Basic-Fit

Governance roles

Reference: page 28. Composition datapoints (paragraph 21 c) are incorporated by reference to Management statements and the Supervisory Board Report (pages 117, 119, 120, 121, 124); G1.GOV-1 paragraphs 5a/5b to Corporate Governance (pages 102, 103).

Basic-Fit's "administrative, management and supervisory bodies" are the Leadership Team (four members: CEO, CFO, CCO, COO) and the Supervisory Board (six members). The former are executive, the latter non-executive; 83% of Supervisory Board members are independent; the ratio of female to male members is 33% for the Leadership Team and 50% for the Supervisory Board (page 28).

There is no sustainability committee: "There is no dedicated body (such as a committee or similar) set specifically for sustainability matters, yet responsibility to perform strategy development, management, and supervision addressing sustainability is covered in the Management Board, Leadership Team and Supervisory Board rules" (page 28). Oversight runs through the annual risk assessment, in which "sustainability governance is assessed as a separate risk (within the category 'compliance')" (page 29). Day-to-day ownership sits with the Director of Treasury, IR and Sustainability and a sustainability team (page 29). Boards' gender diversity (21 d) and independence (21 e) datapoints are located in this section (page 76).

Information provided to the boards

Reference: pages 29-30.

Both boards "actively participated in discussions regarding our double materiality assessment (DMA) of 2024" and "were also involved in discussions confirming the validity of the DMA outcomes for our 2025 reporting too" (page 29). The 2025 agenda was data quality: "we focused in 2025 on enhancing the quality of reported data, mainly through reviewing data sources and calculation methodologies, and setting a sustainability reporting system", plus progress on climate transition and human rights policies (page 29).

Basic-Fit states a governance gap plainly: the Supervisory Board "is informed annually of progress achieved, as part of the annual reporting cycle, whilst the Leadership Team is updated informally throughout the year. We have not set up a formal updating schedule dedicated to the boards' involvement in managing our sustainability strategy, which we plan to explore in the upcoming years" (page 29). The CFO engages with the Works Council periodically in the absence of worker representation on the boards (page 29). On expertise, the boards "discussed their sustainability-related expertise" and "whenever technical knowledge is required (e.g., on GHG emissions or climate change), they seek advice from external consultants" (page 30).

Sustainability in incentive schemes

Reference: page 30. Paragraph 29 and E1.GOV-3 paragraph 13 are incorporated by reference to the Remuneration report, Short-term incentive (pages 137, 138).

"As defined in the Management Board's remuneration package, both the CEO and CFO have targets (as part of their short-term incentives) linked to strategic priorities. For example, the CEO's objectives include expanding our reach and to make fitness more accessible, supporting healthier communities. The CFO's sustainability-related target for 2025 is focused on the implementation of a sustainability reporting system" (page 30).

There is no climate link to pay: "Their performance is not assessed against specific GHG emission reduction targets, nor are climate-related considerations factored into remuneration this year" (page 30). The short-term incentive achievement for 2025 was approved by the Supervisory Board on 5 February 2026 and paid out at 63.75% of annual base salary for both the CEO and CFO (page 219). No percentage of variable remuneration linked to sustainability targets is quantified in the sustainability statement itself.

Statement on due diligence

Reference: page 31. Paragraph 30 is also listed in the datapoints table as located in this section (page 76).

Basic-Fit provides the required mapping table of the five core elements of due diligence against the sections of the statement (page 31):

• Embedding due diligence in governance, strategy and business model - Governance of sustainability matters; Double materiality assessment; Sustainability at Basic-Fit
• Engaging with affected stakeholders - Double materiality assessment
• Identifying and assessing negative impacts - Double materiality assessment
• Taking action to address negative impacts - Climate change and energy use; Smart resource use; Our people; Our members; Business conduct
• Tracking the effectiveness of these efforts - Climate change and energy use; Our people; Our members

The tracking row is the thinnest in substance: the company states elsewhere that "Despite our progress, we have not been able to formally establish approaches for effectiveness tracking in 2025, but will continue our efforts in upcoming years" (page 30).

Risk management and internal controls over sustainability reporting

Reference: page 30. Paragraphs 36(b) and 36(c) are incorporated by reference to Risk management and control systems, Sustainability governance (page 99).

"We started to apply our internal control framework (ICF) to sustainability reporting in 2024... We began with the implementation of control processes for the data related to electricity and gas consumption. We prioritised these topics taking into account our goal to reduce our emissions and the importance of monitoring energy use" (page 30). Coverage is therefore partial by design, with an "annual design reassessment, which helps determine additional sustainability topics to be covered by the ICF" (page 30).

The Sustainability Reporting Manager is process owner for all ESRS-related processes; a quarterly reporting cycle is run by the second line of defence; findings go to control and process owners, then the Management Board (CFO), then the Audit and Risk Committee (page 30). The Management Board declares "that these systems provide limited assurance that the sustainability reporting in the Sustainability Statement section of this report does not contain material inaccuracies" (page 116).

Strategy, business model and value chain

Reference: pages 8, 31-33. The datapoints table records no involvement in fossil fuel, chemical production, controversial weapons or tobacco activities (paragraph 40(d) i-iv, all "Not material", page 76).

Basic-Fit operates 2,151 clubs (1,660 Basic-Fit owned, 56 Clever Fit owned and 435 Clever Fit franchise clubs) with 5.8 million memberships, revenue of EUR 1,420 million and more than 9,000 employees across 12 countries (pages 4, 8). The business model rests on "a winning customer proposition and brand, scalability in existing and new regions, significant cost benefits in building and running clubs, and clear potential for continued growth" (page 32).

Strategy is framed by the "Go for a fitter world programme 2030" launched in 2021, with three pillars: Fitter people, Fitter planet and Fitter communities (pages 31-32). The company flags that the programme is dated: "We have maintained the programme through 2025 and plan to revamp it in the near future, especially the goals connected to each of the pillars. The latter are therefore currently described in broad terms" (page 31).

The value chain diagram (page 33) maps each actor to a topical standard: suppliers (E1, E5, S2), franchisees (G1, S2), own operations (S1), and consumers, users and communities (S3, S4).

Interests and views of stakeholders

Reference: page 32.

"In line with our stakeholder engagement policy, we are committed to creating opportunities to engage with our various stakeholders, enabling us to understand their interests and views, and to take those into account in the pursuit of our sustainable growth strategy" (page 32). Six stakeholder categories are tabulated with the relationship and the interaction channels (page 32):

• Employees - more than 9,000 in seven countries; surveys, intranet, regular meetings, onboarding
• Members - more than 5.8 million; app, surveys, focus groups, social media, online chats
• Suppliers - fitness equipment, digital solutions, maintenance and cleaning, builders; meetings and supplier code of conduct
• Financial community - one-on-one and group meetings, press releases, conferences
• Public sector - national fitness federations, government bodies from EU to local councils
• Local communities - collaboration on sports, education and job programmes

Franchisees are new: "Following the launch of our franchise model at the end of 2025, we welcomed new franchisees as key stakeholders... We will further enhance our engagement approach, formally including them in our policy in the future" (page 32).

Material impacts, risks and opportunities

Reference: pages 36-38.

"There are eight material topics: climate change and energy use; circular economy; working conditions of the workforce; equal treatment, opportunities and privacy for the workforce; value chain workers; communities; members; and business conduct" (page 37). The two tables on pages 36-37 describe each IRO in prose with a colour-coded type (positive or negative, actual or potential impact, risk, opportunity) and a value chain location, and name the disclosures covered: E1-1 to E1-9; E5-1 to E5-4; S1-1 to S1-17; S2-1 to S2-4; S3-4; S4-1 to S4-5; G1-1 to G1-3 and G1-5 to G1-6, plus five entity-specific metrics.

Time horizons are uniform: "we expect all IROs to remain material in the short, medium, and long- term, even if specific elements change over time (e.g., some types of physical risks related to climate change may become less material in time, yet climate change is expected to remain as a material risk)" (page 37).

On financial effects: "Current financial effects of material risks and opportunities are deemed to be limited", illustrated by energy cost savings being "offset by the increase in operating expenses directly related to the higher number of clubs, members and employees" (page 38).

Processes to identify and assess material IROs

Reference: pages 34-35, 38.

The DMA was performed in 2024 and revalidated rather than redone for 2025: "We evaluated the validity of this DMA in the middle of 2025... We concluded that the results of 2024 are still valid for this year's reporting", applying EFRAG's IG1 materiality guidance, with any significant business change "duly assessed in a DMA to be performed in 2026" (page 34). The Clever Fit acquisition is explicitly outside the assessment: "the materiality of impacts, risks or opportunities connected to this transaction has not been assessed yet" (page 34).

Method (pages 34-35): landscape assessment, value chain mapping and stakeholder identification; a long-list workshop; stakeholder interviews and survey; separate impact and financial materiality workshops. Impacts were scored on severity (scale, scope, irremediability) and likelihood, each 1 to 5; risks and opportunities on size of financial effect (under EUR 1 million to over EUR 25 million) and likelihood 1 to 5, with worked threshold examples given for both.

Two scope limits are stated: no entity-specific topics were found ("we did not identify any indication of such topics", page 34), and "we did not perform any specific site or country assessments regarding the environmental topics we assessed... we identified material IROs and topics at an overall group level" (page 38).

Disclosure requirements covered

Reference: pages 74-77.

Basic-Fit prints a genuine ESRS Disclosure Requirements list (page 74) mapping each covered DR to a section name, plus a second table of datapoints derived from other EU legislation (pages 76-77) and a short list of entity-specific metrics (page 75).

Covered per the index (page 74): 2-BP-1, 2-BP-2, 2-GOV-1 to 2-GOV-5, 2-SBM-1 to 2-SBM-3, 2-IRO-1, 2-IRO-2; E1-GOV-3, E1-1, E1-SBM-3, E1-IRO-1, E1-2 to E1-8; E5-IRO-1, E5-1 to E5-4; S1-SBM-2, S1-SBM-3, S1-1 to S1-6, S1-8, S1-9, S1-10, S1-13, S1-14, S1-16, S1-17; S2-SBM-2, S2-SBM-3, S2-1 to S2-4; S3-4; S4-SBM-2, S4-SBM-3, S4-1 to S4-5; G1-GOV-1, G1-IRO-1, G1-1, G1-2, G1-3, G1-5, G1-6.

The second table uses four labels - a section name, "Not material", "Not relevant" and, once, "Phased-in, not reported" (S1-14 days lost, paragraph 88(e), page 77). That distinction is load-bearing: where Basic-Fit omits under a phase-in it says so, and where it judges a datapoint immaterial it says that instead. Entity-specific metrics are memberships, clubs, visits per member per week, financial contribution to communities and weight of fitness equipment per club (page 75).

Transition plan for climate change mitigation

Reference: pages 39-40. The datapoints table locates paragraph 14 in this section and marks paragraph 16(g), exclusion from Paris-aligned Benchmarks, "Not relevant" (page 76).

Basic-Fit has no transition plan yet. "We are working toward the development of a climate transition plan, including GHG emission targets, that will outline how we aim to align our business model with the objectives of the Paris Agreement, particularly the goal of limiting global warming to 1.5 degrees C. We expect to adopt this transition plan by the end of 2026" (page 39).

Four foundational steps taken in 2025 (page 39): recalculation of Scope 3 emissions to improve accuracy and completeness and to include Clever Fit; identification of emission trajectories for Scopes 1, 2 and 3 "providing a baseline for future reduction targets"; analysis of natural decarbonisation trends and near-term emissions evolution against growth assumptions; and an internal workshop "to explore potential decarbonisation actions and define the steps needed to gather the necessary data and insights for a robust transition plan".

The blocker is named: "further granularity in our understanding of emissions sources, particularly within Scope 3, is essential for the development of a concrete and actionable climate transition plan" (page 40). No target, lever quantification, funding figure, locked-in emissions analysis or management approval of a plan is disclosed.

Identification of climate-related risks and scenario analysis

Back-filled from the climate-related risks and opportunities assessment disclosed under E1-IRO-1 in the FY2025 report (pages 40-41). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2024, we undertook a climate-related scenario analysis, the core of which consisted of identifying the material physical and transition risks to and opportunities for the business... as per Task Force on Climate-Related Financial Disclosures (TCFD) recommendations" (page 40).

Scenarios. Physical risk used "a low emissions pathway (SSP1-2.6) and a high emissions pathway (SSP5-8.5), with SSP5-8.5 representing a 'reasonable' worst-case climate scenario by 2050".

Scope. A representative sample of clubs. Physical risk excludes the value chain: "Basic-Fit could not extend 2024's physical risks analysis to its value chain. We are planning to include the value chain by the fourth year of our ESRS reporting" (page 40). The qualitative transition analysis did extend to it.

Results (page 41): water stress material at baseline; heat waves by 2030; heat stress and storm by 2050; volatile energy prices and value chain decarbonisation efforts by 2030; one opportunity in proactive energy management. No temperature projection per scenario is given.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 chapter, where this content is disclosed in the FY2025 report (pages 38-39, 88). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS-defined resilience analysis is reported. What the report offers is a statement of effort and a conclusion: "Since 2024, we have made efforts to understand the resilience of our business model in the face of climate change impacts on our business, including risks related to extreme weather events... Beyond this, we believe our strategy and business model, including actions planned as per our risk management and control systems, will enable us to address material impacts and risks and take advantage of material opportunities" (page 38).

The climate chapter treats resilience as work in progress: "Our approach includes assessing the resilience of our business and identifying adaptation needs" (page 39). The risk section adds that climate risks "were mapped to evaluate the resilience of our business", with 2026 plans to develop "adaptive solutions addressing the mapped climate change risks" (page 88).

Not disclosed: results of a resilience analysis, significant areas of uncertainty in it, or capacity to adjust or adapt assets and financial resources over short, medium and long term.

Policies related to climate change mitigation and adaptation

Reference: page 40.

This is a nil return, stated without hedging: "At present, we do not have a formal climate-related policy or climate-related targets in place. This is primarily because the development of both is closely tied to the outcomes of our climate transition planning process, which is still underway. We believe that a credible and effective policy and targets must be grounded in a clear understanding of our emissions profile, reduction pathways, the feasibility of mitigation and adaptation actions, as well as the resources required to implement them" (page 40).

The same position is recorded at group level: "In general, Basic-Fit has not defined any specific targets to manage impacts, risks, or opportunities related to any of the material topics covered in this report. The main reason for this is that our approach to sustainability is not yet fully formalised, including specific approaches to track effectiveness of relevant policies or actions taken" (page 30).

No policy scope, accountable person, stakeholder consideration or availability statement is therefore disclosed for climate, because no climate policy exists. The E1 chapter is organised around the transition plan under development, the 2024 climate risk assessment, energy and GHG metrics instead.

Actions and resources in relation to climate change policies

Reference: pages 40-41, 48, 156.

Actions are disclosed, resources only partly. "Basic-Fit continued to address our negative impacts on the environment in 2025. This includes continued installation of solar panels, heat pumps, efficient water boilers and HVAC control systems. These actions were taken with the expected outcome of reducing our energy consumption and related emissions" (page 41). The EU Taxonomy section names the countries: "we installed highly efficient HVAC control systems and heat recovery units in clubs in the Netherlands" under CCM activity 7.3, and "we also installed solar panels and highly efficient heat pumps in both Belgium and the Netherlands" under CCM 7.6 (page 48).

Self-generated renewable energy rose from 1,947 MWh to 3,485 MWh total production, of which own use grew from 1,584 to 2,968 MWh and 517 MWh was resold to the grid (page 42).

One quantified resource figure exists, in the financial statements rather than the statement: "The sustainability related investments amounted to EUR 2.3 million in 2025 (2024: EUR 6.3 million)" (page 156). The company otherwise disclaims detail: "Basic-Fit is thus unable to describe in detail the key climate change mitigation and adaptation actions, targets or resources allocated to the implementation of this policy" (page 40). No adaptation action is quantified and no CapEx or OpEx is attributed to a decarbonisation lever.

Targets related to climate change mitigation and adaptation

Reference: pages 30, 40, 44. The datapoints table places "ESRS E1-4 GHG emission reduction targets paragraph 34" in the Governance of sustainability matters section (page 76).

No climate targets are set. "At present, we do not have a formal climate-related policy or climate-related targets in place" (page 40), and at group level "Basic-Fit has not defined any specific targets to manage impacts, risks, or opportunities related to any of the material topics covered in this report" (page 30).

The GHG table (page 44) prints empty "Milestones and target years" columns for 2025, 2030 and (2050) and an empty "Annual % target / Base year" column, footnoted: "2024 is the base year... it represents the first year in which we conducted a full, company-wide measurement of our greenhouse gas emissions, and it reflects a normal operating environment without significant external disruptions. As outlined earlier in the report, our climate transition plan, including milestones and targets is currently in development (E1-6 AR 48)."

A dated commitment exists without a pathway: "we have committed to set science-based targets in the upcoming two years, but though we have progressed in identifying 'decarbonization actions', we still need more work to define the final targets" (page 30), with the plan due "by the end of 2026" (page 39).

Energy consumption and mix

Reference: pages 41-42.

Total energy consumption rose from 259,404 MWh (2024) to 298,309 MWh (2025) and the mix moved against renewables (page 41):

• Fossil: 113,706 to 94,725 MWh; share 44% to 32%
• Nuclear: 64,634 to 136,728 MWh; share 25% to 46%
• Purchased renewable electricity, heat, steam and cooling: 79,480 to 63,888 MWh
• Self-generated non-fuel renewable: 1,584 to 2,968 MWh
• Total renewable: 81,064 to 66,856 MWh; share 31% to 22%

Renewable production totalled 3,485 MWh (2,968 own use, 517 resold), up from 1,947 MWh (page 42).

The fall in renewable share is procurement timing, not a sourcing change: "Basic-Fit intends to purchase guarantees of origin (GOs) for total electricity consumption in 2025, with the purchase planned for 2026... As a result, the energy mix indicated in this report may be updated accordingly" (page 42). Belgium and Luxembourg are fully certified renewable; France, Spain, Germany and Austria are disaggregated on 2023 national generation mixes.

Coverage is partly estimated: "Actual electricity data was available for 73% of our total consumption and gas data for 69%", the rest modelled from median consumption per square metre per club per country. Paragraph 38 and paragraphs 40-43 are treated as not applicable, the company classifying itself under NACE R 93.13 "Activities of fitness facilities" (page 42).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 43-45. Against a 2024 base year, emissions rose (page 44, tCO2eq):

• Scope 1: 8,792 to 6,851 (78%); 0% from regulated emissions trading schemes
• Scope 2 location-based: 21,014 to 23,216; market-based: 110 to 32,248
• Scope 3: 187,643 to 216,615 (115%) - purchased goods and services 130,484; capital goods 48,572; waste 18,440; fuel and energy-related 14,089; employee commuting 3,688; franchises 384 (new)
• Total location-based: 217,449 to 246,682; total market-based: 196,545 to 255,714 (130%)
• Intensity: 179 to 174 tCO2e per million euro location-based; 162 to 180 market-based (page 45)

The market-based jump is explained: 2024 was restated down from 10,577 to 110 tCO2eq for green certificates bought after year-end, and for 2025 "our electricity supply is not currently backed by Guarantees of Origin (GOs). Consequently, residual mix factors are applied, resulting in higher market-based emissions" (pages 43-44).

Scope 3 was rebuilt by classifying spend by industry rather than tax code, restating 2024 purchased goods and services from 152,227 to 106,551 and capital goods from 128,691 to 55,361 tCO2eq, and removing 110,256 tCO2eq of club construction as outside control (page 43). Visitor travel (139,323 tCO2eq, voluntary in 2024) and investments were dropped. Scope 3 carries "a high level of measurement uncertainty" (page 28).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 45. The datapoints table locates paragraph 56 in the Climate change and energy section (page 76).

A complete nil return: "Basic-Fit did not purchase any carbon credits in 2025 and did not participate in any GHG removal or GHG mitigation projects financed through carbon credits" (page 45).

This is consistent with the rest of the climate chapter: the company has no net-zero or neutrality claim to support with credits, because it has no GHG target at all and its transition plan is still in development (pages 39-40). No removals are recorded in its own operations or upstream and downstream value chain, and no future reliance on removals or credits is disclosed. The excess renewable electricity its solar panels return to the grid (517 MWh in 2025) is reported as energy resold rather than as an offset or a removal (page 42).

Internal carbon pricing

Reference: page 45.

A nil return: "Basic-Fit has not applied any internal carbon pricing schemes" (page 45), disclosed in the GHG emissions methodology notes alongside the statements on carbon credits and the consolidation scope.

No shadow price, internal carbon fee or implicit price is used in capital allocation, investment appraisal or the energy-efficiency investment decisions described under E1-3, and none is indicated as planned. The company's capital decisions on solar panels, heat pumps and HVAC control systems are framed in energy cost and consumption terms instead: energy-saving initiatives are presented as an opportunity that "lead to long-term operational cost reductions, improving profitability" (page 36), with the 2025 savings "offset by the increase in operating expenses directly related to the higher number of clubs, members and employees" (page 38).

Policies related to resource use and circular economy

Reference: page 47.

This is a disclosed absence rather than a policy description. The smart refurbishment model "originated as a proactive effort to further reduce our environmental footprint. However, having no dedicated environmental policy, we will keep working in 2026 to develop one and thus formalise the management of our impacts, risks and opportunities related to topics such as sustainable sourcing, use of renewable resources, and circular economy" (page 47).

The company also discloses that no circularity-specific assessment underpins its approach: "Similarly, we did not undertake any specific assessment process regarding our resource use and circular economy. For instance, we did not specifically screen activities in our value chain in terms of resource flows or waste, or perform any dedicated consultations on the topic" (page 47).

What exists instead of a policy is a contractual arrangement with the fitness equipment supplier and the Supplier Code of Conduct, which the refurbishment agreement applies alongside "the responsible disposal or recycling of replaced equipment components" and "compliance with ESG reporting obligations" (page 46). No policy scope, accountability or alignment with the waste hierarchy is disclosed, because no policy is in place.

Actions and resources related to resource use and circular economy

Reference: pages 46, 48-49.

The single substantive action is the smart refurbishment model run with equipment supplier Matrix since 2024: "This model safeguards the quality of the equipment by maintaining the look, feel, and function... extends the lifespan of our equipment and therefore reduces our demand for new equipment. This is achieved via periodic inspections, the implementation of preventive maintenance activities, and the prompt repair of identified defects by Matrix. The agreement... also covers the responsible disposal or recycling of replaced equipment components, compliance with ESG reporting obligations, and the application of our Supplier Code of Conduct" (page 46).

2025 progress was operational: "we collaborated with Matrix to streamline the inspection and maintenance process, by aligning the databases of our two companies. Our product team manages and monitors the process through a unified ticketing system... Bi-weekly meetings are also held between stakeholders... This process has contributed to faster maintenance activities" (page 46).

The EU Taxonomy analysis quantifies the life extension: the supplier refurbishes equipment "until it reaches a new maximum lifetime of 12 years", classified under circular economy activity 5.1 Repair, refurbishment and remanufacturing (page 49). No resources, CapEx or OpEx are attributed to the action in the statement itself.

Targets related to resource use and circular economy

Reference: page 46.

A nil return with a stated reason: "Given that we have focused on setting up this process and ensuring that it runs well, we have not defined any targets for our smart refurbishing project" (page 46).

This sits within the company-wide position: "In general, Basic-Fit has not defined any specific targets to manage impacts, risks, or opportunities related to any of the material topics covered in this report. The main reason for this is that our approach to sustainability is not yet fully formalised, including specific approaches to track effectiveness of relevant policies or actions taken" (page 30).

No target is therefore reported for resource inflows, resource outflows, waste or the increased circularity of product design, and no baseline year or milestone is set. The only quantified trend available to a reader is the entity-specific inflow metric: the weight of fitness equipment acquired per club fell from 4.17 to 2.90 tonnes (page 46), which the company presents as a metric rather than as progress against a target.

Resource inflows

Reference: page 46. The weight of fitness equipment acquired per club is also listed as an entity-specific metric (page 75).

Basic-Fit reports one inflow material - fitness equipment, by weight (page 46):

• Weight of fitness equipment acquired in the year: 4,858 tonnes in 2025, down from 6,565 tonnes
• Weight of fitness equipment acquired per club: 2.90 tonnes, down from 4.17 tonnes

Data provenance is primary: "Primary data obtained from the fitness equipment supplier includes details on the quantity of each equipment type and the total weight purchased by Basic-Fit in 2025" (page 46).

The recycled content datapoint is absent and the absence is explained: "We consulted with our supplier regarding the weight of recycled and other secondary materials or components used to manufacture fitness equipment as a proportion of total input used (in connection with ESRS E5-4-c) but this data is not available" (page 47). The company also removed the line rather than carry an empty row: "This table included a line in 2024 regarding the percentage of fitness equipment composed of recycled or secondary materials, with the indication that the data was not available then. As this figure is still not available in 2025, the line has been excluded from the table this time" (page 46). No total overall weight of products and technical and biological materials used, and no share of sustainably sourced biological materials, is reported.

Policies related to own workforce

Reference: pages 52-53. The S1-1 datapoints on human rights policy commitments (paragraph 20), ILO due diligence (21), trafficking measures (22) and workplace accident prevention (23) are located in this section (page 77).

Policies disclosed (pages 52-53):

• Diversity, Inclusion and Belonging policy - prohibits discrimination on race, ethnicity, gender, sexual orientation, disability, religion "or any other protected characteristics"; covers employees, temporary staff, consultants, interns and freelancers; on the intranet; Management Board accountable
• Health and Safety policy - newly designed in 2025, it "comes into full effect in 2026"; objectives are incident reduction and prevention, cost reduction, compliance and risk management, training and employee satisfaction; a steering committee supports it and the Health and Safety Manager owns it

Human rights commitments sit outside any policy: "While we do not have a dedicated human rights policy, Basic-Fit ensures compliance with international human rights principles through adherence to local laws, practices, and procedures. Our employee lifecycle processes inherently aligns with standards such as the UN Guiding Principles on Business and Human Rights and the ILO Declaration" (page 53). "We do not conduct separate assessments for human rights violations because they are integrated in our standard compliance monitoring" (page 53).

Engaging with own workforce and workers' representatives

Reference: pages 53-54.

Engagement runs through surveys, dashboards and the Works Council. "Employee surveys are conducted every 18 months, alongside quarterly data analysis, which provide valuable insights that shape our HR strategy" (page 54). "Our Works Council meets with the company representation, including the CFO, whenever workers concerns are raised, in addition to two meetings every year to discuss the company's end-of-year and half-year results. For example, the council must be involved in any major business decisions such as a merger or acquisition" (page 54). At board level "the CFO engages with the Works Council periodically, as laid down in the company's articles of association, and shares related topics with the members of the Supervisory Board" (page 29).

Two limitations are disclosed. On effectiveness: "While there is no specific process for the assessment of the effectiveness of these engagements, the Management Board is responsible of ensuring that engagements with employees and their representatives take place" (page 54). On vulnerable groups: "There is no dedicated approach to seek input from specific groups that could be considered particularly affected or vulnerable, such as part-time workers or those with disabilities" (page 53) - notable given that 72% of the workforce is part-time (page 55).

Remediation processes and channels to raise concerns

Reference: pages 53, 62, 70. The grievance mechanisms datapoint (paragraph 32(c)) is located in the Business conduct section (page 77).

The channel is the Speak-Up policy, which "applies not only to employees but to all people who provide labour or services to Basic-Fit, including the employees of our suppliers and contractors" (page 70). Speak-Up officers are appointed in each country, "legal counsels familiar with European and local laws related to whistleblowing, and are accessible directly and in the local language", coordinated centrally, with the central officer informing the Management Board by memo (page 70). Investigation committee members "must be impartial and have no prior involvement with the misconduct", and are "separate from the chain of management involved in the matter"; good-faith reporters "are legally protected from any form of retaliation" (page 71).

Two gaps are disclosed. "When we remedy a situation brought to our attention via the Speak-Up policy, there is no specific assessment of the effectiveness of such remedy" (page 53). And "no particular action has been launched specifically to provide or enable the remedy of negative impacts beyond those stipulated in existing policies, such as the Speak-Up policy" (page 54). Awareness and trust are measured indirectly, "based on the rate of training completion, which requires a passing grade" (page 53).

Taking action on material impacts on own workforce

Reference: pages 52-54, 62.

Actions are operational rather than programmatic. Safety rests on "constant connection to our certified Monitoring Alarm and Receiving Centre (MARC) at our clubs. Club employees or members who find themselves in trouble can rely on direct assistance from our MARC by using alarm buttons. In 2025, we introduced new employee training to ensure club employees know how to collaborate with our MARC" (page 53). Health and safety is run locally by prevention officers who "supervise how clubs operate, have an overview of hazards and risks, and ensure that employees receive continuous safety training, including ergonomics, first-aid and fire prevention" (page 62).

The limits are stated twice. "We aim to avoid causing or contributing to material negative impacts on our employees through adherence to the policies described in this section. However, we do not currently have any specific processes in place aimed at ensuring that our practices do not cause or contribute to material negative impacts on our own workforce" (page 54). On resources: "In general, the resources devoted to HR are allocated to manage material impacts, risks and opportunities related to the topic of 'Our people'" (page 54) - no amount is given.

Targets related to own workforce

Reference: pages 30, 53-54. The index places S1-5 in the Governance of sustainability matters section (page 74).

A nil return. "Impacts related to our workforce are addressed as a whole... As such, we do not yet evaluate these actions by setting specific targets (for example, in terms of the metrics presented below) with respect to our employees" (page 54), and at group level "Basic-Fit has not defined any specific targets to manage impacts, risks, or opportunities related to any of the material topics covered in this report" (page 30).

The stated reason is maturity: "our approach to sustainability is not yet fully formalised, including specific approaches to track effectiveness of relevant policies or actions taken... Despite our progress, we have not been able to formally establish approaches for effectiveness tracking in 2025, but will continue our efforts in upcoming years" (page 30).

One measurement framework is described but not yet in force. To measure the success of the new Health and Safety policy, which takes full effect in 2026, "the steering committee will monitor key indicators connected to the previously mentioned objectives such as incident rates/trends, lost work-days, compliance failures, compensation costs, employee training completion, and employee satisfaction" (page 53). No target value or target year is attached to any of these.

Characteristics of the undertaking's employees

Reference: pages 55-56.

Headcount at year-end 2025 was 9,084 for Basic-Fit (2024: 8,937) plus 348 for Clever Fit, giving 9,432 in total (page 55). By gender across both: 4,860 men, 4,565 women and seven individuals who identify as gender-neutral (page 55).

By country (head count, 2025 against 2024): France 3,875 (3,674); Netherlands 2,278 (2,522); Spain 1,583 (1,470); Belgium 975 (979); Germany 373 (292); Clever Fit 348 (page 55).

By contract type (total 2025 against 2024): permanent 7,847 (7,226); temporary 1,526 (1,608); non-guaranteed hours 59 (103), all of the last in the Netherlands (page 56). Turnover is high and explained: 4,309 leavers at a 55% turnover rate (2024: 5,002 and 60%), reaching 64% in Germany and 55% in France, because "our employees tend to take jobs temporarily, for example during study breaks" (page 58).

Composition notes: "approximately 72%, opts for part-time roles" and "A substantial part (91%) of our personnel works in our clubs" (page 55). Scope exclusions are stated: the count "excludes the Management Board (CEO and CFO) but includes the rest of the Leadership Team (CCO and COO)", and "Workers in Luxembourg are not accounted as employees, as they are subcontracted" (page 56).

Collective bargaining coverage and social dialogue

Reference: page 57.

"All of our employees in France, Spain, and Belgium benefit from the protective umbrella of collective bargaining agreements, adhering to standard sector norms" (page 57). By coverage band:

• 80-100%: Belgium, France, Spain - "100% of our employees in France, Spain and Belgium are covered by collective bargaining agreements"
• 0-19%: Germany, Netherlands - "0% of our employees in Germany or the Netherlands are covered by such agreements"

Workplace representation (EEA only): Belgium, France and the Netherlands at 80-100%, Spain at 60-79%, Germany at 0-19%. The footnote quantifies it: "100% of our employees in Belgium, France and the Netherlands are covered by workplace representation. 66.37% of our employees in Spain and 0% of our employees in Germany... These percentages are the same for both 2024 and 2025 for all countries except in the case of Spain (28.62% in 2024)" (page 57).

Germany and the Netherlands together hold 2,651 of 9,084 Basic-Fit employees (page 55), so a substantial minority sits outside collective bargaining. Scope: "The totals represent employees in the European Economic Area (EEA), as we do not have employees outside this region"; there is no European Works Council, SE or SCE Works Council agreement; "Clever Fit is excluded due to HR information systems not being fully integrated" (page 57).

Diversity metrics

Reference: pages 55, 58-59.

Top management: "At the end of 2025, 38% top management positions were female" - 15 women and 24 men across 39 positions, against 14 and 25 in 2024 (page 58). Top management is "defined as equal or higher than scale 18 in the Basic-Fit job classification system (based on Korn Ferry Hay Method), excluding the Leadership Team (CEO, CFO, CCO, and COO)", and is the same population the Corporate Governance section calls middle management (page 58).

Age distribution of the workforce (2025 against 2024): under 30 59% (60%); between 30 and 50 33% (32%); over 50 8% (8%). The profile varies widely by country - Germany is 81% under 30 and the Netherlands only 41%, with 21% of Dutch employees over 50 (page 59).

Overall gender split across Basic-Fit and Clever Fit is 4,860 men, 4,565 women and seven gender-neutral individuals (page 55). At board level the ratio of female to male members is 33% for the Leadership Team and 50% for the Supervisory Board (page 28).

Scope exclusions are stated for both tables: the Management Board is excluded but the CCO and COO included; Luxembourg workers are subcontracted and excluded; and "Clever Fit is excluded as its job specifications have not been integrated within Basic-Fit's classification system" (pages 58-59).

Adequate wages

Reference: page 61.

A positive nil-exception return: "All employees are paid an adequate wage, in line with applicable benchmarks, understood as either legal minimum wage per country or wage as per collective bargaining agreement (when the latter is higher)" (page 61).

The benchmark definition is therefore the statutory minimum wage or, where a collective agreement applies and pays more, that agreement. Collective bargaining covers 100% of employees in France, Spain and Belgium and 0% in Germany and the Netherlands (page 57), so for roughly 2,650 of the 9,084 Basic-Fit employees the applicable benchmark is the national legal minimum. No percentage of employees paid below an adequate wage is reported, because the company states none are, and no country-level wage floor figure is given.

Supporting context sits under S1-16: the gender pay gap was 2.9% in 2025, against an EU average the company cites at 11.1% as of 2024, and "below the threshold of the EU Gender Pay Transparency Directive, which has a threshold of 5%" (page 61).

Training and skills development metrics

Reference: page 60. This is one of the four areas where Basic-Fit expressly declined the available phase-in relief (page 28).

First-year metrics, 2025 only (page 60):

• Participation in performance reviews: 85% overall - male 86%, female 85%, other 57%
• Average learning hours per employee: 8.5 - male 8.9, female 8.1, other 9.3

"In 2025, 85% of our employees participated in performance reviews. Our employees also received more than 8 hours of training on average. Learning hours refer to the completion of mandatory trainings, such as club staff onboarding, health and safety training, and risk management training for corporate employees" (page 60).

Scope is explained: "As this is the first year we include these metrics... the tables above refer to year 2025 only. The 15% of employees that were not part of the performance review process include those that joined Basic-Fit after October 1st, 2025 and employees that were terminated during 2025. In addition, certain employee types, such as students and contingent workers, and those taking certain types of absences such as long-term sick leave, do not take part", and "Clever Fit is excluded as data is not yet integrated" (page 60). The underlying approach is a "70, 20, 10" model using LinkedIn Learning and Goodhabitz (page 53).

Health and safety metrics

Reference: page 62. The days-lost datapoint (paragraph 88(e)) is labelled "Phased-in, not reported" (page 77).

2025 against 2024 (page 62):

• Employees covered by a health and safety management system: 100% in every country
• Fatalities: 0 (0)
• Accidents: 503 (405); rate of accidents 48.47 (50.24) per million hours worked
• Accidents by country: France 396 (286), Spain 69 (57), Belgium 30 (36), Netherlands 5 (20), Germany 3 (6); rates France 76.30 (64.14), Germany 8.17 (94.73), Netherlands 2.00 (11.42)

The France increase is addressed: "The total accidents recorded were generally as expected, except in France where we observed an unexpected increase... We believe that the maturation of our health and safety department in France contributed to an enhanced focus on health and safety compliance and an increase in reported accidents. Our recently established Health and Safety Steering Committee will enable investigation into the matter" (page 62).

Two caveats: "The number of accidents in France in 2025 required partial estimation due to irreparable documentation errors", and "Clever Fit is excluded due to HR systems not being integrated" (page 62). Recording is broad - "recorded accidents include any case deemed to be work-related regardless of the level of seriousness". No work-related ill health cases or days lost are reported.

Compensation metrics (pay gap and total compensation)

Reference: page 61.

• Gender pay gap: 2.9% in 2025, down from 3.1%
• Annual total remuneration ratio: 61.03, against a restated 55.53 in 2024

"This year, we recorded a gender pay gap of 2.9%. The figure slightly decreased from 2024's pay gap of 3.1% and remains notably low compared to the EU average, which stood at 11.1% as of 2024. Additionally, this number is below the threshold of the EU Gender Pay Transparency Directive, which has a threshold of 5% and does not mandate action for such a low pay gap. The use of the gender pay gap also indicates that there is a low probability of structural injustices between genders within Basic-Fit" (page 61).

Definitions and a restatement are given: "The gender pay gap is defined by the weighted average pay gap per country. The annual total remuneration ratio is defined by the reward of the highest paid individual in the organisation, the CEO, divided by the median reward of the total employee base excluding the CEO. In 2025 we set-up a cross department taskforce through which we significantly improved how we track and calculate remuneration metrics. As a result, we are revising the remuneration ratio of 2024 from 61.45 to 55.53. Clever Fit is excluded as payroll systems are not integrated" (page 61). On the ratio, the restatement means the headline figure rose year on year against the revised base while matching the originally published 2024 figure almost exactly.

Incidents, complaints and severe human rights impacts

Reference: page 62. The discrimination incidents datapoint (paragraph 103(a)) and UNGP and OECD non-respect datapoint (104(a)) are located in the Our people section (page 77).

Two separate counts are reported (page 62):

• Speak-Up channel: 0 incidents recorded in 2025, against 1 in 2024
• Discrimination or harassment: 60 reported incidents in 2025, against 57 in 2024, "including aggression towards staff by members"
• Fines, penalties and compensation: EUR 0.0 - "Resulting from all issues raised, no fines, penalties or compensation for damages (i.e., EUR 0.0) have had to be paid"

"These incidents are investigated and addressed separately in each country. These figures do not include Clever Fit due to HR information systems not being fully integrated" (page 62); Clever Fit is also outside the Speak-Up count "because employees are not yet covered by Basic-Fit HR and the Speak-Up systems".

The gap between 60 discrimination or harassment reports and 0 Speak-Up reports is not reconciled, and no severe human rights incident is reported. The company states its view of inherent risk elsewhere: standard compliance monitoring makes "human rights violations, such as forced labour, human trafficking, or child labour highly unlikely in our operations. Basic-Fit operates as a low-risk organisation for its own employees in these areas" (page 53).

Policies related to value chain workers

Reference: page 63. The S2-1 datapoints on human rights policy commitments (paragraph 17), policies related to value chain workers (18), non-respect of UNGPs and OECD guidelines (19) and ILO due diligence (19) are located in this section (page 77).

This is an explicit nil return. "We have not yet adopted a policy to manage our material impacts on workers in our supply chain, including setting up mechanisms to provide or enable remedy for human rights impacts" (page 63). S2 is one of the four areas where Basic-Fit declined the available quick-fix phase-in relief (page 28), so the disclosure is made despite the absence of a policy.

What is in place is contractual and partial: "We expect our suppliers and partners to adhere to local legal and regulatory requirements, including respect for the human rights of workers. We have a supplier Code of Conduct that we apply to many of our long-standing suppliers, and we have open communication with subcontracted personal trainers in our clubs" (page 63). The outsourcing partner for customer service "has signed a Code of Conduct that covers standards of responsible business conduct" (page 63).

A policy is under construction with a date: "we have also begun developing a human rights policy, ensuring it covers workers in our supply chain. In 2026, we will finalise and formalise the policy and start working on its implementation" (page 63).

Engaging with value chain workers about impacts

Reference: page 63.

Engagement is direct only for workers on Basic-Fit premises, and the shortfall is acknowledged. The groups in scope are set out: "Workers working directly at our facilities, mainly cleaners, maintenance personnel and trainers", outsourced customer service agents, "Construction workers who carry out minor renovation activities required to open a new club", "Workers manufacturing our fitness equipment further upstream in our supply chain", and "Workers in franchised clubs" (page 63).

Vulnerability is identified: "The groups above can include workers who may be particularly vulnerable due to their inherent characteristics, mainly those who could be mistreated due to their migrant status or their gender" (page 63).

The existing channel is narrow: "we have open communication with subcontracted personal trainers in our clubs". The company states the shortfall plainly: "we understand that as a responsible business we should have closer engagement with our suppliers and partners to ensure their workers are treated fairly", and "Basic-Fit has not yet established dedicated processes, metrics or targets to monitor material matters regarding workers in our supply chain" (page 63).

Remediation processes and channels for value chain workers

Reference: pages 63, 70-71.

The only channel reaching value chain workers is the Speak-Up policy, which "applies not only to employees but to all people who provide labour or services to Basic-Fit, including the employees of our suppliers and contractors. The aim of this policy is to ensure that anyone affected has the ability to report issues that are not in line with Basic-Fit's principles and values" (page 70).

Against that, the company states the absence of a remedy framework for this group: "We have not yet adopted a policy to manage our material impacts on workers in our supply chain, including setting up mechanisms to provide or enable remedy for human rights impacts", and "Basic-Fit has not yet established dedicated processes, metrics or targets to monitor material matters regarding workers in our supply chain" (page 63).

No assessment is disclosed of whether value chain workers know of or trust the channel, and no requirement is reported that suppliers maintain their own grievance mechanisms. Upstream manufacturing workers - the group the company itself links to forced labour risk in some Asian countries - are the furthest from it.

Taking action on material impacts on value chain workers

Reference: pages 63, 72. The human rights issues and incidents datapoint (paragraph 36) is located in this section (page 77).

Action sits at the procurement-process level. "In 2024, we took a first step in this direction by performing a thorough assessment of our procurement processes, with the objective of, among other things, including sustainability and responsible business conduct considerations in our procurement policies. In 2025, we have taken initial steps to professionalise, standardise and centralise our procurement processes, including welcoming a new procurement manager. In connection with this, we have also begun developing a human rights policy, ensuring it covers workers in our supply chain" (page 63).

The current gap is named without softening: "the supplier selection procedures do not take into account social and environmental criteria, which we recognise as a gap we need to address" (page 72).

No business model change is foreseen: "We consider the material impacts we could have on the workers in our supply chain as directly connected to our business model, but we do not anticipate any major strategy or business model adaptations being required to address these impacts" (page 63). No supplier audit, remediation case, resource figure or severe human rights incident is reported, and effectiveness tracking is explicitly absent (page 63).

Taking action on material impacts on affected communities

Reference: page 68. The financial contribution to communities is also listed as an entity-specific metric (page 75).

Action is delivered through partnerships: "Our main partner in the Netherlands and Spain is the Johan Cruyff Foundation. Together we focus on children and young people for whom access to sport is not guaranteed. Through sports sessions and workshops, we raise awareness of the benefits of physical activity... In Belgium, we support Sport2be and our partner in France is Sport dans la Ville" (page 68).

Financial contribution to communities fell to EUR 675 thousand from EUR 860 thousand (page 68), explained: "Our spending was lower in 2025, as in 2024 we made a one-time dedicated contribution for our adherence to the Grande Cause Nationale in the context of the 2024 Olympics in France. Clever Fit is excluded as community investment strategies are not integrated yet." The calculation "is based on contributions to partners following indications from our communications and marketing teams" and includes any amount registered as a donation.

Governance is an internal framework rather than a policy, with "internal oversight, approval processes, and criteria" (page 68). No severe human rights issues or incidents connected to communities were identified.

Policies related to consumers and end-users

Reference: pages 65, 68. The S4-1 datapoints on policies related to consumers and end-users (paragraph 16) and non-respect of UNGPs and OECD guidelines (17) are located in the Our members section (page 77).

Member-facing instruments are documentary: country-level terms and conditions that "any person seeking to become a member must declare they have read and accepted", covering withdrawal rights, access, fees and payments, QR codes and member cards, opening hours, minimum age, insurance, risks and liability and personal data; a privacy statement setting out how personal data "is anonymised, not used for other purposes and deleted after a limited period", the safeguards applied, transfers outside the EU and complaint handling; and regulations for the use of camera surveillance covering "image retention periods, transparency, transfers and the security of images" (page 65).

Alignment with international instruments is disclaimed: "While our policies related to members are not explicitly aligned with internationally recognised instruments relevant to consumers, such as the UN Guiding Principles on Business and Human Rights, Basic-Fit ensures compliance with international human rights principles through adherence to local laws, practices, and procedures. Breaches of the right to privacy present a non-severe risk of a failure to respect our members' human rights" (page 65).

Engaging with consumers and end-users about impacts

Reference: page 65. S4-SBM-2, the interests and views of members, is also located in this section (page 74).

"We engage with our members at every stage of their membership. For example, when members join, they receive a confirmation email providing them with their contract, terms and conditions and house rules, instructions for downloading the Basic-Fit app and using the QR code to access our clubs" (page 65).

"Basic-Fit also continuously gathers feedback from members through several channels. We periodically collect feedback via our app after members have visited a club, including questions related to the member's overall experience, hygiene, staff, crowdedness, equipment and ambiance of the club. This feedback is requested from members once every two weeks after at least two club visits to a maximum of twice per month per member. Either seven weeks or six months after becoming a member, members are asked to tell us how likely they are to recommend Basic-Fit to other people. We monitor this feedback continuously and escalate as appropriate" (page 65).

Responsibility is assigned: "The Customer Relationship Manager and Customer Service Manager have operational responsibility for these engagements, while the Management Board is responsible for ensuring that the results inform Basic-Fit's approach" (page 65). No engagement route specific to vulnerable member groups is described.

Remediation processes and channels for consumers and end-users

Reference: pages 65-66.

Channels are set out in detail. "From within our clubs, members can speak to our hosts or they can contact an agent 24/7 via an intercom... Basic-Fit also makes a chatbot known as 'Ruby' available to members. Ruby can help members with certain queries and pass the member on to a customer service agent in cases it cannot resolve. Additionally, members can raise any concerns directly with customer service, which they can contact through the live chat on our website or app, on Facebook or via email" (page 65).

Escalation is routed by issue type: club facilities to the regional or cluster manager; "If it is in relation to harassment or aggression from another member it will be escalated to the regional or cluster manager and a warning or a ban will be issued to the offending member. If it is a GDPR-related complaint, it will be escalated to the Privacy Officer" (page 66), with the International Customer Service Manager responsible and ultimate responsibility with the Management Board.

Three gaps are disclosed in one paragraph: "We do not yet have in place specific processes to assess the effectiveness of remedies provided... while the contents of member complaints are monitored, we do not yet assess whether members are aware of these structures or trust them as a way to raise concerns" (page 66).

Taking action on material impacts on consumers and end-users

Reference: pages 64, 66-68. The human rights issues and incidents datapoint (paragraph 35) is located in this section (page 77).

Actions map to the identified IROs. Against information complexity and equipment misuse: "We continue to work to improve the Basic-Fit app functionalities and provide an in-app tour to guide users", plus app customisation, and in 2025 "we launched our AI powered Fitbuddies in the Netherlands... while keeping personal data private and secure" (page 64). Against inaccessibility and gymtimidation, the 'Be Comfortable' initiative "includes digital and in-club initiatives such as behavioural guidelines for members, staff training on how to create a comfortable environment, tailored training plans for various groups and social content to tackle gym intimidation in a positive way" (page 67), responding to two commissioned studies finding "some 30% of people experience 'gymtimidation'". Since 2023 the app carries programmes for people "who can present with a lack of motricity (motor skills)"; 2025 added 'Boost Her Power' and 'Boost Your Mind'.

Resources and remedy are not quantified: "Basic-Fit is thus unable to describe in detail the actions or resources, or specific targets, allocated to the implementation of these policies" (page 68).

Targets related to consumers and end-users

Reference: pages 30, 64, 68. The index places S4-5 in the Governance of sustainability matters section (page 74).

No ESRS target is set: "Basic-Fit is thus unable to describe in detail the actions or resources, or specific targets, allocated to the implementation of these policies" (page 68), consistent with "Basic-Fit has not defined any specific targets to manage impacts, risks, or opportunities related to any of the material topics covered in this report" (page 30).

What is presented instead is an operating objective with a reported outcome: "We want to motivate our members to visit our clubs at least once a week, so they are on the right track to build a healthy lifestyle. Our objective is to inspire our members to visit our clubs at least this frequently or more. We are glad to have reached this objective again in 2025, with a slight increase connected to the expansion of 24/7 clubs" (page 64).

Effectiveness is tracked loosely: "achieving increases in our membership base and seeing our members visit our clubs at least once a week, serves as a general indication that our efforts are broadly effective" (page 68). Health and safety goal setting for members begins only "Once the steering committee is in place in 2026" (page 67).

Business conduct policies and corporate culture

Reference: pages 53, 69-71. The UN Convention against Corruption datapoint (paragraph 10(b)) and protection of whistleblowers (10(d)) are located in this section (page 77); G1.GOV-1 paragraphs 5a and 5b are incorporated by reference to Corporate Governance (pages 102, 103).

"Basic-Fit has a Code of Conduct, which reflects the company's values and principles and ethical business practices in a wide range of areas, such as good business practice, integrity in dealing with third parties and financial reporting, health and safety, conflicts of interest and handling confidential information" (page 70). It "applies to all employees and temporary staff, consultants, interns and freelancers", and "The principles and rules for ethical conduct, anti-corruption and anti-bribery are laid down in the Code of Conduct".

Supporting policies: an insider trading policy under the European Market Abuse Regulation, an internal data security policy, and the Speak-Up policy (pages 70-71). Culture is reinforced by mandatory annual retraining: "As of 2025, we have implemented a mandatory, annual (re)training for employees outlining our 'Compass of Conduct'... Awareness and trust in the Speak-Up policy and the effectiveness of the training are measured based on the rate of training completion, which requires a passing grade" (page 53). One gap: "We do not have a specific policy for training related to these instruments" (page 70).

Management of relationships with suppliers

Reference: page 72.

"Basic-Fit applies a supplier Code of Conduct, and the second line of defence regularly performs reviews regarding business conduct and corporate culture, including on supply chain matters" (page 72). "When entering into any engagement with suppliers, Basic-Fit always tries to apply its own contract documentation, including the principles and values related to sustainability, human rights, anti-corruption and anti-bribery, or negotiates the contract conditions to ensure that these principles and values are complied with."

Two limitations are disclosed without hedging. On SMEs and payment vulnerability: "We do not monitor the size of our suppliers specifically to identify which are SMEs. Payment terms may be shorter for small suppliers in accordance with local legislation." On selection criteria: "We recognise that we need to continue to develop sustainability-related matters in our relationships with suppliers and that these are not yet fully embedded. For example, the supplier selection procedures do not take into account social and environmental criteria, which we recognise as a gap we need to address" (page 72).

The material IRO this addresses is power imbalance: "Basic-Fit's commercial influence or high dependency of certain suppliers on Basic-Fit's payments might create power imbalances. This could pressure suppliers to cut corners" (page 37).

Prevention and detection of corruption and bribery

Reference: pages 70-71.

Risk assessment is annual and methodical. "The elements and values reflected in the Code of Conduct are assessed in an annual integrity, fraud and corruption risk assessment, based on a Systematische Integriteitrisicoanalyse (SIRA, in Dutch) model. The Basic-Fit compliance officer initiates and processes this assessment. This includes assessing those functions most at risk in respect of corruption and bribery, which are generally related to all employees who are qualified as 'insiders' due to our obligations as a stock exchange listed company" (page 70) - the Supervisory and Management Boards plus parts of finance, property, marketing, legal, IR, tax, IT, operations and HR.

Investigation is independent of management: Speak-Up investigation committee members "must be impartial and have no prior involvement with the misconduct, nor a close personal or working relationship with the person being investigated. The investigators are also separate from the chain of management involved in the matter" (page 71). Basic-Fit "has been subject to all national laws, including Directive (EU) 2019/1937, related to the protection of whistleblowers since our initial public offering" (page 71).

Training is embedded rather than dedicated: "We do not have a specific policy for training related to these instruments, but the principles and rules of business conduct are embedded in our onboarding programme" (page 70).

Targets related to business conduct

Back-filled from the business conduct chapter and the governance section, 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.

No business conduct target is set. "In general, Basic-Fit has not defined any specific targets to manage impacts, risks, or opportunities related to any of the material topics covered in this report... we have not been able to formally establish approaches for effectiveness tracking in 2025" (page 30).

Consistent with MDR-T's other limb, effectiveness is nonetheless tracked:

• Training: "Awareness and trust in the Speak-Up policy and the effectiveness of the training are measured based on the rate of training completion, which requires a passing grade" (page 53)
• Risk assessment: the annual integrity, fraud and corruption risk assessment on the SIRA model "enables us to determine which target groups may require (re)training" (page 70)
• Outcome counts: 0 Speak-Up reports in 2025 (1 in 2024) and EUR 0.0 in fines, penalties or compensation (page 62)

"The Leadership team takes overall responsibility for Basic-Fit's sustainability strategy, approves targets and monitors performance" (page 69), but no approved target is disclosed.

Political influence and lobbying activities

Reference: page 71.

Political contributions: EUR 648 thousand in 2025, down from EUR 875 thousand. "We manage our political engagement in coordination with trade unions and lobbying agencies advocating for the promotion of fitness and physical activity. The amount of 'political contributions'... represents the financial resources paid to these organisations. We made no additional contribution to any other type of recipient or beneficiary" (page 71).

Lobbying topics are listed and tied to material matters: "lobbying activities are primarily focused on material impacts, risks and opportunities that connect with the promotion of health and well-being, working conditions of the workforce, and members' safety and security".

Governance and the revolving-door datapoint are both covered: "The Management Board is responsible for the oversight of these activities. Additionally, none of the members of Basic-Fit's administrative, management and supervisory bodies appointed in 2025 held a comparable position in public administration in the two years prior to said appointment" (page 71). Clever Fit is excluded. No EU transparency register entry is cited.

Payment practices

Reference: page 72.

• Average time for payment: 28 days in 2025, down from 32
• Outstanding legal proceedings for late payments: 0, down from 1
• Payments aligned with standard terms: 93% (2024: 91%)

"Payments are performed upon receipt of invoice as per agreed payment terms with suppliers. Unless otherwise specified, these terms follow the generally applicable payment terms between companies of 60 days" - footnoted to "the European Directive for combating late payments in business dealings" - and "These terms apply to all of our supplier categories, and 93% of payments are aligned with them (91% in 2024)" (page 72).

Method and scope are stated: "The average time for payment is calculated as the difference between the date of payment and the date of receipt of invoices. The alignment percentage of payments with payment terms reflects the percentage of invoices paid in under 60 days. The calculation excludes direct debit payments and correction entries. Clever Fit is excluded as supplier payment systems are not integrated" (page 72).

The SME datapoint is not answered, with the reason given under G1-2: "We do not monitor the size of our suppliers specifically to identify which are SMEs" (page 72). That matters because the company's own material IRO concerns "high dependency of certain suppliers on Basic-Fit's payments" creating power imbalances (page 37).