Bally's Intralot

The role of the administrative, management and supervisory bodies

Reference: pages 295-298, 441-442.

Board (page 295). Eleven members, elected 30 May 2024 for a six-year term and reconstituted on 7 November 2025 when Robeson Mandela Reeves became CEO. After 16 March 2026: two executive and nine non-executive members, four independent (36%), with "approximately 27% female representation". The report states: "Bally's Intralot does not maintain designated elected representative from its own workforce on the Board of Directors (BoD)."

Three-level sustainability governance, established early 2025 (pages 296-297).

• Supervisory: the Board supervises the sustainability strategy; the Audit Committee assesses the integrity of the Sustainability Statement.
• Management: the Group COO, who also serves as Sustainability Officer, holds overarching responsibility and chairs the Sustainability Committee. A Risk Management Committee and a Responsible Gaming Committee also sit here.
• Administrative: a Coordinating Team of the Corporate Affairs & Sustainability, Finance, Regulatory Compliance, HR, Risk Management, Supply Chain, Technology and Subsidiaries units.

A limitation is disclosed: the structure "has yet to assign targets for the identified material impacts, risks, and opportunities at each level of governance" (page 296). Board expertise is developed "through a combination of direct experience and access to external experts or training" (page 298).

Information provided to and sustainability matters addressed by the undertaking's bodies

Reference: pages 299-304.

The bodies and committees "are regularly informed about material impacts, risks, and opportunities, as well as the implementation of due diligence and the results and effectiveness of policies, actions, metrics, and targets adopted to address them" (page 299). Roles are set out across Supervisory, Management and Administrative levels, including the Board, Audit Committee, CEO, COO/Sustainability Officer, CTO, CFO, CLO, CCO, the Sustainability Committee, the Risk Management Committee and the Responsible Gaming Committee (pages 300-303).

Matters addressed in the period (pages 303-304): energy consumption and emissions and climate mitigation strategies; fair employment, diversity and inclusion, talent attraction and retention; human rights, training and skills, grievance mechanisms; employee health, safety and wellbeing; responsible gaming, including product design with responsible gaming features; innovation and digitization; data privacy and security; local community engagement; corporate governance, business ethics and anti-corruption; and responsible procurement.

Internal Audit "monitors and evaluates the process of drawing up and submitting the Sustainability Statement in terms of design and effectiveness" (page 303). Frequency is not quantified and no schedule of meetings at which sustainability matters were tabled is given.

Integration of sustainability-related performance in incentive schemes

Reference: pages 304-305 and 384.

A nil return, stated twice. For the Board: "For Bally's Intralot no incentive schemes linked to sustainability matters have been implemented for members of the Board of Directors during the reporting period, nor are any such schemes currently under consideration" (page 305, tagged [GOV-3 29, AR 7] and [GOV-3 29 a, b, c, e]).

For climate: "Information regarding incentive schemes and remuneration policies linked to climate-related matters is currently unavailable. The Group does not currently evaluate performance against greenhouse gas (GHG) emission reduction targets, as such targets have not yet been established. Consequently, no portion of remuneration recognized during the reporting period is linked to climate-related criteria" (page 384). The Group "considers introducing climate-related performance indicators into the remuneration and incentive schemes of its administrative, management, and supervisory bodies... with disclosures to follow in future reporting cycle".

The Remuneration Policy for Board members is described as supporting "the Group's business strategy, long-term objectives, and sustainability" (page 304), but no sustainability metric, weighting or percentage of variable pay is attached to it.

Statement on due diligence

Reference: pages 305-306.

The statement is the required mapping of the five core elements of due diligence to sections of the Sustainability Statement (page 305):

The supporting narrative (pages 305-306) describes periodic assessment of existing and emerging corruption risks; supplier assessment "based on criteria such as quality of deliverables, infrastructure deployment, testing, system performance, and incidents recorded by its Global Service Desk"; due diligence on agents, consultants, intermediaries, joint venture partners, contractors and distributors before engagement; KYC procedures; anti-corruption clauses in supplier agreements; and "a standardized internal auditing procedure performed annually to assess its business units for relevant risks". The Group also "underwent an extensive independent assessment of its responsible gaming practices and products, resulting in the renewal of its Certificate of Alignment with the World Lottery Association (WLA) Responsible Gaming Framework for Associate members until 2027" (page 306).

Risk management and internal controls over sustainability reporting

Reference: pages 306-309.

A Risk Management System sits inside the Internal Control System, supported by an Enterprise Risk Management Framework defining governance, roles and methodologies. The process runs through risk identification, assessment, response, and monitoring and reporting (page 306). The Board approves the ERM Framework and sets risk appetite; a Risk Management Committee of Chief-level executives evaluates it; a Risk Management Officer coordinates and reports to the Board; divisions act as first line of defence; Internal Audit and the Audit Committee provide assurance (pages 307-308).

For sustainability reporting, "risks are classified based on the Group's ERM Framework risk classification, where sustainability-related risks fall under the first-level Classification 'Strategy and Planning' and second-level classification 'Corporate Responsibility & Sustainability (CR&S)'" (page 308).

Two reporting risks are named with controls (pages 308-309): accuracy of data due to the nature of the subsidiaries, mitigated by standardized reporting templates, internal audits and training of subsidiary finance teams; and consolidation of the data, mitigated by an ESG software solution implemented to consolidate sustainability data and improve traceability, plus reconciliation procedures, regular review and segregation of duties between data entry, review and approval.

Strategy, business model and value chain

Reference: pages 309-321.

The 2025 combination of INTRALOT and Bally's International Interactive created a group "operating in more than 40 regulated jurisdictions worldwide" (page 309). Six gaming verticals are served: lottery, iGaming, sports betting, VLT/AWP machines, racing, and IT products and services. Products include Lotos X omni (36 lottery operations), Orion sports betting (9) and iGEM VLT monitoring (5) (pages 312-313). Three engagement models are reported: technology and support services contracts, management contracts and licensed operations (page 315).

Revenue (pages 320-321). Total EUR 518.04 million, approximately 53.05% under NACE 62.01 computer programming and 46.95% under NACE 92.00 gambling and betting. Bally's Intralot S.A. alone: EUR 14.5 million and 426 employees.

Workforce by region (page 316): Europe 1,624; Americas 820; Asia 233; Oceania 67; Africa 33.

Value chain (pages 316-319). Upstream: IT hardware, software licences, AI tools, cloud servers, encryption, third-party gaming content and KYC/AML components. Own operations now include direct licensed gaming, player account administration, AML and responsible gaming monitoring, and fraud prevention. Material IROs "are predominantly located within Bally's Intralot's own operations, particularly concerning the workforce and the resources utilised in operating gaming platforms and IT infrastructures" (page 319).

Interests and views of stakeholders

Reference: pages 321-325.

Stakeholder groups (page 321): Shareholders, Employees, Customers, Suppliers, Business Partners, Investors and Financial Community, National and International Regulatory Authorities, Industry Associations, Community and NGOs, Media, Retailers, Players, and Industry Peers. Each is given channels, focus topics and frequency (pages 322-324): employees through the iSpace intranet, the whistleblowing form, HR focus groups and the "Your Voice" platform, frequently; suppliers on human rights, health and safety, data privacy, energy and emissions, waste and materials; players through gaming platforms and the call centre on game updates and player protection.

A material limitation is disclosed. The FY2025 process "focused on an internal validation of the previously identified IROs, without conducting a new external stakeholder survey", while taking account of the wider post-acquisition scope (page 324). "Internal peer review and management validation exercises were carried out to confirm that the shortlisted material topics were aligned with internal strategic priorities... Lessons and insights from last year's external survey were referenced where relevant to maintain continuity in stakeholder perspectives" (page 325). The bodies "are kept informed, as appropriate, of internal and previously gathered external stakeholder views" (page 325).

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

Reference: pages 325-337.

31 material IROs are tabulated with type, actual or potential status, value chain location and time horizon: 15 impacts (pages 326-329), 8 risks (pages 330-331), 8 opportunities (pages 332-333).

• E1 (12): four actual negative impacts (Scope 3 from upstream and downstream activities, Scope 1 and 2 from transport and facilities, IT infrastructure energy use, upstream hardware manufacture); five risks (rising energy prices, heat stress, sudden temperature spikes, the cost of moving to greener cloud providers, electricity price volatility and grid constraints); three opportunities.
• S1 (4): two positive impacts, one negative impact (absence of an international employee union across subsidiaries), one opportunity.
• S3 (1): economic growth of local communities, positive.
• S4 (7): three positive impacts, one potential negative impact (contribution to players' gambling addiction), one risk, two opportunities.
• G1 (7): three positive impacts, two risks (residual non-compliance across subsidiaries; failed post-merger cultural alignment), two opportunities.

Changes versus FY2024 (pages 333-334): the validation "did not identify any new ESRS material topics"; E5 and the G1 political engagement sub-topic ceased to be material.

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

Reference: pages 337-351.

FY2025 was a validation of the FY2024 DMA: "For FY2025, the Group used the existing baseline list of impacts, risks, and opportunities established during the previous reporting period (FY2024) Double Materiality Assessment as the starting point" (page 337).

Six steps (pages 338-346):

1. Peer benchmarking against lottery, gambling, casino, software and online gaming peers, "based on publicly available sustainability disclosures".
2. Updating the IRO inventory, merging overlaps and removing IROs no longer relevant, aligned to the ERM framework.
3. Scoring by the Corporate Affairs Department with internal experts. Impact materiality uses Severity, Scale, Scope, Irreversibility and Likelihood on a five-level scale. Financial materiality uses Magnitude and Likelihood, anchored to four ERM pillars and to EBITDA bands (below 1%, 1-2%, 2-5%, 5-10%, above 10%) (pages 343-344).
4. External stakeholder engagement was not repeated: "the Group deemed it was not necessary to repeat the external stakeholder analysis" (page 346).
5. Threshold: "set at a value equal to or higher than the median of the assessed scores and was applied consistently for both impact materiality and financial materiality" (page 346).
6. Validation by the central team and subsidiaries, approved by top management including the President and COO.

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

Reference: pages 456-467.

A full ESRS content index is printed under "Appendices [IRO-2] - List of disclosure requirements" (pages 456-460), listing each covered disclosure requirement against the section carrying it. Its scoping note: "The disclosure requirements for topical standards E2, E3, E4, E5 and S2 are excluded, as they did not emerge as material topics of the Group, based on the current year's DMA for the reporting year" (page 456).

Coverage: ESRS 2 BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1 GOV-3, E1-1, SBM-3, IRO-1, E1-2 to E1-6 and E1-9, the last shown against the marker "Phased-in"; S1 SBM-2, SBM-3 and S1-1 to S1-17; S3 SBM-2, SBM-3 and S3-1 to S3-5; S4 SBM-2, SBM-3 and S4-1 to S4-5; G1 GOV-1, IRO-1, G1-1, G1-2, G1-3, G1-4, G1-6. E1-7, E1-8 and G1-5 are absent.

A second table (pages 461-467) lists the ESRS 2 Appendix B datapoints derived from other EU legislation against SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, marking each as located in a named section or "Not material".

Transition plan for climate change mitigation

Reference: pages 384-385.

There is no transition plan. "Even though Bally's Intralot has not yet adopted a formal transition plan for climate change mitigation, the Group considers it essential to be in line with climate-related targets and is reviewing its operational and strategic framework to align climate resilience and mitigation strategies... its future efforts will now include the process of developing a coherent transition plan, alongside its existing initiatives to reduce energy consumption and GHG emissions. The specific date for the adoption of the transition plan and the process of its approval will be finalized until the next reporting period" (page 384, tagged [E1-1 17]).

Nor is there Paris alignment. "Bally's Intralot has adopted various climate-related initiatives... however, the Group has not formally aligned with the Paris Agreement; There is no specific adoption date fixed yet, but one will be decided in the next reporting cycles" (page 385, tagged [E1-1 15]).

Appendix B marks E1-1 paragraph 14 (transition plan to reach climate neutrality by 2050) and paragraph 16(g) (undertakings excluded from Paris-aligned Benchmarks) as "Not material" (page 462). What exists instead is a set of unquantified mitigation actions grouped by decarbonization lever under E1-3 (pages 389-390).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (the E1 IRO-1 section, pages 347-349) and E1.SBM-3 (pages 385-386), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (page 385). "In total, Bally's Intralot has identified five (5) material risks, out of which three (3) are considered to be transition risks and two (2) are considered to be physical risks", each labelled in a table.

Methodology (pages 347-348). Three horizons: short-term (2025), medium-term (2026-2030), long-term (2031-2050). Material physical hazards were heat stress, changing temperatures and heatwave; "The assessment did not include a quantitative exposure analysis or geospatial modelling of assets."

Scenarios (pages 347-349). Physical risk under the high-emissions IPCC SSP5-8.5; transition risk under a scenario "aligned with a 1.5 degrees C pathway with no or limited overshoot, specifically the IPCC SSP1-2.6 scenario", to 2050, informed by IPCC projections "complemented by widely recognized transition narratives referenced by... NGFS and IEA".

Gaps the company names (page 349). No temperature projection per scenario is given; constraints include "the absence of asset-level exposure modelling"; and climate assumptions "have not been incorporated into Bally's Intralot's financial statements".

Resilience in relation to climate change

Back-filled from E1.SBM-3 (pages 386-387). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Performed for the first time, qualitatively (page 386). "This resilience analysis was performed for the first time during the reporting year and encompassed the Group's operations and infrastructure, as well as the... value chain... No material physical or transition risks were omitted from the scope." SSP1-2.6 and SSP5-8.5 were applied.

Limits stated (page 386). "the resilience assessment was carried out on a qualitative basis. No quantified emissions reduction targets under ESRS E1-4 nor quantified anticipated financial effects under ESRS E1-9 were incorporated."

Results and uncertainty (page 387). Climate change "could progressively influence Bally's Intralot's operational landscape, particularly through physical impacts on infrastructure"; the results "do not constitute a quantified stress test". "Uncertainty remains regarding the timing and strictness of climate policy implementation, the pace of decarbonization... and the severity of hazards."

Capacity to adjust (page 387). The Group "retains the capacity to adjust its strategy and business model over time through initiatives such as improving the resilience of key assets, maintaining access to financing... and capitalizing on opportunities linked to more sustainable operations".

Policies related to climate change mitigation and adaptation

Reference: pages 387-388.

The Group has no climate change policy. "In accordance with ESRS 1 - General Requirements (paragraph 114) and ESRS 2 (paragraph 62), Bally's Intralot Group has not yet developed a formal Climate Change Policy. This is due to fact that the Group is currently operating in a transition phase, during which policies, procedures and strategic priorities - including climate change-related commitments - are being progressively aligned, following the recent acquisition of Bally's International Interactive" (page 388, tagged [ESRS 2 62]). A policy "aligned with the requirements of ESRS E1 and the objectives of the Paris Agreement... is expected to be completed in the next reporting cycles".

Two partial instruments stand in its place:

• A Sustainability Policy developed in 2025 by Bally's Intralot S.A., one core principle of which covers Climate and Environment, "reflecting the Group's commitment to environmental protection, compliance with applicable legislation and the continuous reduction of environmental impacts" (page 387). The Policies Overview names the Group COO as accountable (page 352).
• An Environment and Climate Change Policy at Bally's International Interactive, which "outlines... [its] approach to reducing its carbon footprint through the deployment of alternative energy solutions and the efficient use of resources" (pages 387-388).

Actions and resources in relation to climate change policies

Reference: pages 388-391.

Actions (pages 388-390). An Environmental Management System applying ISO 14001 principles, a Building Management System and energy meters. Named 2025 actions: rooftop photovoltaics at the Greek headquarters through third-party arrangements, where "The external provider financed, constructed and operates the installations... energy is not considered self-generated but procured as renewable electricity"; motion sensors in all 52 restroom areas and subterranean areas; LED replacement; air-conditioning optimisation; replacement of the gasoline fleet with hybrids; and virtualized and cloud environments replacing physical servers.

Five decarbonization levers are named (pages 389-390) - energy efficiency, fuel switching, renewable energy, virtualization and cloud, and product specifications - none quantified. Outcomes are stated as expectations, not results.

Progress cannot be measured this year (page 391). "the change in the scope of consolidation... limits the comparability of historical data... A formal baseline year for monitoring emissions performance will be established in a future reporting cycle... Consequently, historical measurements cannot be used at this stage to assess progress."

Resources (page 391) are described qualitatively only, with no monetary amounts: "many implemented initiatives did not require significant capital investment".

Targets related to climate change mitigation and adaptation

Reference: pages 391-392.

A nil return. "Bally's Intralot actively tracks the impact of its policies and activities, however it has not yet set measurable, outcome-oriented targets for Climate Change Mitigation and Energy. This is mainly due to the recent acquisition of Bally's International Interactive in October 2025 and the ongoing alignment and integration of the acquired entity into the Group's structures, systems and reporting processes. As a result, the Group has not yet determined the most appropriate baseline year upon which to establish measurable climate and energy targets" (pages 391-392). Appendix B marks E1-4 paragraph 34, GHG emission reduction targets, as "Not material" (page 462).

The disclosure is tagged [ESRS 2 81], the minimum disclosure requirement for tracking effectiveness without a target, and describes the monitoring in place (page 392): GHG quantification under ISO 14064:2018 for Scope 1 and 2; the ISO 14001 EMS, which "monitors and records the Group's environmental footprint... providing continuous data"; a Building Management System that "allows for proactive automatic shutdowns... helping identify high-consumption assets"; and periodic audits of the Energy Management System under ISO 50001:2018.

Directional commitments without figures or dates are given: replacing gasoline vehicles with hybrids, and photovoltaics "for a net-zero electricity balance".

Energy consumption and mix

Reference: pages 392-395.

Self-generated non-fuel renewable energy is nil, consistent with rooftop photovoltaic output being procured rather than self-generated (page 388).

Caveats printed with the table. 2024 figures marked * were recalculated after "the subsequent receipt of updated data from Intralot Inc." (page 394). For Intralot Inc. no primary energy data were available, so prior-year consumption scaled by year-end headcount was used (page 393). Bally's International Interactive data cover offices in Ceuta, Barcelona, Estonia, Gibraltar, Malta, London Stoke and Manchester and are "scaled to the final three months of 2025", so the comparison is not like for like.

External verification is limited to Bally's Intralot S.A. under ISO 50001:2018: "No other subsidiary currently underwent external validation" (page 392).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 395-400.

Scope 3 by category (page 396): purchased goods and services 26,983.56; capital goods 1,885.97; fuel and energy-related 669.32; upstream transport and distribution 2,765.67; waste 0.84; business travel 2,385.33; employee commuting 661.81; upstream leased assets 1.35; use of sold products 4,373.61. Nine of fifteen categories are covered; "The Group has decided not to include the rest Scope 3 categories in its analysis due to the lack of relevant data" (page 398). Scope 3 is 84.5% of the market-based total, and the year-on-year jump reflects the acquisition and first-time inclusion of five categories, not a performance movement.

Methodologies (pages 397-400). DEFRA 2024 and Greek Climate Law factors for Scope 1; DAPEEP 2025 residual mix for market-based Scope 2; EEIO model 2020 for categories 1, 2 and 4; a 2025 commuting survey with 666 responses from 2,683 employees.

Policies related to own workforce

Reference: pages 403-406.

No standalone Human Rights Policy. "While Bally's Intralot does not have a standalone Human Rights Policy, principles and commitments regarding respect on human rights are mainly embedded in the Code of Conduct" (page 403), which applies to all employees, directors and officers of the Group and its subsidiaries and states firm opposition to child labour. The Group has been a UN Global Compact signatory since 2009 (page 404).

Health and safety. A management framework sits under the Code of Conduct and Quality Policy; Bally's Intralot S.A. is ISO 45001 certified (pages 404-405).

Diversity. "the Group has not yet established a stand-alone diversity-related policy" (page 405); commitments sit in the Code of Conduct and the Elimination of Violence and Harassment Policy, with zero tolerance for discrimination on gender, race, colour, nationality, sexual orientation, age, religion, disability, medical and marital status.

Elimination of Violence and Harassment Policy, designed to comply with Greek Law 4808 and ILO Convention No. 190, "is currently under review".

Whistleblowing Corporate Policy offers anonymity and anti-retaliation protection, but "applies to Bally's Intralot S.A." only (page 406); Intralot Inc. staff follow a separate policy (page 404). The Group "is in the process of aligning and extending its workforce policies to cover all employees" (page 403).

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

Reference: pages 406-407.

Channels (page 406). The Whistleblowing Corporate Policy and the Elimination of Violence and Harassment Policy; HR focus groups "aiming to enforce open and honest communication"; the corporate intranet portal iSpace, with a designated section for employee suggestions, comments and ideas; an open door policy; e-mail announcements; frequent one-to-one meetings between managers and employees; awareness initiatives with Q&A sessions; and team-level communication through managers and department heads.

Engagement "occurs both directly with employees and through workers' representatives", and the Group "respects and safeguards the right of employees to participate in working unions" (pages 406-407). Outside Greece, engagement "takes place through regular meetings, with the frequency determined at the local level... and managed by the respective HR teams" (page 407).

Accountability. "The Group's Human Resources Director oversees the engagement strategy and ensures that the results of employee feedback are incorporated into the Group's decision-making processes."

Coverage gap, stated by the company (page 407). "While these processes are fully operational within the headquarters, they have not yet been expanded across all Group locations" (tagged [S1-2 29]). No engagement frequency or effectiveness assessment is quantified.

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

Reference: pages 407-408.

Grievance mechanisms exist "to ensure that employees across the headquarters, have accessible channels to address concerns related to harassment, discrimination, or other matters affecting their well-being" (page 407). Reports may be submitted "either anonymously or by name through a letter to designated email address, a formal email, and the whistleblowing form which is publicly available to company's website", and the channel is open to shareholders, employees, clients, suppliers and partners (pages 407-408).

The Whistleblowing Corporate Policy "ensures that individuals can raise issues on an anonymous basis if desired and guarantees protection from retaliation... [and] outlines clear procedures for receiving, investigating, and addressing reported concerns" (page 408). Employees are informed of the channels "through internal communication and onboarding training", and anti-retaliation protection extends to workers' representatives.

Coverage gap (page 408). The Group "is actively working on expanding these channels to other regions and entities within the Group" (tagged [S1-3 34]). Appendix B locates the SFDR datapoint on grievance and complaints handling (paragraph 32(c)) in this section (page 465). Outcomes appear under S1-17: zero incidents and zero complaints in 2025, against six discrimination incidents in 2024.

Taking action on material impacts on own workforce

Reference: pages 408-412.

Remediation (page 409). "Following the DMA, no material negative impacts on the Group's own workforce requiring remediation have been identified." On the absence of a Group-wide employee union, the Group "continues to assess opportunities to further strengthen social dialogue mechanisms across subsidiaries" and states that "Employees are free to form or join trade unions of their choosing".

Prevention (page 409). Suppliers are required "to adhere to ethical labor standards"; in sales, "measures are in place to prevent excessive pressure that could adversely affect employee well-being or work-life balance".

Named actions (pages 409-412). Compensation: flexible working, paid time off and parental leave, mainly at Bally's Intralot S.A. Training: induction covering responsible gaming, personalised development plans, and courses on Artificial Intelligence and its application in business. Performance management: an appraisal system running "for the past nine years" and the second year of the competencies model. Health and safety: "assessed as non-material at Group level", with a committee "controlled by the local labor union" at headquarters and ISO 45001 certification at Bally's Intralot S.A. Diversity: bias-free job adverts, diverse interview panels, and the WHEN Career Fair for Everyone; female representation is tracked in quarterly performance KPIs.

Targets related to own workforce

Reference: page 412.

A nil return, with effectiveness tracking described in place of targets. "Bally's Intralot has not yet established time-bound and outcome-oriented targets, to measure its progress in mitigating its negative impacts, advancing its positive impacts, or managing material risks and opportunities related to its own workforce" (page 412).

The disclosure is tagged [S1-5 44] and [MDR-T 81 b], the limb that applies where no target is set: "In the meantime, the Group monitors the effectiveness of its policies and actions through regular engagement with employees, grievance mechanisms. Although quantitative indicators are still under development, the Group aims to track improvements in employee well-being, health and safety compliance, and workplace satisfaction, using metrics such as incident reduction rates, employee retention, and performance data as baseline indicators."

This matches the Group-wide position: "even though it has not yet set measurable targets for managing its material sustainability impacts, risks, and opportunities... Bally's Intralot is currently evaluating the necessity and feasibility of establishing specific targets" (page 454), and the governance admission that the structure "has yet to assign targets... at each level of governance" (page 296). No workforce involvement in target setting is described.

Characteristics of the undertaking's employees

Reference: pages 412-414.

Headcount at 31 December 2025: 2,777 (1,669 in 2024), of whom 1,877 male and 900 female (page 412). The expansion reflects the inclusion of Bally's International Interactive.

Turnover: 527 leavers, a rate of 18.98%, against 239 and 14.32% in 2024 (page 413). Turnover is defined as employees who left "voluntarily or due to dismissal, retirement or death" during the period, divided by year-end headcount.

Countries of significant employment (page 414): United Kingdom 803, United States 644, Greece 540. Significant employment is defined as at least 50 employees representing at least 10% of the Group workforce; inside the EEA this covers the United Kingdom and Greece, outside it the United States. (The report classifies the United Kingdom as inside the EEA, which is inaccurate post-Brexit.)

Headcount methodology is used throughout, measured at 31 December, and the report cross-references page 254 of the financial statements for the total number of employees (page 413). No breakdown by region in the S1-6 table itself; a continental split appears under SBM-1 (page 316): Europe 1,624, Americas 820, Asia 233, Oceania 67, Africa 33.

Characteristics of non-employee workers

Reference: pages 414-415.

The definition given is narrow and specific: "Non-employees in own workforce of Bally's Intralot are considered the contractors and third-party workers supplied by external service providers" (page 414). For 2025 the figure "is reported in headcount, as an average across the reporting period" (page 415), a different basis from the 31 December headcount used for employees under S1-6, which the report discloses but does not reconcile.

No breakdown of non-employee workers by type (self-employed versus supplied by undertakings primarily engaged in employment activities) is given, and no gender or country split is provided. The figure is not restated for the change in consolidation scope, so the 111 against 79 movement mixes organic change with the acquisition of Bally's International Interactive.

Related coverage is reported elsewhere: under S1-14 the Group states "Due to the nature of the Group's operations, non-employees in own workforce are not exposed to high levels of risk on Health and Safety matters" (page 420), and the S1.SBM-3 scoping confirms that "The workforce comprises directly employed staff, contractors, and third-party workers engaged through external service providers" (page 401), so non-employees are inside the S1 boundary for impact purposes.

Collective bargaining coverage and social dialogue

Reference: pages 415-416.

The fall is explained, not glossed: "The decrease in the percentage is due to the integration of coverage data of Bally's International Interactive" (page 415).

Coverage by country of significant employment (page 415). The banded table places the United Kingdom in the 0-19% band and Greece in the 80-100% band for EEA employees, and the United States in the 0-19% band for non-EEA. Workplace representation within the EEA is reported for Greece only.

Two gaps are disclosed. "The Group does not have any agreement in place for employee representation through a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council" (page 415). And social dialogue coverage "could not be provided for the operations in the United Kingdom, due to the recent acquisition of Bally's International Interactive and ongoing integration of reporting processes" (page 416).

This metric sits behind the Group's one material negative workforce impact: "the absence of an international employee union or representative association across all global subsidiaries may result in under-representation of employees and limited ability to collectively negotiate wages, benefits, and working conditions".

Diversity metrics

Reference: pages 416-417.

Top management (page 416). Defined as "one and two levels below the supervisory bodies".

The female share of top management fell slightly, from 26.87% to 25.36%, while the absolute number of top management roles more than trebled with the acquisition.

Age distribution (page 417).

Distribution is calculated by headcount at 31 December.

Board-level gender diversity is disclosed separately under GOV-1: eleven members with "approximately 27% female representation" and four independent members representing 36% (page 295). The Group states under S1-4 that "Acknowledging that the workforce is predominantly male, the Group actively seeks to enhance female representation", monitored through quarterly performance KPIs on female representation by geographical area, age group and job position (page 412), though no target percentage is attached.

Adequate wages

Reference: page 417.

A nil-exception return. "All employees of Bally's Intralot receive fair and competitive wages, which reflect the Group's strong commitment to equitable compensation practices. The wages provided to employees are consistently above the minimum thresholds established by Greek legislation, ensuring compliance with legal standards. Furthermore, the Group reports that no employees earn below the applicable wage benchmarks in any of the countries in which it operates both inside and outside the European Economic Area (EEA)" (page 417, tagged [S1-10 69, AR 72, 73, 74]).

That answers the disclosure requirement, which asks whether all employees are paid an adequate wage against applicable benchmarks and, if not, in which countries. The Group states there is no such country.

Two limits for a reader. The only benchmark named is Greek minimum wage legislation; the wider claim about "applicable wage benchmarks" in other countries is asserted without naming a benchmark per country. And no percentage of employees paid at or above the benchmark is given, so the statement rests on assertion rather than a disclosed calculation. Related content: the Compensation and Benefits policy gives "all employees within the headquarters and most subsidiaries, including part-time and temporary employees, a defined salary level and benefits" (page 409), while S1-16 reports a 17.22% gender pay gap.

Social protection

Reference: page 417.

"All employees who are subject to the collective labor agreement, are covered by social protection in accordance with jurisdictional local regulations, in cases of sickness, injuries, unemployment, parental leave and retirement. There are no identified categories of employees who are excluded from these protections. In addition, Bally's Intralot offers additional programs and benefits aimed at further supporting and enhancing the well-being of its employees" (page 417).

The disclosure covers all five events the standard asks about: sickness, unemployment from the point of employment, employment injury and acquired disability, parental leave, and retirement.

A tension a reader should note. The coverage statement is framed as applying to employees "subject to the collective labor agreement", yet collective bargaining coverage is reported as only 24.74% of employees (page 415). The following sentence then asserts that no categories are excluded, which reads as a Group-wide claim. The report does not reconcile the two, and no percentage of employees covered by social protection is quantified or broken down by country.

Benefits beyond statutory protection appear under S1-4: "flexible work arrangements, paid time off, and parental leave" applying mainly to Bally's Intralot S.A., with local practice elsewhere potentially adding "private medical/life insurance, company sponsored automobiles and fuel allowance" (page 409).

Persons with disabilities

Reference: page 418.

"As of the reporting period, 0.34% of the Group's employees are persons with disabilities, while in 2024 the percentage corresponded to 0.18%. The Group respects the privacy and confidentiality of its employees and ensures that the collection and handling of this data are in line with local data protection laws" (page 418).

Scope limitation, disclosed by the company. "For 2025 reporting year, this metric does not include data for Bally's International Interactive, due to the recent acquisition and ongoing integration of reporting processes. The Group aims to progressively integrate this information into its sustainability reporting scope in future reporting cycles." The percentage therefore covers only the legacy Intralot perimeter and is not comparable with the 2,777 Group headcount reported under S1-6.

No breakdown by gender is given, and the report does not state whether the figure reflects self-declaration or statutory registration, beyond the reference to local data protection law.

Related content sits under S1-1 and S1-4: the Code of Conduct prohibits discrimination on grounds of physical or mental disability, "The Group actively promotes the inclusion of people with disabilities in the labor market through various initiatives" (page 405), and the Group participates in the WHEN Career Fair for Everyone and Disability Awareness programmes (page 412).

Training and skills development metrics

Reference: pages 418-419.

Performance and career development reviews (page 418): male 83.22% (2024: 77.95%), female 82.56% (2024: 87.55%), all employees 83.00% (2024: 80.77%).

Training hours (page 418): male 7.23 (2024: 9.17 restated), female 7.37 (2024: 8.95), average per employee 7.27 (2024: 9.10).

Average training hours fell by roughly 20% year on year, and the 2024 male figure was restated "due to previous miscalculations". BP-2 confirms S1-13 as one of three sections where 2024 data were recalculated (page 293).

A disclosed data limitation: "For Bally's International Interactive, a portion of training hours recorded during the reporting period could not be attributed to employees' gender due to system limitations. These hours were therefore excluded from the calculation" (page 418), so the averages understate delivered training across the enlarged Group.

Scope is defined (page 419): onboarding and induction, online courses, adherence to policies and the Code of Conduct, compliance courses on the corporate e-learning platform, and AI and Digital Transformation upskilling; excluded are "ad-hoc, informal training, one-off workshops, or training activities not directly related to job functions or core business operations or on the job training".

Health and safety metrics

Reference: pages 419-421.

Accidents fell from 18 to 14 and the rate from 5.59 to 3.56, while recorded cases of work-related ill health rose from 29 to 380 and days lost from 39 to 451. The report does not explain the ill-health movement; the 2024 days-lost figure carries the note that "data regarding days lost for INTRALOT Inc. were not recorded" (page 420), so the years are not comparable.

Coverage caveat. The 100% figure excludes Bally's International Interactive: its employees "are not yet included in this calculation due to the recent acquisition and the ongoing alignment of governance, policies, and management systems" (pages 419-420). Non-employees are outside the metric because "non-employees in own workforce are not exposed to high levels of risk on Health and Safety matters" (page 420). Appendix B locates the fatalities and days-lost datapoints here (page 465).

Work-life balance metrics

Reference: pages 421-422. First year of disclosure.

Why 2024 is blank, in the company's words: "As part of the phased-in approach to preparing the Sustainability Statement, in 2024 the Group has opted to omit sustainability data required by ESRS S1-15, for all its subsidiaries, for the first year of reporting" (page 421). FY2025 is therefore the first year reported and no comparative exists.

Definitions (pages 421-422). Family-related leave covers maternity, paternity, parental and carers' leave "where applicable due to local legislations". Entitlement is calculated from HR policies and national labour legislation, and the report explains why it falls short of full coverage: "As eligibility criteria may vary across jurisdictions, the percentage does not necessarily reach 100% of total employees per gender group."

The gap between female take-up of 17.79% and male take-up of 9.95% is disclosed but not commented on, and the roughly quarter of the workforce reported as not entitled to family-related leave is attributed to jurisdictional variation without naming the countries.

Compensation metrics (pay gap and total compensation)

Reference: page 422.

The gap widened, from 14.33% to 17.22%. Pay gap is defined as "the difference in average pay levels between female and male employees, expressed as a percentage of the average pay level of male employees", calculated "using a weighted average methodology of employee average gross hourly pay data". A scope limitation is stated: "Subsidiaries unable to provide accurate data were excluded from the calculations", and the excluded entities are not named.

The Group's explanation: "While the reported gender pay gap is partly due to a higher proportion of men being attracted to roles within the gaming and technology sectors, Bally's Intralot is committed to promoting gender equality across all levels of the organization."

The remuneration ratio is not reported. "The Group was unable to provide accurate calculations for the annual total remuneration ratio of the highest-paid individual to the median annual total remuneration for all employees, as the necessary data was not available", and is "actively working on implementing a centralized system to track and standardize remuneration data". Appendix B marks the SFDR "Excessive CEO pay ratio" datapoint as "Not material" (page 465).

Incidents, complaints and severe human rights impacts

Reference: page 423.

Scope limitation on the two lines that changed. Both the discrimination incidents and complaints rows carry the footnote: "For this metric, data for Bally's International Interactive was not provided." The move from six reported discrimination incidents in 2024 to zero in 2025 therefore cannot be read as an improvement across a like-for-like population.

Narrative confirmation: "No complaints were filed through grievance mechanisms or other channels for raising concerns related to discrimination or harassment... and no financial penalties were incurred." On severe impacts: "the Group has recorded no cases of severe human rights incidents, including cases of forced labor, human trafficking, or child labor... [and] no incidents of non-respect of the UN Guiding Principles on Business and Human Rights, the ILO Declaration... or the OECD Guidelines."

Policies related to affected communities

Reference: pages 425-427.

No dedicated policy exists. "While specific policies addressing affected communities have not yet been formally established, the Group already undertakes community initiatives, including support for underprivileged children and employee volunteer programs" (page 426, tagged [S3-1 14]). Community commitments currently sit inside the Sustainability Policy, covering "promoting social welfare and strengthening local communities, with particular emphasis on cultural preservation and improving quality of life" (page 425).

Human rights (page 426). "while Bally's Intralot has not yet adopted a standalone human rights policy, the Group remains committed to respecting and promoting human rights... as outlined in its Code of Conduct", and "intends to... develop a formal human rights policy in the near term". Appendix B locates the S3-1 paragraphs 16 and 17 datapoints here (page 466).

Indigenous peoples (page 426). "Due to the nature of its activities, Bally's Intralot does not impact Indigenous peoples. It operates within the gaming and lottery industry, which does not interfere with Indigenous lands, rights, or cultural heritage."

Remedy (pages 426-427). The Group adheres to the UN Guiding Principles, the ILO Declaration and the OECD Guidelines: "In 2025, there were no recorded cases of non-compliance related to the human rights of affected communities."

Processes for engaging with affected communities about impacts

Reference: pages 427-428.

The Group "maintain[s] ongoing communication with communities impacted by its operations aiming to promote transparency and build trust. Through direct and open dialogue with affected communities representatives, Bally's Intralot seeks to understand local economic needs" (page 427).

Channels (page 427). Public reports, "memberships in collective associations (such as Chambers of Commerce and SEV), and participation in economic forums". Engagement occurs "at various stages of decision-making, from identifying sustainability impacts to developing and implementing business strategies".

Accountability (pages 427-428). "The Group Chief Operating Officer (COO), who also serves as a Chief Sustainability Officer is responsible for overseeing engagement with affected communities."

Effectiveness (page 428). "assessed through the analysis of survey participation rates, the quality and relevance of feedback received, and the extent to which stakeholder input confirms or challenges the identified material topics."

Weigh this against IRO-1. The 2025 DMA validation was internal only: "the Group deemed it was not necessary to repeat the external stakeholder analysis" (page 346), so the survey-based effectiveness measure refers to the prior year. Engagement with vulnerable communities is handled by cross-reference to S3-1.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: pages 428-429.

Channels (page 428). "Bally's Intralot provides dedicated internal reporting channels, including direct contact with responsible Group representatives, as well as an online reporting form available on the Group's website. These channels allow affected communities to voice concerns securely and confidentially. The Group ensures that these mechanisms are well-publicized and easily accessible to all relevant stakeholders, including vulnerable groups that may be disproportionately affected."

Handling (page 428). "Each case is evaluated based on its severity and potential impact, with a clear framework in place for implementing corrective measures... This review process includes direct feedback from affected stakeholders, who are actively involved in assessing the adequacy of the remediation provided."

Value chain reach (pages 428-429). The Group "works with its business partners to promote the availability of such grievance mechanisms throughout its supply chain and broader business ecosystem".

Tracking and trust (page 429). Detailed records are kept of "reported issues, the actions taken, and the outcomes achieved", assessed through evaluations, engagement sessions and internal audits; "the Group actively seeks feedback to assess trust in its reporting and remediation processes."

Taking action on material impacts on affected communities

Reference: pages 429-432.

Named actions (pages 429-430). Youth employability initiatives, "such as upskilling and training programs, scholarships, graduate programs, and career days"; community programmes under the pillars of Education and Sports; support for underprivileged children "through initiatives in partnership with NGOs and foundations"; employee volunteering including blood donations; and local entrepreneurship networks between universities and businesses.

A candid limitation (page 430). "Currently, Bally's Intralot does not have a formal system in place to track and assess the effectiveness of its actions or initiatives in delivering outcomes for affected communities. Beneficiaries often express their appreciation... through formal letters of gratitude." The Group says it is exploring how to develop such mechanisms.

Resources (pages 430-431). Management sits within existing functions. "The resources required for managing these impacts are limited... Consequently, they are not separately recorded or tracked." A plan aligning impacts "with specific actions and corresponding budget allocations" is promised for 2026.

Negative impacts (pages 431-432). The Group "has not identified any negative material impacts or risks related to affected communities in 2025", and there were "no reported human rights incidents". No community investment figure is disclosed.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 432.

A nil return. "Bally's Intralot has not yet established specific targets for managing its material impacts, risks, and opportunities. Consequently, the Group has not developed a structured monitoring system for these key performance indicators (KPIs). However, recognizing the importance of effective oversight, Bally's Intralot is in the process of designing and implementing a comprehensive framework. This system, which will be introduced in the coming years, aims to enhance transparency, track progress, and ensure continuous improvement in managing material sustainability factors" (page 432).

The disclosure is tagged [ESRS 2 81]. Here the Group states that no structured monitoring system exists either, which is a weaker answer than the equivalent S1-5 and S4-5 entries, where effectiveness tracking through grievance mechanisms and engagement is at least described.

The gap runs through the statement: the governance structure "has yet to assign targets... at each level of governance" (page 296), and no measurable targets are set for any material topic (page 454).

The single S3 material IRO is a positive impact, economic growth of local communities through jobs and taxes (page 327), so the absent target concerns advancing a positive impact rather than mitigating harm.

Policies related to consumers and end-users

Reference: pages 434-435.

A Responsible Gaming policy was developed in 2025. "In 2025, Bally's Intralot S.A. developed a Responsible Gaming policy (RG policy)... The policy applies to all employees, suppliers, partners, contractors and internal consultants of Bally's Intralot S.A. and its subsidiaries and is fully aligned with international best practices and standards developed in collaboration with... Lottery and Gaming Associations and regulatory authorities."

Two policies, not yet merged. "Bally's International Interactive Group maintains a Responsible Gaming policy governing its i-gaming activities... Its commitments will be progressively aligned with the Group's broader responsible gaming framework" (page 435); the Group "is undertaking a policy alignment process to harmonize Responsible Gaming standards across all operations" (page 434).

Content (page 435). A Stakeholder Engagement principle covering "regulators, partners and treatment organizations", and principles on Behavioral Monitoring and Ethical AI Use: "behavioral analytics that assist operators in identifying early signs of risky gambling behavior."

No standalone human rights policy. "While the Group does not maintain a standalone Human Rights Policy, the RG Policies incorporate commitments relevant to consumers and end-users, including respect for player safety [and] the provision of transparent and accurate information."

Processes for engaging with consumers and end-users about impacts

Reference: pages 436-437.

Two distinct populations. "Bally's Intralot's customers include licensed lottery and gaming operators as well as users of online gaming and betting platforms. The company tailors its engagement approach... to the characteristics and needs of each customer rather than applying a single standardized process."

B2B operators (page 436). "dedicated representatives from the company's workforce are assigned to each client as primary contact persons throughout the project", through email, meetings and "dedicated working groups and support teams."

Accountability (page 436). "The Group Chief Commercial Officer (CCO) holds the most senior role with operational responsibility for ensuring engagement with licensed lottery and gaming operators."

Effectiveness (pages 436-437). Customer insights are shared with departments to improve products; "This feedback-driven model is a key assessment tool of the effectiveness of customer engagement".

Players are the weaker half, and the Group says so (page 437). "Within Bally's International Interactive, engagement with players occurs directly through its digital platforms. As the Group continues the integration... player engagement practices... will be further assessed and progressively reflected in future Group disclosures." No process is described for engaging end-users of the B2B and B2G platforms.

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

Reference: pages 437-438.

Ownership (page 437). "The Commercial Devision including Marketing Services and Customer Operations, Sales and Business Development departments along with Corporate Affairs department, play a key role in this process by collecting feedback from... customers, end-users and consumers."

Grievance channel (page 437). "a grievance and reporting mechanism that allows stakeholders, including customers and end-users, to raise reports or complaints related to misconduct, non-compliance, or operational concerns. This mechanism can be used either anonymously or by name and is accessible via email, postal mail, or an online form."

A named operator-facing mechanism (page 437). The ICMA Change Request process, "a formal mechanism for submitting, reviewing, and managing system modifications... to allow licensed operators to communicate technical needs and operational concerns".

Where remedy actually sits for players (page 438). "The Group's approach to addressing potential adverse impacts on players is primarily preventive... Where potential harm is identified through behavioral monitoring tools, intervention measures are implemented by licensed operators." No count of complaints from consumers or end-users is reported, and no assessment of player awareness of or trust in the channels is given.

Taking action on material impacts on consumers and end-users

Reference: pages 438-440.

Responsible gaming and player protection (page 438). "The Group embeds player protection functionalities within its platforms, including self-exclusion options, budget-setting tools and behavioral monitoring capabilities that support early identification of potentially risky gaming patterns", supported by "targeted in-platform messaging and awareness initiatives". Resources go to "responsible gaming training programs, continuous monitoring of gaming activity, and the enhancement of player protection features". The portfolio also offers "age verification, tools for self-exclusion, cool-offs etc." (page 433).

Accessible gaming (page 439). "inclusive customer facing product solutions such as Vending Machines and Self-Service Terminals with adaptive features", with resources for accessibility enhancements, interface design and ongoing testing.

System reliability and security (page 439). "secure authentication mechanisms, encryption protocols and advanced cybersecurity infrastructure", plus a 24/7 Service Desk aligned with ISO 20000.

Effectiveness tracking is not yet in place (page 440). "the Group is currently exploring the development of a comprehensive customer survey". No monetary resource allocation is given, and no responsible gaming outcome metric such as self-exclusion counts or intervention volumes is disclosed.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 440.

A nil return. "Bally's Intralot has not yet established time-bound and outcome-oriented targets for managing its material impacts, risks, and opportunities on consumers and end-users. However, the Group is committed to establishing clear KPIs and monitoring mechanisms to assess the effectiveness of its policies and activities. This process is set to be implemented in the coming years, with concrete steps planned for future reporting cycles" (page 440, tagged [MDR-T 81 b]).

This matters more here than for the other social topics. S4 carries the Group's largest material negative impact, the potential contribution to players' gambling addiction, arising "because of the nature of the industry it operates in, as it is inherently linked to products that involve repetitive play" (page 329), with the risk of "significant reputational and regulatory risks... potential financial losses including fines and penalties" (page 331). No target, threshold or KPI is attached to it.

What stands in place of a target is the preventive apparatus under S4-4, the WLA Responsible Gaming Framework certification renewed to 2027 (page 306), and the RG Policy developed in 2025. Effectiveness tracking is earlier still: the Group is "exploring the development of a comprehensive customer survey."

Business conduct policies and corporate culture

Reference: pages 443-448.

Framework (pages 443-444). The Code of Conduct, supported by the Whistleblowing, Anti-Corruption and Anti-Money Laundering Policies, plus the "voluntarily adopted... Hellenic Corporate Governance Code 2021."

Whistleblowing (pages 444-445). Reports may be made "either anonymously or by name, through a dedicated e-mail or via an online form". "New hires undergo classroom training on the Whistleblower Policy during their induction, while all staff have access to e-learning modules covering anti-corruption policies." Coverage is incomplete: consistent application "across all Bally's Intralot subsidiaries is expected to be achieved by the end of 2026."

Anti-Corruption Policy (pages 445-446). Third parties must certify compliance on request, the Group retains audit rights over their books, and where a regulator warns that a relationship jeopardises licensing, "the agreement will be terminated unless a remedy is implemented within thirty calendar days". On the UN Convention against Corruption the report is precise about what it does not claim: "the Policy does not explicitly state that it has been formally designed to ensure full alignment with... the Convention".

Functions at risk (page 447). "BoD members, senior management, and employees operating in high-risk departments (e.g. traders) and in high-risk countries are especially susceptible".

Management of relationships with suppliers

Reference: pages 448-450.

Selection (pages 448-449). Standardized procedures apply "across its entire product chain", with "a detailed procurement policy that outlines step-by-step procedures, supplier requirements, and necessary documentation". Audits verify vendor selection "based solely on financial and technical evaluation". Local suppliers are included in bidding alongside international ones.

A gap the Group states plainly (page 449). "Bally's Intralot's current Procurement Policy does not yet incorporate specific ESG criteria for supplier evaluation at Group level... there is no dedicated focus on ESG performance. This gap could impede progress towards environmental sustainability and social justice." Extension across the enlarged Group is "expected to be achieved by the end of 2026".

Monitoring (pages 449-450). Financial and technical quality control per order, with subcontractor evaluation on "financial stability, technical capabilities, quality of deliverables... and incident records from the Global Service Desk". Screening is embedded in KYC: "The identification of suppliers with actual or potential negative environmental, labour practices, human rights, or social impacts is incorporated into the supplier Know Your Customer (KYC) process."

Environmental requirements (page 448). RoHS Directive 2002/95/EC for all terminals; European suppliers must comply with WEEE Directive 2002/96/EC.

Prevention and detection of corruption and bribery

Reference: pages 451-454.

Reporting routes (page 451). Concerns can go "to the Human Resources Department and the Internal Audit Unit", anonymously or named, or via "an online whistleblowing tool" to the "Chief Legal Counsel... appointed as Compliance Officer".

Independence, stated candidly (page 451). "Where the Compliance Officer is the subject of the report... the matter may be reported to another designated officer... investigations are conducted within the existing management structure and are not structurally separate from the chain of management, although escalation mechanisms are provided."

Certification (page 452). The parent company "is notably one of the few gaming companies certified with ISO 37001 for its Anti-Bribery Management System".

Training, and its limits (page 452). "While no standalone training programs are currently in place, the Anti-Corruption Policy is communicated during employee induction". Elsewhere, "All new hires must complete an interactive Anti-Bribery and Anti-Corruption eCourse" (page 453). But "the percentage of functions-at-risk covered by training programs has not been calculated" (page 454).

Risk assessment (page 452). "no functions have been identified as being at heightened risk of corruption", which sits uneasily beside the G1-1 statement naming BoD members, senior management and traders as "especially susceptible".

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under the Minimum Disclosure Requirements rather than as a numbered DR. G1-3 became a standalone targets DR only in the 2025/2026 ESRS.

Reference: page 454.

Bally's Intralot discloses no business conduct targets, and no targets at all. Under "Metrics, targets, and actions": "Bally's Intralot is committed to tracking the effectiveness of its policies and actions related to sustainability, even though it has not yet set measurable targets for managing its material sustainability impacts, risks, and opportunities. The Group employs various processes to monitor progress, including qualitative and quantitative indicators" (tagged [ESRS 2 81]).

Consistent with MDR-T's other limb, effectiveness is tracked without a target:

• Zero confirmed incidents of corruption or bribery and zero fines in 2025 (page 454).
• Payment indicators: 23.83 days average payment time, 85.41% aligned with standard terms (page 455).
• "a standardized internal auditing procedure performed annually to assess its business units for relevant risks" (page 305).
• "The Group tracks policy adoption and feedback from internal communication channels" (page 443).

Two dated commitments act as milestones rather than targets: harmonised whistleblowing training and extension of the Anti-Corruption and Procurement Policies across all subsidiaries by the end of 2026.

Incidents of corruption or bribery

Reference: pages 454-455.

A nil return, stated in full. "During the reporting period, Bally's Intralot was not involved in any confirmed incidents of corruption or bribery, and no convictions, fines or penalties were imposed by courts or competent authorities for violations of applicable anti-corruption and anti-bribery legislation. Accordingly, no remediation actions were required in relation to breaches of relevant procedures or standards" (pages 454-455, tagged [G1-4 24 a, b, AR 8] and [G1-4 25]).

"The Group maintains a zero-tolerance approach to corruption and bribery and has established policies, controls and reporting mechanisms designed to prevent, detect and address such incidents" (page 455). Appendix B locates G1-4 paragraph 24(a), fines for violation of anti-corruption laws, here, and marks 24(b) as "Not material" (page 467).

Two limitations a reader should carry. The nil return is not disaggregated for the newly acquired Bally's International Interactive entities, whose governance and policies the report describes as still being aligned to end-2026 (pages 292, 441, 445). And the detection apparatus behind the zero is itself qualified: investigations are "not structurally separate from the chain of management" (page 451), the percentage of functions-at-risk covered by training "has not been calculated" (page 454), and no functions were identified as at heightened corruption risk (page 452).

Payment practices

Reference: page 455, with the Payment Policy at page 450.

Both figures carry footnotes. On the rise in payment days: "During the current reporting period, additional subsidiaries of Bally's Intralot Group provided data for the calculation of the indicator, resulting in a more comprehensive and representative consolidated figure at Group level", so the movement reflects a wider reporting population rather than slower payment. On method: "The average is calculated using internally generated data from each subsidiary, rather than a standardized procedure."

Standard terms (page 450). "standard payment terms generally provide for 60 days or more for Greek vendors and 30 days or more for international vendors, unless otherwise approved", with domestic payment runs on the 5th and 20th and international runs on the 10th and 25th.

On SMEs (page 450). "there is no formal prioritization of specific supplier categories at Group level", though the Group may informally expedite payments to SMEs on request, and it has "not adopted a dedicated policy specifically addressing the prevention of late payments".