (287/63), White-collar 589 (476/113) and Blue-collar 367 (343/25), on a total of 1,355 with a 2024 category mix of 3% executives, 26% managers, 44% white-collar and 27% blue-collar (pages 146-147).

Women were 227 of 1,426 employees, 15.9%, and 5 of 48 executives, 10.4%, at the end of 2025. The "Other" and "Not disclosed" gender categories are nil throughout.

At board and committee level the picture is different: across all administrative, management and supervisory bodies 13 of 25 members (52%) are women, including 6 of 11 Board members (page 71).

The report also presents a distribution by age group across the four employee categories (page 147). Gender diversity carries a 5% weighting in the ESG component of the 2026-2028 Performance Share Plan, measured as the ratio of female employees to total employees (page 72), and Avio holds UNI/PdR 125:2022 Gender Equality certification obtained on 21 February 2025 (page 74).

Adequate wages

Reference: pages 148-149.

All employees receive an adequate wage. The tables report nil employees who do not receive an adequate wage, and 0%, for Italy, France, French Guiana and the USA in both 2024 and 2025, against a 2025 population of 1,297 in Italy, 16 in France, 109 in French Guiana and 4 in the USA (pages 148-149).

The basis is collective bargaining: "As reported within S1-8 - Collective Bargaining Coverage and Social Dialogue Group employees, with the exception of AVIO USA, are 100% covered by collective bargaining. The relevant collective agreements comply with minimum wage requirements in accordance with Directive (EU) 2022/2041 of the European Parliament and of the Council on adequate minimum wages in the European Union" (footnote 115, page 148). "For employees in French Guiana, French collective bargaining applies. For AVIO USA employees, the minimum wage level is established based on an assessment of the wage level necessary for a decent standard of living" (footnote 116).

Training and skills development metrics

Reference: pages 149-151.

Average hours of training per employee, 2025 (page 151):

The 2024 comparatives were Executives 22, Managers 39, and a Group total of 36 hours, so average training hours fell from 36 to 29 (page 151). Average hours "were calculated with respect to the total hours of training of employees in the categories by the total number of employees" (footnote 119, page 151).

Performance and career development reviews are run through two systems (page 149): the Performance Appraisal System, an annual assessment of white-collar and blue-collar employees without performance-based pay, focused on "one organisational-behavioural objective, and a second role-based objective"; and the VRL/MBO system covering individual and company-wide targets, where "Appraisals are carried out by managers, who are responsible for assigning and sharing annual work targets with employees". Temis staff "are assessed annually on their acquired skills and those required for the specific role set out in the job description" using a Skills Matrix, and the Regulus Career Committee "continued to analyse roles and prospects for the professional development of all staff".

Health and safety metrics

Reference: pages 151-152. The index flags a partial phase-in on this row: "Phase-in applied to non-employees" (page 90).

The rate "is calculated as follows: (total number of injuries/hours worked) * 1,000,000" (footnote 123, page 152), and hours worked include employees terminated during the year (footnote 122). The column for "Other workers operating at the undertaking's sites" is nil against every line in both years.

Injuries rose from 5 to 6 and days lost from 69 to 84, with the injury rate up from 2.14 to 2.37 per million hours worked, on a 8% increase in hours worked.

Compensation metrics (pay gap and total compensation)

Reference: page 153. The report heads this section "S1-16 - Remuneration metrics (pay gap and total remuneration)".

Gender pay gap, 31 December 2025 (page 153): AVIO S.p.A. 4%; AVIO French Branch N/A; Temis 12%; Regulus 14%; AVIO Guyane 28%; AVIO France 17%. A consolidated figure is reported for the first time this year: Group gender pay gap 7%, calculated "on gross wages, including variable components" (footnotes 127-128, page 153). The 2024 entity figures were AVIO S.p.A. 3%, Temis 12%, Regulus 14%, AVIO Guyane 8% and AVIO France 36%; "Group total pay gap comparative figure is not reported as detailed data for the 2024 Group recalculation is not available" (page 153).

Total annual remuneration index, 31 December 2025: AVIO S.p.A. 23.43; AVIO French Branch 1.62; Temis 2.98; Regulus 2.05; AVIO Guyane 3.20; AVIO France 2.37; Group 22.90. The 2024 entity figures were AVIO S.p.A. 28.83, AVIO French Branch 2.07, Temis 6.15, Regulus 2.78, AVIO Guyane 1.48 and AVIO France 1.75, with no Group comparative "as detailed data for 2024 Group calculation is not available" (page 153).

The index "is calculated as the ratio of the total remuneration, including variable elements, of the highest paid person within the Group to the median value of the remuneration including variable elements of employees excluding the highest paid person" (footnote 130, page 153).

Incidents, complaints and severe human rights impacts

Reference: page 154.

A complete nil return across both tables for 2024 and 2025.

Incidents of discrimination (page 154):

• Incidents of discrimination, including harassment: nil
• Complaints filed through channels for people in the undertaking's own workforce to raise concerns, including grievance mechanisms: nil
• Complaints submitted to the OECD National Contact Points for Multinational Enterprises: nil
• Total amount of fines, penalties and compensation for damages as a result of the incidents and complaints, with reconciliation to the amounts presented in the financial statements: Euro nil

Identified cases of serious human rights incidents (page 154):

• Number of serious human rights incidents related to the enterprise's workforce: nil
• Complaints filed through own-workforce channels: nil
• Complaints submitted to the OECD National Contact Points: nil
• Total amount of fines, penalties and compensation for damages: Euro nil

Policies related to value chain workers

Reference: page 155.

Five instruments cover all workers in the value chain (page 155): the Code of Ethics; the Supplier Code of Conduct; the Supplier Charter of Ethics (Charte Etique Fornisseur) used by Regulus; the Human Rights Protection Policy; and the Organisation, Management and Control Model under Legislative Decree No. 231/2001.

On international instruments: "The Group's policies, and in particular its Code of Ethics, specifically refer to the Conventions of the International Labour Organization (I.L.O.) and address the issue of child labour. Furthermore, the Group has a Supplier Code of Conduct that is public and available for consultation on the Group's website." The Group "incorporates into its business processes principles and rules of conduct in line with the Universal Declaration of Human Rights, ILO Conventions, OECD Guidelines, UN Guiding Principles and the EU Charter of Fundamental Rights" (page 155).

Reported outcome and its caveat: "To date, no cases of non-compliance with the terms of these policies or serious human rights violations against workers in AVIO's value chain have been reported to the Group, but AVIO is committed to progressively implementing increasingly systematic and comprehensive monitoring measures" (page 155). No policy on human trafficking specifically, and no statement on alignment with the UN Guiding Principles reporting framework, is disclosed.

Processes for engaging with value chain workers about impacts

Reference: pages 155-156.

Engagement is indirect and framed as an aspiration rather than a practice. "The company's current engagement with workers in the value chain is achieved, in relation to identified potential or actual impacts, through the plan to improve the process of monitoring ESG parameters of entities with which AVIO establishes business relationships" (page 155).

The gap is stated plainly: "To date, the Group does not have structured methods for engaging workers in the value chain, or particularly vulnerable groups within it, but in line with Avio's growing maturity toward this issue, the Group has set a goal of increasing engagement initiatives by formalizing structured ways to include the category more actively" (page 155).

Operational responsibility for ensuring such involvement sits with the Board of Directors (page 155), which is unusually high in the organisation for a process disclosure and is not accompanied by a description of how the Board discharges it.

No worker representatives, trade unions or credible proxies for value chain workers are identified as engagement counterparts, no frequency of engagement is given, and no assessment of the effectiveness of engagement is disclosed. The statement cross-refers to ESRS 2 SBM-2 for stakeholder involvement generally (page 156).

Processes to remediate negative impacts and channels for value chain workers

Reference: page 156.

"In the event of any reports of negative impacts by the Group on workers in the value chain, AVIO is committed to remedial action as appropriate in each specific case" (page 156).

The channel is the same Whistleblowing Procedure used for own workers: "In the Supplier Code of Conduct, AVIO invites suppliers to report any potential violations, express concerns or report incidents related to the possible violation of human and workers' rights through the internal reporting channel activated by Avio, the application methods of which are defined by the Whistleblowing Procedure. This tool is also available to workers in the value chain, and can be used to report possible violations with respect to human rights" (page 156). The platform is "accessible to all internal and external Group stakeholders, including suppliers, the value chain, end-users and members of communities affected by Avio's activities", though "there are no formalized procedures designed to verify the awareness of all categories of stakeholders" (page 165).

The gap is stated by Avio: "The Group has also set itself the goal of developing specific procedures capable of keeping track of these matters, which also define and enable the evaluation of any measures taken in order to remedy any negative impacts caused" (page 156). No count of reports received from value chain workers is disclosed.

Taking action on material impacts on value chain workers

Reference: page 156.

The principal action is contractual extension of Avio's ethical principles: "the Group's Italian companies require their suppliers and sub-contractors, both international and Italian, on insertion as suppliers, to sign the company's Code of Ethics. If suppliers have a Code of Ethics of their own, the equivalence of its principles with the AVIO Group is verified. Suppliers managed by the companies in French Guiana, meanwhile are required to sign the Group's Charter of Ethics" (page 156).

Screening is partial and Avio says so: "To date, due in part to the nature of the business and the peculiarities of supplier relationships, there is no established system for selecting suppliers based on ESG criteria, although these are monitored at the selection stage wherever possible, including through the administration of the survey linked to the MANF form (Master Data Form for supplier register inclusion), where environmental and social data are collected through a check-list that suppliers must complete. The MANF module includes also an indication of whether there are Occupational Safety and Health Management Systems (OHSAS 18001 or ISO 45001), or Social Responsibility Management Systems that comply with SA 8000 or ISO 26000 standards" (page 156).

Resources: the interventions "are included within the general CAPEX/OPEX item of the Group and are not significant" (page 156).

Targets related to value chain workers

Reference: page 157.

No targets are set. "Currently, the Avio Group has not identified specific targets related to workers in the value chain; however, AVIO has adopted a Human Rights Policy in order to promote compliance throughout its value chain" (page 157).

For supply chain improvement the statement cross-refers to the governance chapter: "Regarding the improvement of supply chain management in ESG, please refer to G1-2 Management of relationships with suppliers" (page 157). That section describes the CRIF Synesgy platform initiative, in which Avio has participated as Lead Partner since 2021 and which "seeks to invite suppliers in the registry to obtain the CRIBIS ESG certificate"; the Supplier Code of Conduct adopted in 2024 "to ensure compliance with its ESG KPIs along the entire supply chain", signature of which "is required of all suppliers"; and the "Jaggaer" supplier portal, operational since June 2025, which carries a sustainability questionnaire (page 168). None of these is expressed as a target with a value or a date.

Effectiveness tracking in the absence of targets is limited to the statement that Avio "is moving toward structuring comprehensive and timely processes that allow not only for the accurate monitoring of such situations ... but also for tracking the actions implemented and evaluating their effectiveness" (page 156).

Policies related to affected communities

Reference: pages 157-158.

The Code of Ethics is the governing instrument. It "expresses the Group's commitment to socially responsible behaviour, ensuring the protection of local cultures in the countries where it operates and conducting business with the highest safety standards, as well as respect for the human rights of the affected communities. In the event that violations occur, Avio is committed to taking appropriate remedial measures depending on the specific circumstances" (page 157).

The communities in scope are identified precisely (page 157): the Municipality of Colleferro, Lazio, "located near AVIO S.p.A.'s operational sites and serving as a key hub for the Group's activities"; the community of Perdasdefogu, Sardinia, near the launch site; and the community of Kourou, near the Group's site in French Guiana.

No policy commitment referencing the UN Guiding Principles, ILO Declaration or OECD Guidelines specifically in relation to affected communities is disclosed, and no policy addressing indigenous peoples is given; Avio states that "there is no need to implement special safeguards aimed at protecting marginalized groups specifically or indigenous communities" (page 158). The statement cross-refers to the MDR-P table for policy detail (page 158).

Processes for engaging with affected communities

Reference: page 158.

"Avio employs various engagement methods with affected communities depending on the specific context. The main channels through which affected communities can be involved in the management of impacts are institutional: with regard to, for example, the communities of Colleferro and Perdasdefogu, Avio maintains an ongoing dialogue with the respective local administrations, which actively represent the affected communities, enabling the Group to have clear visibility of what their specific needs may be, and to respond effectively and in a timely manner when necessary" (page 158).

A limitation is disclosed in the pollution chapter and bears directly on this disclosure: "For this CSRD reporting year, the identification of stakeholders for the purpose of stakeholder engagement took into account stakeholders' knowledge of ESG issues for the purpose of giving a timely assessment of the issues covered. Local communities were not directly involved in the stakeholder engagement process for this reporting year, but their perspective was taken into account during the company's internal assessments" (page 124). The same point is made in the E5 chapter: "The perspective of local communities ... was taken into account during the internal assessments of the double materiality process" (page 132).

Processes to remediate negative impacts and channels for affected communities

Reference: page 158.

"The primary method for affected communities - or any other entity internal or external to Avio - to raise concerns about the company's conduct and file complaints is the reporting channel available on the company website and regulated by the Whistleblowing Procedure, which is publicly accessible" (page 158). The statement cross-refers to G1-1 for detail.

An external channel through the ANAC website is available where the internal channel is not active, where a report has gone unanswered, where the whistleblower reasonably fears retaliation, or where "the Breach being reported may pose an imminent or obvious danger to the public interest" (page 165).

Beyond whistleblowing, the institutional route described under S3-2 - ongoing dialogue with the local administrations of Colleferro and Perdasdefogu - serves as the practical grievance path (page 158). Community-facing emergency arrangements sit under the External Emergency Plan for Colleferro, issued by prefectural decree in December 2024 (page 124).

No figure for grievances received from affected communities is disclosed, and no assessment of whether communities are aware of or trust these channels is given.

Taking action on material impacts on affected communities

Reference: pages 158-159.

"Both areas affected by the impacts that have emerged as relevant are central to the Group's operations and attended to on an ongoing basis, and therefore it is unnecessary to create a formalised action plan aimed at managing the impacts defined with regard to the issue at hand" (page 158).

On the negative impact - potential impacts on the safety of communities in French Guiana and Perdasdefogu related to launch activities - Avio "has implemented safety management systems defined in compliance with the Seveso III Directive and national transposition regulations (Legislative Decree No. 105/2015), in addition to a set of company procedures to ensure controlled use and management of substances classified as Comburents and Explosives". Training is provided "to ensure the site safety for relevant personnel at sites subject to the regulations". In French Guiana "Every building at the facility ... complies with local French legislation and [is] located at an appropriate distance from the city's urban center, [and is] carefully monitored in terms of their impacts on local communities through the safeguards provided by the relevant Management Systems". At Regulus "the Industrial Management and the Safety and Environmental Service implement and maintain an appropriate management system in line with the relevant international standard" (page 158).

Targets related to affected communities

Reference: page 160.

On the positive impact, two high-level targets (page 160):

• "Promote listening within the territory";
• "Prompt action with respect to the communities in which Avio operates".

"The goals were formulated by considering the perspective of the affected communities, seeking to best capture the feedback received with respect to what has been done to date and to contribute even more effectively to the well-being of the community" (page 160). Neither carries a measurable value, a base year or a target date.

On the potential negative impact, one target is stated in outcome terms: "the AVIO Group has set the goal of "zero events with potential risk of major accidents", managed through the actions described in section S3-4" (page 160). That is the only quantified target in the S3 chapter, and it is expressed as a nil threshold rather than a trajectory. The actions behind it are the Seveso III management systems, controlled handling of comburent and explosive substances, and site-safety training (page 158).

No reporting of performance against these three goals for 2025 is given in the S3 metrics section, and no process is described for how affected communities are involved in tracking them beyond the statement that community feedback informed their formulation.

Policies related to consumers and end-users

Reference: page 161.

Eight instruments are listed as managing the identified impacts and risks (page 161): the Code of Conduct; the Human Rights Protection Policy; the Inside Information Processing Policy; the Cyber Security Policy; the Data Breach Management Policy; Corporate regulations for the use of information systems; the Quality Policy; and the Quality, Occupational Health and Safety and Environmental Policy applied at Regulus.

"These policies were formulated with the views of the relevant stakeholders in mind. In the event of the violation of the principles defined by these policies resulting in negative impacts on Human Rights, AVIO will undertake specific remedial actions for the violated right. To date, there are no reports of any relevant incidents in this regard" (page 161).

Avio's end-users are institutional rather than retail: "The AVIO Group does not sell its products directly to end consumers", the affected categories being the European Space Agency, the Italian Space Agency, business partners, players in the European defence sector "and, following developments in 2025, certain stakeholders in the United States" (pages 160-161).

Processes for engaging with consumers and end-users

Reference: pages 161-162.

"The Group seeks to satisfy its customers by attempting to anticipate the needs of current and prospective customers to create value in the short, medium and long term. The perspective of this category is therefore crucial for AVIO, which it promotes through its corporate website, dedicated meetings and the distribution of brochures" (page 161).

The structured mechanism is customer satisfaction assessment under the quality management system: "as required by the quality management system, AVIO undergoes customer satisfaction assessment, once the metrics for evaluating its performance have been agreed with said customers. The results of these surveys are periodically analysed, and where any critical issues emerge during the commercial phases before the signing of supply contracts and implementation, these results allow improvement action plans to be developed" (page 161).

On vulnerable users: "Given the nature of Avio's business and the Group's customers, there is no indication of user categories with particular vulnerabilities to the identified impacts that may require the implementation of specific ways of engagement" (page 161).

End-users participated in the materiality process: the Double Materiality Assessment identified the S4 impacts "considering the views of certain end-users who participated in the impact assessment process" (page 161).

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

Reference: page 162.

"The potential negative impact identified in relation to the loss or leakage of sensitive data is managed in accordance with the Data Breach Management Policy, which provides for the reporting of incidents to the Privacy Guarantor in compliance with the GDPR (General Data Protection Regulation)" (page 162).

Two grievance routes are available (page 162):

• the general channel: "the principal method available to report wrongdoing or raise complaints against the Group is through the reporting channel available on the corporate website governed by the Group's Whistleblowing Procedure", which is explicitly stated to be open to customers and end-users;
• the contractual channel: "Regarding customer complaints specifically related to products supplied by the AVIO Group, reports can also be made directly by contacting the relevant departments identified in the contract. These departments are then responsible for managing the complaint."

No count of complaints or data breaches received or reported to the Privacy Guarantor is disclosed for 2025, and no assessment of whether customers and end-users are aware of or trust these channels is given. Avio states under S4-1 that "To date, there are no reports of any relevant incidents in this regard" (page 161).

Taking action on material impacts on consumers and end-users

Reference: pages 162-163.

On data protection and cyber security (page 162). "AVIO conducts activities to identify vulnerabilities in its IT systems each year. 2025 saw the conduct of a Cyber Security Remediation Plan, under which activities pertaining to awareness development, increased security measures, review of PSNC systems and training were carried out. Specifically, all AVIO S.p.A. employees are required to complete online courses as part of an ongoing cyber security training programme, which includes a final assessment." Also in 2025: a Business Continuity Plan including an ICT Recovery Plan; restructuring of the IT department and plans "to integrate changes brought by the approval of the NIS2 Directive"; additional funding and a dedicated employee for IT; and certification of the CyberEssentials IT environment, "covering external IT processes in terms of processes, procedures and technologies".

On product quality and customer safety (pages 162-163). No specific action plan is judged necessary because safeguards are "attentively monitored on an ongoing basis given the nature of the Group's business". Processes are mapped under ISO 9001:2015 and EN 9100:2018 for Avio S.p.A. and ISO 9001:2015 for Regulus; "These certifications were renewed for AVIO S.p.A. in March 2026 through audits by the certification body Rina with three-year validity (March 2029)."

Targets related to consumers and end-users

Reference: page 163.

No measurable targets are set. "Avio has prepared a set of objectives related to its own workforce, designed to guide the Group's actions. Given the nature of the impacts and risks identified and in view of the Group's focus on these risks as they are implicated by its business activities, the actions discussed are in fact mostly carried out on an ongoing basis as an integral part of ensuring the quality of Avio's services" (page 163). The sentence refers to "its own workforce" in a consumers and end-users section, which appears to be a drafting error carried over from S1-5.

What is disclosed instead is a forward commitment with a defined horizon: "the actions initiated in 2025, particularly regarding the strengthening of cyber security measures and the updating of existing procedures, will also extend into 2026 as part of a structured three-year plan. This plan seeks to align with the changes introduced by the NIS 2 Directive, which updates European legislation on network and information security" (page 163).

One dated commitment is reported: "Avio has officially joined the EU Space ISAC (Information Sharing and Analysis Center), the European Space Sector Security Network, with an operational debut on September 18, 2025. The entry aims to strengthen cyber resilience, share threat intelligence and protect infrastructure such as Vega C launchers from cyber attacks" (page 163).

Business conduct policies and corporate culture

Reference: pages 164-166. The report heads this section "G1-1 - Corporate culture and business conduct policies".

Sixteen instruments are listed (pages 164-165): the Code of Ethics; Charter of Ethics; the Whistleblowing Procedure; Supplier Code of Conduct; Supplier Charter of Ethics; the Organisation, Management and Control Model under Legislative Decree No. 231/2001; Anti-Corruption Code; Internal Dealing Policy; Related Party Transactions Procedure; ITAR and EAR Materials Management Procedure; Inside Information Processing Policy; Human Rights Protection Policy; Cyber Security Policy; Data Breach Management Policy; and the Major Accident Prevention Policy.

Corporate culture mechanisms. Employees of all Italian companies, including new hires, must sign the 231 Model and the Whistleblowing Procedure for acceptance (page 165). The 231 Model "is disseminated and communicated through continuous information and training of personnel, delivered both in e-learning mode and through in-person attendance at classroom courses" (page 166). Regulus "has communicated the Charter of Ethics to all staff, including new hires, since 2022, despite not offering ad hoc training courses on these topics" (page 166).

Management of relationships with suppliers

Reference: pages 166-168.

The supply chain is divided into three macro areas (page 166): Direct suppliers of parts or raw materials for a sub-assembly; System suppliers providing a complete sub-assembly "of which they often also have design authority"; and Indirect suppliers of products or services necessary for factory operation but not part of the finished product.

Selection criteria are "quality, innovation, cost and services" plus "good standing, reputation and professionalism". Given the sector, the absence of any past or present suspicion of involvement in terrorist activities or subversion of public order is of particular importance in supplier selection" and where economically feasible the Group applies a dual sourcing policy (pages 166-167).

ESG monitoring. Since 2021 Avio has participated "as Lead Partner in an initiative promoted by the company CRIF through Synesgy digital platform", inviting registry suppliers "to obtain the CRIBIS ESG certificate". "In 2024, Avio adopted a Supplier Code of Conduct to ensure compliance with its ESG KPIs along the entire supply chain. Signature of the Code is required of all suppliers. The 'Jaggaer' portal for suppliers has been operational since June 2025", carrying the signed document and a sustainability questionnaire (page 168). Environmental assessment is by supplier self-certification at registration.

Prevention and detection of corruption and bribery

Reference: pages 167-168.

"The Avio Group is committed to countering corruption and preventing the risks of illegal practices at any working level and in any geographic area, both through the dissemination and promotion of ethical values and principles and through the effective provision of rules of conduct and the implementation of control processes, in line with the requirements established by applicable laws and international best practice" (page 167). The framework comprises the Anti-Corruption Code of Conduct, the Code of Ethics, the Whistleblowing Procedure and the 231 Model.

Reports not archived are assessed jointly with the Supervisory Board; results go semi-annually to the Control and Risks Committee (page 168).

Functions at risk and training. "The functions most exposed to corruption risk are those that deal with customers and suppliers, as well as with the public administration" (page 166). "The percentage of functions-at-risk covered by training programmes is 100%. Training activities in this area involve top management from various departments across the company" (page 168). Avio cooperates "with sector associations such as Transparency International and AITRA (the Italian Transparency and Anti-Corruption Association)" (page 166), and the Human Resources Department "is responsible for defining the annual employee training plan on the contents of the Anti-Corruption Code" (page 166).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; the ESRS content index lists MDR-T against the business conduct metrics and targets section (page 88).

Avio discloses no measurable business conduct target. The G1 metrics and targets section (4.1.3, pages 168-169) contains only G1-4 and G1-6. No base year, target value or target date for anti-corruption, supplier ESG coverage or payment practices is given anywhere in the chapter.

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of targets:

• Training coverage is measured and reported at 100%: "The percentage of functions-at-risk covered by training programmes is 100%. Training activities in this area involve top management from various departments across the company" (page 168).
• Semi-annual reporting to governance: results of reports received and not archived, "including the verifications carried out and any sanction measures taken, are summarised in a report sent by the Committee, on a semi-annual basis, to the Company's Control and Risks Committee", with a parallel semi-annual report from the Supervisory Board to the administrative body (page 168).
• Outcome metrics are reported at nil under G1-4 for both 2024 and 2025 (page 169).

Incidents of corruption or bribery

Reference: pages 168-169. The report heads this section "G1-4 - Confirmed incidents of corruption or bribery".

A nil return for both years (page 169):

No confirmed incidents, no dismissals or disciplinary actions for corruption or bribery, and no contract terminations with business partners on those grounds are reported. The nil figures are consistent with the S1-17 tables, which report nil incidents of discrimination, nil complaints and nil fines for both years (page 154).

The sanctions framework behind these figures is set out in detail (pages 168-169). Violations of the Anti-Corruption Code "result in Group companies instigating action both internally, through the application of disciplinary sanctions, and externally, through maximum co-operation with the relevant public authorities". For parties outside Group personnel, conduct in conflict with the Code "will be examined in order to assess the adoption of measures, such as unilateral termination of the contract" (page 169).

Payment practices

Reference: page 169.

"The contractual commitments are not standard and can vary from supplier to supplier, and on the significant sample taken range on average between 30 and 90 days" (page 169).

"The average time for payment of invoices to be settled including contractual commitments, for the significant sample, is approximately 90 days, in line with the previous year. The analysis was performed considering all invoices paid during the year by AVIO S.p.A. and its most significant subsidiaries" (page 169).

"No legal proceedings are currently outstanding for late payments" (page 169).

On SMEs specifically, "During the payment process, the Group pays particular attention to suppliers falling within the SME category" (page 169), and under G1-2 Avio states that "Payment policies specifically for SMEs are currently being formalized, although operationally a special focus on payments to SMEs is already applied" (page 168).

Not disclosed: the percentage of payments aligned to standard terms, the number of legal proceedings currently outstanding for late payments expressed as a figure rather than a statement, and the standard payment terms broken down by main supplier category. The disclosure rests on a "significant sample" whose size and composition are not given.