BasicNet

Governance roles

Reference: pages 67-70. Composition datapoints are incorporated by reference to the Directors' Report (page 148).

Board composition (Table 1, page 68): 14 members, unchanged from 2024, of whom six are female (43%), eight executive (57%), six non-executive (43%) and three independent (21%).

Responsibilities (pages 69-70):

• The Board sets strategic direction, monitors the Internal Control and Risk Management System, and reviews and approves the double materiality assessment and the statement after a favourable opinion of the Control and Risks Committee.
• The Control and Risks and Related Parties Committee oversees risk management; it comprises three independent directors, Piera Braja (Chairperson), Francesco Calvo and Cristiano Fiorio.
• The Chief Staff Officer, who is also Internal Control and Sustainability Director, coordinates the statement and reports to the Committee quarterly.
• The Executive Officer for Financial Reporting certifies the statement under Article 154-bis(5-ter) of Decree No. 58/1998.

No employee representation: "BasicNet does not provide for formal and direct employee representation within its administration, management and supervisory bodies", worker involvement running instead through unions, RSAs and RSUs (page 68).

The Group adds that "Although no formal ESG objectives are currently in place, Directors are committed to incorporating ESG considerations into their decisions" (page 68).

Information flow to the governance bodies

Reference: page 70.

The Control and Risks and Related Parties Committee "meets on average every quarter and, when necessary, dedicates part of its discussions to sustainability updates". In those meetings it "receives reports and updates from the Occupational Health and Safety Manager and the Supervisory Board (SB) to monitor material impacts, risks and opportunities, and to evaluate the effectiveness of the policies and actions adopted".

Frequency in 2025 is quantified: "During the year, the CRRPC of BasicNet addressed, during three meetings, ESG-related risks which were subsequently assessed as material through the double materiality assessment." The governance bodies also "reviewed the double materiality assessment conducted by the Company, with the support of external consultants".

BasicNet states that its bodies "constantly integrate impacts, risks and opportunities into their strategic decision-making processes" and are "aware of the potential trade-offs" involved, linking Group success to "the economic development of its network of licensees".

The approval chain sits under GOV-5 (page 74): data owners review the draft, the Committee performs "an in-depth analysis of the content", and the CSO presents it to the Board "for review and approval via a written resolution".

Sustainability in incentive schemes

Reference: page 70. The climate-specific cross-reference (ESRS 2 GOV-3 E1) is listed in the content index against the same page (Table 28, page 145).

A nil return. The disclosure is a single sentence covering both the general and the climate-specific requirement:

"At present, there are no incentive systems linked to ESG targets or climate-related targets allocated to BasicNet's administrative, management and supervisory bodies."

This is consistent with the rest of the statement. The Board section records that "no formal ESG objectives are currently in place" (page 68), and the Remuneration Policy is described under S1-1 purely in terms of attracting, retaining and motivating executive directors and senior executives, with no sustainability metric attached (page 119). BasicNet sets no climate targets at all (E1-2 and E1-4, page 105), so no climate performance measure exists to link to pay.

Due diligence

Reference: pages 70-73. Table 2 maps the five ESRS due diligence elements to the paragraphs covering each (pages 72-73).

The company discloses that its due diligence is not formalised: "BasicNet initiated a process of collecting and analysing information related to its due diligence practices, while acknowledging that this is not yet a formalised process" (page 70). Supply chain assessment happens "during the qualification stage, conducted on a voluntary basis through questionnaires", and those assessments "are not exclusively focused on sustainability matters, although they are taken into account within control procedures" (page 71).

Alignment with international frameworks is expressly denied:

"While inspired by international principles of corporate responsibility, the processes adopted across the value chain do not formally align with the Due Diligence models outlined by the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises" (page 71).

Table 2 anchors each element in existing machinery rather than a dedicated process: the Ethics Code, Code of Conduct for Sourcing Centres and whistleblowing procedure for element (a); the Control and Risks Committee and Internal Audit for governance; the customer service, counterfeiting and whistleblowing channels for identifying negative impacts; and an annual whistleblowing report to the Supervisory Board (pages 72-73).

Controls over sustainability reporting

Reference: pages 73-74.

The procedure dates from 2024: "In 2024, a Sustainability reporting and ESG governance reporting procedure was developed to define roles and responsibilities, establish specific procedures to ensure data collection, validation and reporting, and provide assurance that the main risks associated with the Sustainability Statement are covered by internal control activities." The Group adds that those processes "are based on previously non-formalised data collection, validation and reporting activities, also carried out for the 2025 Statement" (page 73).

The Executive Officer for Sustainability Reporting is responsible for the consolidation scope, planning, managing the double materiality process and identifying the disclosure requirements, involving data owners, verifying and validating data completeness and accuracy, preparing and reviewing the statement, and managing approval by the CEO, Committee and Board (page 73).

Risk assessment: "Risks linked to sustainability reporting are assessed within the Enterprise Risk Management activity and therefore follow the same methodology; the main risk factors identified include regulatory compliance, data accuracy and data completeness." These "were exacerbated following the introduction of the CSRD and ESRS Standards", mitigated by the new procedure and "specialist advisory support" (page 73).

Strategy, business model and value chain

Reference: pages 74-78; the revenue breakdown by ESRS sector is incorporated by reference to the Directors' Report (page 148).

Business: apparel, footwear and accessories, through Kappa, Robe di Kappa, K-Way, Superga, Briko, Jesus Jeans, Sabelt and Sebago; in 2025 the Group acquired Woolrich and Sundek (page 74). 1,771 employees at 31 December 2025 across 14 countries (Table 3, page 75). The network comprises "1,098 Kappa and Robe di Kappa monobrand and shop-in-shop stores, 104 Superga points of sale, 133 K-Way stores and 48 Sebago points of sale" (page 75).

The "networked" model (page 75): BasicNet supplies licensees with "an integrated service system" rather than product alone, on "a fully integrated IT platform". Manufacture "is entrusted to Sourcing Centres", which "are in fact third-party firms to the Group". Direct retail runs through plug@sell in Italy, Switzerland, Spain, France, England, Portugal and Ireland.

Value chain (pages 76-77): upstream covers raw material extraction and processing, production at Sourcing Centres and packaging; own operations the Business System, retail and design; downstream commercial licensees and end customers. The model covers the life cycle "excluding the use and end-of-life phases".

Results (page 78): revenues of Euro 415.8 million and EBITDA of Euro 29.3 million against Euro 61.1 million in 2024 (pro-forma Euro 54.1 million).

Stakeholders

Reference: pages 78-79, with the methodology note at page 81.

Mapping dates from 2022: "in 2022 BasicNet updated the mapping of its main stakeholders, conducting an analysis of its business and with the participation of Group management". The December 2025 brand acquisitions changed the reporting scope, "which will result in changes to the mapping process in 2026" (page 78).

Groups identified (page 78): Group Resources, investors, shareholders and the financial community, the public sector, governmental and control bodies, and local communities, plus Sourcing Centres and Licensees, treated as commercial partners.

Engagement methods (page 79): employees through training, onboarding follow-ups and the internal "BasicPress.com" press agency; the financial community through regular meetings and reports; suppliers and Sourcing Centres through quality initiatives; licensees through marketing and product strategies; customers through product feedback and loyalty initiatives; local communities through corporate responsibility projects and sports sponsorship. The Group participates in Federazione Manageritalia, the Turin chapter of ASCOM-Confcommercio and the Turin Industrial Union.

Limitation to note: the materiality assessment drew only on internal stakeholders. "For this reporting year, the double materiality assessment process did not involve external stakeholders" (page 81).

Material impacts, risks and opportunities

Reference: pages 80-92. The full list is Table 5 (pages 85-92); the summary is Table 4 (page 83).

Outcome: "Following updates to the double materiality assessment, 20 material impacts, nine risks and six opportunities were identified" (page 83). Table 4 distributes them as E1 4 / 3 / 2; E3 1 / 0 / 0; E5 3 / 0 / 0; S1 5 / 2 / 1; S2 3 / 2 / 1; S4 1 / 1 / 2; G1 3 / 1 / 0.

Topics excluded: "the topics of pollution (E2), biodiversity (E4) and local communities (S3) will not be reported by the Group, as the double materiality assessment did not deem them material for its business, value chain and business relationships" (page 83). Payment practices were also found immaterial "given the characteristics of the Group's supply chain and business".

Where the IROs sit: E3's single impact and all three E5 impacts are attributed to the value chain, while E1 carries two own-operations and two value chain impacts (pages 85-87).

Financial effects and resilience (page 84): "no current financial effects were recorded for the 2025 reporting year. In addition, BasicNet has not yet formalised a specific resilience plan to address material impacts, risks and opportunities, nor has it conducted a quantitative analysis of its capacity to adapt".

Change on 2024 (pages 83-84): impacts rose from 18 to 20, on a new E3 water impact, a new E1 upstream energy impact and an additional S2 workers' rights impact.

The double materiality process

Reference: pages 80-85.

History and scope: "Since 2024, BasicNet has adopted the double materiality principle." In 2024 impacts came from "a contextual analysis that resulted in the definition of a long list of 40 impacts, with an approach in which mitigation actions are not considered"; risks from "the Group's Risk Universe". In 2025 the process was revised, producing a long list of 47 impacts, and "reporting was expanded to include ESRS E3 - Water and marine resources" upstream (page 80).

No disaggregation: "it was not necessary to disaggregate the IROs, which are to be considered valid for the Group as a whole" (page 81). Engagement: internal stakeholders only (CSO, HR, Corporate Affairs, Internal Audit, Purchasing, Sourcing and Operations, Facility Manager, brands). "For this reporting year, the double materiality assessment process did not involve external stakeholders" (page 81).

Impact scoring (pages 81-82): scale, scope, irremediable character and likelihood on a 1 to 5 scale, severity being "the average of the scale, scope and irremediable character factors multiplied by the likelihood of occurrence". Human rights impacts prioritise "severity over likelihood".

Financial materiality (page 82) follows the ERM framework, using residual risk "except for an intrinsic approach for climate-related risks". Outcomes are approved annually by the CSO, go to the Committee for opinion, then to the Board (page 83).

ESRS content index

Reference: Table 28 "List of material DRs", pages 145-147, with Table 29 (disclosure requirements included by reference) at page 148 and Table 30 (datapoints derived from other EU legislation) at pages 150-157.

What the index lists. ESRS 2 in full (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2); for E1 the topical SBM-3 and IRO-1, GOV-3, E1-1 to E1-6 and E1-9; for E3 the topical IRO-1 and E3-1 to E3-5; for E5 the topical IRO-1 and E5-1 to E5-6; for S1 the topical SBM-3, S1-1 to S1-9 and S1-13 to S1-17; for S2 SBM-3 and S2-1 to S2-5; for S4 the topical SBM row and S4-1 to S4-5; for G1 GOV-1, IRO-1 and G1-1 to G1-4.

What it does not list. E1-7, E1-8, S1-10, S1-11, S1-12, G1-5 and G1-6 appear nowhere in the index, and E2, E4 and S3 are absent entirely, matching the materiality outcome at page 83.

Rows carrying a reason instead of a page. Four state "The Group has chosen to apply the phase-in option" (E1-9, E3-5, E5-6, S1-15). Three state that "The topic is considered material only in relation to the value chain and, consequently, its metrics are disclosed only qualitatively" (E3-4, E5-4, E5-5).

Caution. The index's page references run one page lower than the headings they point to (GOV-1 at 66 where the heading is at 67, S1-1 at 118 where it is at 119), so references here are taken from the body.

Transition plan

Reference: page 105 (index row at page 145).

BasicNet discloses that it has no transition plan. The disclosure is explicit:

"Based on the above, BasicNet has not adopted a transition plan for the current year. Any decarbonisation initiatives that the Group decides to adopt in future years, to achieve the objectives defined in Article 4 of Legislative Decree No. 125/2024, will be appropriately included in a transition plan consistent with what has been approved by the governance bodies and with what will be defined in the Group's strategic plan."

What is offered in its place is a statement of principle drawn from the Ethics Code: respect for the environment "is primarily consolidated in dutiful and scrupulous compliance with environmental regulations", together with a commitment to "adopting responsible environmental-protection behaviours, avoiding harmful conduct and promoting the responsible management of the energy resources used". Sourcing Centres are "required and obliged - by signing Sourcing Agreements - to comply with all environmental laws and regulations, as well as maintaining procedures to notify the local Authorities in a timely manner of any environmental incidents" (page 105).

No GHG reduction target, decarbonisation lever set, capital allocation, locked-in emissions assessment or Paris alignment statement is disclosed. The EU Taxonomy tables report 0% aligned turnover, CapEx and OpEx (pages 98-103).

Climate risk identification

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA section (pages 80-84, 104). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No scenario analysis was performed. "BasicNet did not conduct a resilience analysis on the identified physical and transition risks including a scenario analysis. Therefore, although no formal analysis of climate-related scenarios was conducted, the identification and assessment of physical and transition risks were based on analysis of international institutional sources, the regulatory framework, and BasicNet's internal expertise and knowledge" (page 104).

Risks are classified physical or transition (page 104): one physical risk, long term, "Potential business interruption due to accidents (e.g. fires) or extreme weather events (e.g. floods) that damage sourcing centre facilities, production sites or distribution centres of its suppliers"; and two transition risks, also long term, covering products containing materials "incompatible with environmental regulations" and "increased operating costs... to meet government and/or market requirements".

Methodology is thin but covers own operations and value chain: the assessment addressed risks "relevant to BasicNet's direct operations and its value chain (upstream, direct operations, and downstream)". The Group names no scenario. Because none was used, the scenario datapoints do not apply.

Climate resilience

Back-filled from ESRS 2 SBM-3 and the E1 climate DMA section (pages 84 and 104). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No resilience analysis was carried out, and the company says so:

"BasicNet has not yet formalised a specific resilience plan to address material impacts, risks and opportunities, nor has it conducted a quantitative analysis of its capacity to adapt" (page 84).

"BasicNet did not conduct a resilience analysis on the identified physical and transition risks including a scenario analysis" (page 104).

What is offered instead is a qualitative argument that the business model absorbs climate risk: "Climate risks are mitigated by BasicNet's business model itself. It employs a 'network' business model, where BasicNet does not act as a supplier of the product itself, but as a provider of an integrated set of services", an extensive sourcing network reducing concentration risk (page 104).

Named mechanisms: strategic products must be made by "at least two or three Sourcing Centres (if possible in different regions)"; "after five years, orders are transferred to a new Sourcing Centre"; and "no factory devotes more than half of its production capacity to Group-branded products".

No areas of uncertainty and no assessment of capacity to adjust financial resources or redeploy assets are given. Table 29 incorporates "SBM-3, par. 19 a, b, c" by reference (page 148).

Climate policies

Reference: page 105 (index row at page 145).

A nil return, disclosed as such:

"[ESRS 2 par. 62; 72] In addition, BasicNet currently has no specific policies in place to manage material impacts, risks and opportunities related to climate change mitigation, adaptation to it, or energy resource management, nor has it formalised targets to do so."

The stated reason, recorded verbatim: "The decision not to implement these policies and targets is due to the changing nature of the environment and business in which the Group operates and the need to progressively align with international standards and regulations. The Group adapts as it goes along to the current regulations and does not set additional targets, believing that alignment with the targets is sufficient" (page 105).

The only climate-relevant commitments cited are general: the Ethics Code's requirement of "dutiful and scrupulous compliance with environmental regulations" and a commitment to "promoting the responsible management of the energy resources used"; and the Code of Conduct obligation on Sourcing Centres to comply with environmental law and notify authorities of environmental incidents (page 105). Neither is presented as a climate policy under ESRS E1-2, and neither carries a scope, owner or monitoring arrangement.

Climate actions and resources

Reference: pages 105-106.

Three energy-efficiency initiatives are disclosed, two of them pre-dating the reporting year:

• "the automated management of the lighting system at BasicVillage's offices"
• "the implementation of software for managing the thermofluid system at the BasicVillage and BasicItalia's offices", permitting "optimal management and regulation of summer and winter office temperatures according to the type of premises, thus allowing for a theoretical reduction in energy consumption"

The Group states that "The implementation of both of these initiatives was completed before 2024 but they have continued to be used since, including during the reporting year" (page 105).

The one quantified 2025 item: "the replacement of neon lighting with LED lamps at the BasicItalia site (warehouse and offices) remained unchanged compared with 2024, stabilising at approximately 70% LED lighting, with an estimated reduction in emissions of 1.46 tCO2 /per year" (page 106). The footnote sets out the estimate: average neon consumption against current LED consumption from a 2023 base year, assuming 10 hours a day for 253 days, giving "an estimated reduction in consumption of approximately 5 MWh/year"; on the market-based method the reduction is 2.3 tCO2.

No resources are quantified: no CapEx or OpEx figure is attached to any climate action, there is no forward action plan, and no adaptation action is described.

Climate targets

Reference: page 105 (index row at page 145).

BasicNet sets no climate targets. E1-4 is disclosed in the same paragraph as E1-2, and the statement is a nil return:

"BasicNet currently has no specific policies in place to manage material impacts, risks and opportunities related to climate change mitigation, adaptation to it, or energy resource management, nor has it formalised targets to do so" (page 105).

The reason is recorded as "the changing nature of the environment and business in which the Group operates and the need to progressively align with international standards and regulations", with the Group concluding that "alignment with the targets is sufficient" (page 105).

Corroborating disclosures: there is no transition plan (E1-1, page 105); "At present, there are no incentive systems linked to ESG targets or climate-related targets" (GOV-3, page 70); and the Board section notes that "no formal ESG objectives are currently in place" (page 68). No base year, no 2030 or 2050 milestone, no gross or net target, no sectoral decarbonisation pathway and no science-based target validation are disclosed. The only quantified climate figure in the E1 chapter that looks forward is the estimated 1.46 tCO2 per year saving from LED replacement (E1-3, page 106), which is an outcome estimate rather than a target.

Energy consumption and mix

Reference: pages 106-107. The reconciliation of net revenues from high climate impact sectors is incorporated by reference within the same section (page 148).

Sources (page 106): all stores and locations buy grid electricity; natural gas heats BasicVillage Turin and Milan, the KWAY France office and some retail outlets; petrol and diesel fuel the vehicle fleet. A photovoltaic system installed at BasicVillage Milan in 2023 fed its output into the grid, with "only a residual and insignificant part" used on site.

Table 9, energy consumption and mix (MWh), 2025 against 2024:

• Total energy consumption 9,941 (9,530)
• Total from fossil sources 9,252, a 93.06% share (9,063 / 95.10%)
• Crude oil and petroleum products 1,843 (1,991); natural gas 2,825 (2,619); purchased fossil electricity, heat, steam and cooling 4,584 (4,453)
• Nuclear 598, a 6.02% share (467 / 4.90%)
• Total renewable 92, a 0.92% share (0 / 0%), of which 82 MWh is renewable fuel including biomass

High climate impact sectors (page 107): G wholesale and retail trade, H transport and storage, L real estate. Energy intensity is 0.023 MWh per Euro thousand of related revenue (0.022 in 2024), on net revenue from those sectors of Euro 398,167 thousand (394,892) against total net revenue of Euro 414,713 thousand (Table 11). Estimates were used for nuclear-source and US consumption, BasicVillage Milano on a floor-area basis, and BasicAir fuel (page 67).

GHG emissions

Reference: pages 107-112; methodology in Table 14 (pages 109-112).

Scope 3 entered the inventory this year. "In 2025, BasicNet incorporated the indirect emissions identified by the GHG Protocol along the value chain (Scope 3)". Ten of fifteen categories were material; category 3.5, waste generated in operations, "was considered as not material and therefore excluded". Scope 3 "account for 98% of the total emissions" (page 107).

Emissions (tCO2e), 2025 against 2024:

• Scope 1: 964 (976); 0% from emission trading schemes
• Scope 2: 1,315 location-based (1,952); 2,068 market-based (2,272)
• Scope 3: 96,336 (87,509), dominated by cat 1 purchased goods and services at 80,413 (73,921); then cat 4 upstream transport 6,693 (3,694); cat 7 commuting 2,139; cat 2 capital goods 1,954; cat 12 end-of-life 1,543; cat 6 business travel 1,343; cat 15 investments 1,172; cat 3 fuel and energy 515; cat 14 franchises 370; cat 13 leased assets 193. Cat 5 is shown as "n.d."
• Total: 98,614 location-based (90,437); 99,368 market-based (90,757)

Intensity (page 108): 0.238 tCO2e per Euro of net revenue location-based (0.222) and 0.2404 market-based (0.223). Total emissions and intensity both rose.

Method: cats 1, 2, 6, 12 and 15 use spend-based factors (Eurostat EEIO 2022); DEFRA/BEIS 2025 for energy and transport; AIB, EPA and Terna for Scope 2. EY flags Scope 3 as "subject to greater intrinsic limitations compared to Scope 1 and 2".

Water policies

Reference: page 113 (index row at page 145).

A nil return on policies, stated directly:

"BasicNet has not adopted specific policies to manage material impacts related to water and marine resources along its value chain, neither with regard to areas at water risk nor to areas of high water stress."

The stated reason, recorded verbatim: "This decision, which is in line with the Group's approach to the climate change topic, is equally motivated by the dynamic nature of BasicNet's business and the need to quickly align with the relevant regulatory environment" (page 113).

E3 entered the Group's reporting only this year: "compared with 2024, reporting was expanded to include ESRS E3 - Water and marine resources, in relation to the Group's upstream activities" (page 80), and the single material IRO is an actual negative impact sitting upstream, "High levels of water withdrawal and consumption in textile processes require significant quantities of water and contribute to water use, with impacts on the environment and local communities" (page 113).

The one water-related commitment disclosed is brand-level rather than a Group policy: Sebago "is committed to promoting and strengthening collaboration with LWG (Leather Working Group)-certified tanneries", with "particular attention to reducing water consumption, improving wastewater treatment and protecting local ecosystems" (page 113).

Water actions and resources

Reference: page 113 (index row at page 145).

No Group-level actions are defined. The disclosure is combined with E3-1 and E3-3:

"In addition, for the same reasons, BasicNet has not defined Group-level targets or actions in this regard along its value chain. Nevertheless, the Group is actively committed to developing products designed to reduce water consumption and withdrawal and to prevent waste, in full compliance with applicable regulations" (page 113).

The single named initiative is brand-level. Sebago "is committed to promoting and strengthening collaboration with LWG (Leather Working Group)-certified tanneries to produce natural leather goods, promoting more sustainable and responsible management of water resources and chemicals throughout the production chain. This collaboration seeks to encourage the adoption of innovative practices and high environmental sustainability standards, paying particular attention to reducing water consumption, improving wastewater treatment and protecting local ecosystems, thereby contributing to a more responsible and informed use of this critical resource" (page 113).

No resources are quantified: no CapEx or OpEx figure, no time horizon and no supplier coverage are given for the LWG collaboration, and no water action in the Group's own operations is described. The Code of Conduct obligation on Sourcing Centres to notify authorities of environmental incidents is cited as context (page 114).

Water targets

Reference: page 113 (index row at page 146).

No water targets are set. E3-3 is disclosed in the same paragraph as E3-1 and E3-2:

"In addition, for the same reasons, BasicNet has not defined Group-level targets or actions in this regard along its value chain" (page 113).

The reason given is the one applied across the environmental standards: "the dynamic nature of BasicNet's business and the need to quickly align with the relevant regulatory environment", described as "in line with the Group's approach to the climate change topic" (page 113). The Group repeats the same formula for E5 targets (page 115), S1 targets (page 124), S2 targets (page 135) and S4 targets (page 139), and states more generally that "the Group does not have formal, specific targets related to significant product groups, customer categories or geographical areas" (page 78).

No threshold, base year, target year, water-intensity objective or supplier commitment is disclosed. The Group does state a direction of travel without attaching a measure to it, being "actively committed to developing products designed to reduce water consumption and withdrawal and to prevent waste, in full compliance with applicable regulations" (page 113), and points to the Sebago LWG tannery collaboration as the practical expression of it.

Water consumption

Reference: pages 113-114. The index row carries no page, reading instead: "The topic is considered material only in relation to the value chain and, consequently, its metrics are disclosed only qualitatively" (page 146).

No volumes are reported, and the company explains why: "BasicNet does not have direct data on the volumes of water consumed, recycled or stored, but monitors and assesses water-related impacts qualitatively along its supply chain" (page 113). BP-1 records that "The value chain-related metrics for ESRS E3 and ESRS E5 will be integrated over the next three years, as stipulated in ESRS 1 Section '10.2 Transitional provision related to chapter 5 Value Chain'" (page 66).

What is disclosed instead is a qualitative water-risk screening (pages 113-114):

• External sector context: the fashion industry "consumes approximately 1.5 trillion litres of water each year and is responsible for around 20% of global freshwater pollution"; "approximately 85% of the water consumption associated with textiles consumed in Europe occurs outside the continent, primarily in Asia"
• A supplier screening run this year: the "main suppliers were analysed using the Aqueduct tool... developed by the World Resources Institute (WRI)", showing water risk "generally corresponding to medium-high and high-risk areas"
• South and East Asia production sites "fall within river basins marked by high water stress"

No own-operations water figure is given.

Circular economy policies

Reference: page 115 (index row at page 146).

A nil return, disclosed in terms that track the ESRS datapoints:

"BasicNet does not have specific policies in place to manage the material impacts related to resource use and the circular economy, nor with regard to the phasing out of virgin resources or the sustainable sourcing of renewable resources, nor has it set formal targets to address impacts in these areas."

The stated reason, recorded verbatim: "This decision, which is in line with the Group's approach to the topics of climate change and marine resources, is equally motivated by the dynamic nature of BasicNet's business and the need to quickly align with the relevant regulatory environment" (page 115).

What the Group offers instead of a policy is activity: it "is actively engaged through its brands in the adoption of sustainability-oriented solutions, promoting the use of more sustainable, recycled and recyclable materials, and applying the principles of circular economy in concrete terms" (page 115). Those initiatives are set out under E5-2.

The three material E5 impacts all sit upstream: resource depletion from cotton and synthetic fibre use, inefficient use of recycled or recyclable materials and non-biodegradable packaging, and improper management of production waste and unsold stock (page 114).

Circular economy actions

Reference: pages 115-116. "The resources allocated to these initiatives were not material in terms of the Group's total CapEx and OpEx" (page 115).

Seven named actions:

• Tags and polybags: all brand tags made "exclusively of FSC-certified paper", polybags "made of 100% recycled and recyclable material", and a K-Way "zip closure system to make its plastic bags reusable"
• QR code labelling added "to all labels and packaging, providing clear and up-to-date information for the proper disposal of materials", across all brands
• Recycled materials at K-Way: recycled fabrics and padding in the Heavy Warm, Marmot Twill, Marmot Soft Touch and SKI collections, plus recycled nylon in three others
• K-Way and Coral Gardeners: protective clothing from recycled materials supporting coral reef regeneration in French Polynesia; the partnership "will run for three years, from 2024 to 2026, and involves an outlay (OpEx) of Euro 73,931"
• Sebago resoling service with Alvisi Milano, letting customers "resole their shoes with original Sebago soles"
• Briko UpCycling Programme, launched in 2025, collecting used bike helmets against a contribution towards a new one, recycled through Esosport "into secondary raw materials"
• Packaging: all brands "have stopped using traditional glossy plastic films on boxes, replacing them with direct printing on cardboard"

Euro 73,931 is the only monetary figure attached to any E5 action.

Circular economy targets

Reference: page 115 (index row at page 146).

No targets are set. E5-3 is disclosed in the same paragraph as E5-1:

"BasicNet does not have specific policies in place to manage the material impacts related to resource use and the circular economy... nor has it set formal targets to address impacts in these areas." And: "Furthermore, for the same reasons, BasicNet has not defined specific objectives in this context" (page 115).

The reason given is the one repeated across the Group's environmental and social chapters: "the dynamic nature of BasicNet's business and the need to quickly align with the relevant regulatory environment", described as "in line with the Group's approach to the topics of climate change and marine resources" (page 115).

No recycled-content target, virgin-material phase-out target, packaging target, waste-diversion target or reuse target is disclosed, and no base year or target year appears anywhere in the E5 chapter. The closest the statement comes to a forward commitment is qualitative: BasicNet "will continue to explore innovative solutions to further improve the use of sustainable materials in its processes" and "will continue to develop new solutions to further expand the use of low-impact materials" (page 115).

Resource inflows

Reference: page 116. The index row carries no page, reading instead that the topic "is considered material only in relation to the value chain and, consequently, its metrics are disclosed only qualitatively" (page 146).

No tonnages are reported, and the reason is structural: "BasicNet does not directly manage the manufacture of its products, but relies on Sourcing Centres, which are responsible for the procurement and use of material resources, plants and machinery" (page 116). BP-1 records that E3 and E5 value chain metrics "will be integrated over the next three years, as stipulated in ESRS 1 Section '10.2 Transitional provision related to chapter 5 Value Chain'" (page 66).

What is disclosed is a qualitative inventory of materials used by Sourcing Centres (page 116):

• Clothing: "natural textile fibres, such as cotton and linen, and synthetic fibres, including polyester, spandex, and nylon"
• Footwear: "leather, rubber, and advanced polymers such as TPU (thermoplastic polyurethane) and EVA (ethylene vinyl acetate)"
• Sports equipment: "polycarbonate and fiberglass for helmets"
• Packaging: "recycled cardboard boxes, paper shopping bags and plastic bags"

No weight or volume of inflows, no biological-versus-technical split and no percentage of secondary reused or recycled components are given. R&D is said to focus "on finding environmentally friendly materials and reducing environmental impact in manufacturing", unquantified.

Resource outflows

Reference: page 116. The index row carries no page, reading instead: "The topic is considered material only in relation to the value chain and, consequently, its metrics are disclosed only qualitatively" (page 146).

The disclosure is qualitative and short. On products and materials, the Group states that "The goal is to constantly improve the production process and the related supply chain", that "the Group has always paid the utmost attention to LEP (Labelling, External decoration, Packaging), which is considered a distinctive element of the product", and that "BasicNet continued to assess the possibility of using pre-recycled/recyclable materials for pendants and boxes at its main sourcing centres, in line with the relative certifications" (page 116).

On product design it adds that it "has always focused on offering the best possible product to the Licensee Network, always prioritising the research of products with a targeted and certified content" (page 116).

What is missing and why. No rates of recyclable content, recycled content or durability are reported. The Group relies on the ESRS 1 value chain transitional provision, with BP-1 confirming that E5 value chain metrics "will be integrated over the next three years" (page 66). The related potential impact concerns "the inefficient use of recycled or recyclable materials" and "unnecessary and non-biodegradable packaging" upstream (page 114).

Waste

Reference: page 117, within the E5-5 resource outflows disclosure.

No waste tonnages are reported, and the company explains both the basis and the timetable:

"Having no production activities in-house, BasicNet's own activities generate waste attributable to typical office operations, in an amount considered non-material compared to waste generated by upstream production activities, by the Sourcing Centres. Recognising the importance of the topic, a more in-depth analysis of this issue will be implemented over the next three years... so as to provide precise reporting accompanied by quantitative data" (page 117).

What is given is a qualitative characterisation of Sourcing Centre waste streams (page 117):

• Material waste: "scraps of fabric, leather, rubber and other materials"
• Chemical waste: "residues of dyes and finishes, as well as substances used for cleaning equipment and machinery"
• Packaging waste: "cardboard boxes, plastics and polystyrene"

The impact behind this is actual and material in the short term: "Improper management of waste and scrap (both hazardous and non-hazardous) during production processes, in addition to unsold and non-recyclable materials at the sales stage, generates significant negative environmental impacts" (page 114). GHG Protocol category 3.5 was also "considered as not material and therefore excluded" (page 107).

No total weight, hazardous split, recycling diversion or disposal figure is disclosed.

Own workforce policies

Reference: pages 119-120. The human trafficking, forced and child labour datapoint is incorporated by reference to the same section (page 148).

Three policies are named (page 119):

• Ethics Code, covering health and safety, workers' rights, equal opportunities and professional growth, applying to board members, all Group human resources, contractors, consultants and suppliers, supervised by the Supervisory Board
• Whistleblowing procedure, guaranteeing confidentiality and protection from retaliation, handled by Group Internal Audit
• Remuneration Policy, applying to directors and senior executives

Three gaps the company discloses itself (page 120):

• "BasicNet has not yet adopted specific policies on human rights, human trafficking, forced labour and child labour regarding its own workforce", on the basis that its operations and sites "do not present material risks in this regard"
• "the topics of discrimination and harassment are not addressed by specific policies dedicated to the workforce", the Ethics Code being relied on instead, showing "an implicit - if not formalised - attention"
• "the company recognises the importance of the United Nations Guiding Principles on Business and Human Rights, but its policies related to its own workforce are not fully aligned with these international instruments"

Health and safety is monitored by the ".com" BasicGuys, which "tracks all accidents and injuries" (page 120).

Engaging own workers

Reference: pages 120-121.

Positive impacts are handled informally. "employees are involved in various ways, such as through training programs, regular performance reviews, onboarding and related follow-up activities", complemented by "the informal engagement channel represented by the functions pertaining to Human Resources, the first listening channel for issues raised by employees" (page 120).

Health and safety is handled formally. "In contrast, a more structured approach is followed regarding the potential negative impact of work-related injuries." Annual meetings under Article 35 of Decree No. 81/2008 bring together company representatives and employee health and safety representatives (EHSR), formalised by the ".com" BasicFacility and BasicGuys with reports shared with relevant parties. Participants named are the employer for each Group company, the external Health and Safety Manager, Health and Safety Officers, the Company Doctor, the EHSRs and Human Resources (pages 120-121).

Work-related stress is assessed biannually with the employer, Health and Safety Manager, company doctor, managers, EHSRs and Trade Union Representative Bodies, via "the completion of a checklist aimed at identifying any critical issues related to work organisation and the environmental and relational context", after which "the Group implements corrective actions" (page 121).

No global framework agreement is disclosed.

Remediation and grievance channels

Reference: page 121.

The channel is the whistleblowing system, and it is not workforce-specific. Employees may report "either directly to their supervisor or through the whistleblowing mechanism". The dedicated system is the "Legality Whistleblowing" portal, which "allows alerts to be sent in written or oral form, with the option of recording an audio message with voice distortion"; reports may also go by post or in a face-to-face meeting. Workers are made aware through the website, the intranet and onboarding.

A limitation the company states itself: "The whistleblowing channel is public and open to all... while there are no additional formalised channels dedicated only to the workforce to raise critical issues and concerns anonymously."

Protections (page 121): data minimisation "by design" applies; the reporter's identity "may not be disclosed, without his or her explicit consent, to persons other than the person receiving the report"; where it is essential to an accused person's defence it may be disclosed only with written consent. Anyone suffering retaliation may report it to the person handling reports.

Process and timing: the receiving party acknowledges receipt and conducts a preliminary verification; assessment sits with Group Internal Audit "which performs them with priority over routine activities"; feedback is given "within three months", with a final report under Decree No. 24/2023.

Actions on own workforce

Reference: pages 122-124.

Health and safety (the actual negative impact). Management sits with BasicFacility "which coordinates activities with the support of an external consultant (Group Torinoprogetti S.r.l.)", and "Each year, BasicFacility prepares a budget dedicated to safety." All injuries are "recorded, analysed and discussed" at the Article 35 meeting. Training is planned by the ".com" BasicEducation, and "in 2025 BasicNet made an outlay (OpEx) of Euro 17,488 for this action" (page 122).

Welfare and work-life balance (positive impacts and the opportunity), page 123. Initiatives in place since 2004 include an "Hour bank, which allows flexible management of overtime"; "Reversible part-time, available for female workers with young children"; BasicCare; BasicGym; a Sports voucher, outlay "Euro 504.637"; "pink parking spaces" for pregnant workers; and a Psychological Listening Desk, outlay "Euro 711.66". A supplementary non-work accident policy carries Euro 272,567.

Risks (page 123). Violation of workers' rights is managed through the BasicGuys platform. Inefficient training is managed through BasicEducation, beginning with the four-day "Welcome on Board" induction and a six-month follow-up, effectiveness "monitored by analysing the training hours used, the number of staff involved and the feedback".

Two welfare outlays are printed with Italian-style decimal separators and should be checked against the source.

Own workforce targets

Reference: page 124 (index row at page 146).

No workforce targets are set, and the company explains why:

"Due to the dynamic nature of BasicNet's business and the consequent need to rapidly align with relevant regulatory developments, BasicNet has not yet defined specific targets related to material impacts, risks, and opportunities connected to its workforce. As noted above, however, it oversees and monitors the most material topics with an established approach that is well integrated into its operations."

On diversity and anti-discrimination specifically, the Group states that "the provisions of current legislation, the Ethics Code and the procedure for reporting alleged wrongdoing and irregularities (Whistleblowing) provide adequate safeguards that counter discrimination, including harassment, and promote equal opportunities and other solutions in support of diversity and inclusion. As such, it did not identify the need to set targets beyond compliance with external and internal Group regulations" (page 124).

No injury-rate target, gender-balance target, training target or turnover target is disclosed, and no workforce metric is tied to an incentive scheme (GOV-3, page 70). The same formulation is used for S2-5 (page 135) and S4-5 (page 139).

Employee characteristics

Reference: pages 124-126. S1-6 is also listed among the disclosures included by reference (page 148).

Headcount. "As at December 31, 2025, the Group had 1,771 employees... an increase of 58% over 2024 due to an expansion of the reporting scope", driven by "the consolidation of the Group's international presence and the opening of new directly operated stores" in France and Spain (page 124). All figures are headcount.

Gender (Table 15, page 125). 662 male and 1,109 female; women are 62.6% of total employees. "None of the Group's employees and non-employees identify themselves with genders other than male and female."

Contract type (Table 17, page 125). Permanent 1,343 (502 male, 841 female); fixed-term 424; non-guaranteed hours 4. The narrative at page 124 calls 1,343 fixed-term, contradicting the table heading; the table is used here.

Country (Table 16, page 125). Italy 1,199; France 314; Spain 91; Germany 70; UK 18; Switzerland 17; Netherlands 15; China 9; Austria 9; Vietnam 8; Portugal 8; USA 7; Ireland 6; Monaco 0. Germany, Austria, the Netherlands, Portugal and the UK are new in 2025.

Turnover (Table 19, page 126). 420 departures against 368 in 2024; turnover rate 24% (33% in 2024), 27% for men and 22% for women.

The SBM-3 section states the Group "employs 1,728 workers" alongside a workforce of 1,771 and 44 non-employees (page 118), which does not reconcile with 1,771 employees here.

Non-employee workers

Reference: page 126, with Table 20 at page 127 (index row at page 146).

"At December 31, 2025, the Group had 44 non-employee workers." All data are headcount at that date.

Breakdown (Table 20, page 127), 2025 against 2024:

• Interns 27 (18 in 2024), of whom 9 male and 18 female
• Temporary staff, described as staff leasing, 16 (4), of whom 4 male and 12 female
• Other 1 (0)
• Total 44 (22), of whom 14 male and 30 female

Where they work. The figure "reflects, in addition to new acquisitions, the continuity of the activities for which they are employed, with temporary workers predominantly active in the logistics area and in temporary corners within shopping centres, whereas interns are placed consistently with the company's strategy of using this tool as an entry mode for staff with no experience in the assigned role" (page 126). The SBM-3 section puts the same population at "16 temporary workers - working mainly in the logistics and retail areas - and 27 interns" (page 118), which accounts for 43 of the 44.

Self-employed workers and workers provided by employment agencies are not reported as separate categories, and no methodology note accompanies the figure. The Group states that in both categories of own workers "there are no groups with specific characteristics that are more exposed to the potential negative impacts identified" (page 119).

Collective bargaining and social dialogue

Reference: page 127, with Table 21 on the same page.

Coverage. "The total percentage of employees covered by collective bargaining agreements is 91% of the Group's workforce (EEA and non-EEA). As for the EEA countries where the Group has a significant level of employment, i.e. a headcount of at least 50 employees, representing at least 10% of the total, 100% are covered."

Social dialogue. "the overall percentage of employees covered by employee representatives in EEA countries where the Group has a significant level of employment is 60% for Italy (71% in 2024) and 24% for France (31% in 2024)." Both rates fell. Table 21 puts Italy and France in the 80-100% band for bargaining coverage, Italy in the 40-59% band and France in the 20-39% band for representation.

Agreements named (page 127). In Italy the Tertiary Distribution and Services Contract applies "to the majority of the company population, with some exceptions". At Kappa France and K-Way France the "Convention collective nationale de l'import-export et du commerce international" and the "Commerce de gros et négoces connexes de bonneterie lingerie confection" apply.

Freedom of association. "In Italy and France, all workers are covered by a collective bargaining agreement, although only a small proportion choose to join national trade union organisations." The Group guarantees that right "without interference or retaliation".

Diversity metrics

Reference: page 128 (index row at page 147).

Top management by gender (Table 22, page 128), 2025 against 2024:

• Top Management (Executives) 43 in total, of whom 31 male and 12 female (31 in total in 2024, 23 male and 8 female)
• Shares: 72% male and 28% female (74% and 26% in 2024)

The Group notes that "Compared to the previous year, the composition of the Top Management category increased by two percentage points in favour of women" (page 128).

Age distribution (Table 23, page 128), 2025 against 2024:

• Under 30: 624 employees, 35% (391, 35%)
• 30 to 50: 901, 51% (563, 50%)
• Over 50: 246, 14% (167, 15%)
• Total 1,771 (1,121)

"the 30-50 age group continues to represent the majority of the company population" (page 128).

The framing is the Ethics Code: "the Group considers it essential to handle labour relations in a way that assures equality of opportunities and encourages everyone's professional development". Read against S1-16, the male-dominated top management is the stated driver of the Group's 22% gender pay gap, "primarily reflecting the higher salary received by the Group's male component owing to the positions held" (page 128). No diversity target accompanies these metrics (S1-5, page 124).

Training and skills development

Reference: pages 129-130 (index row at page 146).

Volume. "In 2025, the Group provided approximately 11,000 hours of training to its employees", covering health and safety, compliance, business model and "training aimed at upskilling and reskilling (particularly through the use of the Fondimpresa Interprofessional Fund): improvement of digital skills... relational skills... time management; sustainability" (page 129).

Average hours per employee (Table 25, page 130), 2025 against 2024:

• Male: 511 employees, 3,537 hours, 6.92 average (440 employees, 2,559 hours, 5.82)
• Female: 804 employees, 7,522 hours, 9.36 average (681 employees, 6,719 hours, 9.87)

Performance and career development reviews (Table 24, page 129), 2025 against 2024:

• Male: 19% reviewed (28% in 2024)
• Female: 89 of 804 reviewed, 11% (114 of 681, 17%)

Both review rates fell year on year. The count of male employees reviewed is rendered ambiguously in the extracted text and is not reproduced here; the percentage is.

Scope caveat, stated by the company: "The total number of employees reported in tables 24 and 25 does not correspond to the figure reported in S1-6, as the scope used for the denominator has been aligned with the scope for the numerator... thereby including the entire Group, excluding recent acquisitions (Woolrich, Sundek and Sebago France)" (page 129). Training "is only carried out in some Group countries".

Health and safety metrics

Reference: pages 130-131.

Headline. "In 2025, a total of eight work-related injuries occurred among Group employees - none of which resulted in death - and there were no recordable cases of work-related ill health".

No certified management system. "Currently, BasicNet does not have a certified health and safety management system", and the footnote is explicit: "Since no Group location is covered by a certified OSH management system, it follows that 0% of Group employees are covered by OSH management systems" (page 130). The Group relies instead on "compliance with applicable national regulations and the adoption of preventive measures".

Table 26, work-related injuries (page 131), 2025 against 2024, employees (non-employees all nil):

• Fatalities from injuries or ill health: 0 (0)
• Recordable work-related injuries: 8 (8)
• Rate of recordable work-related injury: 4.15 (4.32)
• Recordable cases of work-related ill health: 0 (0)
• Days lost due to work-related injuries: 523 (79)

Injury numbers were flat while days lost rose from 79 to 523, which the statement does not explain.

Method caveat. The rate "is calculated as the number of injuries, divided by the hours worked and multiplied by 1,000,000... Hours worked are recorded for employees in the Italy scope only. Those hours were added to an estimated figure for the foreign scope" (page 131). Hours worked abroad are flagged as an estimate (page 67).

Remuneration metrics

Reference: page 128.

Gender pay gap: 22% for 2025, up from 17% in 2024. The Group attributes it to seniority structure rather than discrimination: the workforce "is characterised by a majority presence of women compared to men, a figure that is reversed, however, in the representation of top management, which is male-dominated. This is also reflected in the gender pay gap, which stands at 22% for 2025 (17% in 2024)... and in no way reflecting gender pay discrimination."

The footnote gives the method: "(average male wage - average female wage) / average male wage, and is expressed as a % of average male wage".

Total annual remuneration ratio: 123.33 for 2025, against 52.74 for 2024. The Group explains the jump: "This increase can primarily be attributed to the payment of remuneration and bonuses to certain strategic individuals who have made a significant contribution to the brand's growth." The method is "dividing the total annual salary of the person with the highest salary by the annual total remuneration for all employees (excluding the highest-paid individual)".

Basis. "The average payroll was calculated considering all employees at December 31, 2025, including all actual pay components, such as base salary and variable elements, including bonuses, travel allowances and overtime."

Both metrics moved against the company year on year, and no pay-gap target is set (page 124).

Incidents and complaints

Reference: pages 128-129.

A nil return:

"During the reporting year, there were no reported incidents of discrimination or human rights violations; consequently, there were no sanctions or compensation for related damages" (page 129).

This covers both limbs of the requirement in one sentence: no incidents, and therefore no fines, penalties or compensation for damages.

Context. The reporting route is the whistleblowing system described under S1-3, with feedback to the reporter within three months under Legislative Decree No. 24/2023; the Group notes there are "no additional formalised channels dedicated only to the workforce to raise critical issues and concerns anonymously" (page 121). Reports are assessed by Group Internal Audit and, for matters under the 231 Model, by the Supervisory Board, which "reports its findings periodically to the Board of Directors and other corporate control bodies" (page 143).

The nil return should be read against the policy position disclosed at S1-1: "the topics of discrimination and harassment are not addressed by specific policies dedicated to the workforce", the Ethics Code being relied on instead (page 120). No separate figure for severe human rights incidents, and no breakdown of complaints received through the channel, is given. For the value chain, "During the year, no cases of human rights violations involving workers in BasicNet's value chain were reported" (page 133).

Value chain worker policies

Reference: pages 132-133. The S2-1 paragraph 16 datapoint is incorporated by reference to this section (page 148).

Three instruments are cited: the Ethics Code and the whistleblowing procedure, both described under S1-1, and the Code of Conduct for Sourcing Centres, which is the value chain specific one.

Code of Conduct for Sourcing Centres (pages 132-133):

• It "defines the minimum requirements to be met by all Sourcing Centres appointed by the BasicNet Group" and "regulates key aspects such as child labour, involuntary labour, discrimination, health and safety, working hours and freedom of association"
• Scope: it "applies to all Group Sourcing Centres, without exception, and is managed by the Vice President Sourcing and Operations"
• Standards: it draws "from the core conventions of the International Labour Organization (ILO) and the Universal Declaration of Human Rights"
• Communication: workers must be informed "by displaying a copy of it, translated into the local language, in a conspicuous place within production facilities"

A gap the company names itself: "Human trafficking is not explicitly touched upon in the document, but it is understood to be included in the topic of forced labour" (page 132).

Outcome for the year: "During the year, no cases of human rights violations involving workers in BasicNet's value chain were reported - through the whistleblowing channel or other channels" (page 133).

Engaging value chain workers

Reference: page 133 (index row at page 147).

The company discloses that no such process exists in formalised form:

"The Group has not yet implemented a formalised general process for direct involvement of workers along the value chain regarding the actual and potential impacts that affect them."

What is done instead is supplier-level, not worker-level. BasicNet "is committed to promoting compliance with environmental and social standards through the procurement functions of its 'strategically important' subsidiaries". The mechanism named is "a pre-contract analysis designed to assess Sourcing Centre potential... The information collected includes a questionnaire, 'Company Profile,' which covers aspects of environmental and social compliance, and allows information to be gathered on material impacts for workers by involving supplier representatives in filling out the questionnaire" (page 133).

So the engagement runs through supplier management rather than through workers or their representatives. No worker representative, trade union or credible worker proxy is named, no frequency is given, and no function is identified as operationally responsible for engagement. The one route that does reach workers directly is described under S2-3: third-party audits during which "private interviews with Sourcing Centre employees" may be conducted (page 133).

Remediation and channels for value chain workers

Reference: pages 133-134.

No dedicated channel exists, and the company says so: "the Group does not have specific communication channels dedicated to workers in the value chain for reporting and communication. However, this category of stakeholders can also make use of the whistleblowing channel, the details of which are public and available online" (page 133).

Starting position. "The double materiality assessment shows no actual negative impacts on workers in the value chain generated by BasicNet through its business activities." For potential impacts, "clauses are included in the Code of Conduct to protect value chain workers with respect to all identified topics" (page 133).

Remediation approach. "Corrective actions are assessed on a case-by-case basis... The effectiveness of the solutions adopted is monitored through informal and regular monitoring of the results."

Audits, where the substance sits. "BasicNet is progressively strengthening the monitoring of its supply chain, including through third-party audits, with scheduled and unannounced inspections of selected Sourcing Centres... representatives may examine employee books and records and conduct private interviews with Sourcing Centre employees." Violations trigger "a Corrective Action Plan", and repeated or deliberate breaches may lead to "cancellation of orders and/or termination of business arrangements".

Actions on value chain workers

Reference: pages 134-135. "The resources allocated to these initiatives were not material in terms of the Group's total CapEx and OpEx" (page 134).

The principal action is contractual. "all Sourcing Centres joining the Group's Network are required to view and sign the Code of Conduct", which "requires all Sourcing Centres to comply with all applicable laws and regulations relating to respect for the individual and human rights, health and safety and the environment". Signing it is "ongoing" and applies "to all Sourcing Centres with an active business relationship".

The one quantified action: "Also in 2025, the assessment process was conducted on 100% of the new Sourcing Centres (78 factories in 2025, 65 in 2024), including through remote interviews and site visits" (page 134).

Risks and opportunity (page 135). The human rights risk is mitigated through the Sourcing Agreement and Code of Conduct. The data protection risk is managed through IT controls: an Information Security Officer appointed in 2019 for the Italian companies, "a sandwich of two firewalls", "a new CyberIA Darktrace platform" and an outsourced SOC with "24/7 monitoring". On the opportunity: "no additional actions were carried out in the year nor are any planned in the future".

Outcome: "the Group received no reports of serious human rights issues or incidents related to its value chain" (page 134).

Value chain worker targets

Reference: page 135 (index row at page 147).

No targets, and no formalised effectiveness tracking either:

"The company has not defined specific objectives regarding material impacts, risks and opportunities related to workers in the value chain. The decision not to implement these objectives is due to the changing nature of company policies and the need to progressively align with international standards and regulations."

"Similarly, the company has not implemented a formalised monitoring system to assess the effectiveness of its policies and actions related to impacts, risks and opportunities related topics. Actions taken are assessed periodically, and any policy changes are made based on emerging needs and regulatory developments."

What does substitute for a target is the audit programme: "regular audits are implemented in cooperation with suppliers and partners, which include scheduled visits by internal resources, required audit reports and, if necessary, scheduled and unscheduled inspections, as required by the Code of Conduct" (page 135). The one associated figure sits under S2-4: the assessment process covered "100% of the new Sourcing Centres (78 factories in 2025, 65 in 2024)" (page 134).

No coverage target for existing suppliers, no remediation closure target and no timeline is disclosed. The same reasoning is given for S1-5 (page 124) and S4-5 (page 139).

Consumer and end-user policies

Reference: pages 136-137.

Cross-cutting rather than a single dedicated policy. BasicNet "adopts a structured approach to management of impacts, risks and opportunities related to consumers and end-users, applying cross-cutting policies that ensure high standards of protection and a safe and transparent shopping experience". Those policies "cover several aspects, including quality management and customer service practices. Mechanisms are also provided to address potential counterfeiting issues, with a focus on data and privacy protection" (page 136).

Regulatory anchor: the company "adheres to the requirements of the Consumer Code, which, among other matters, details the rules regarding the right of withdrawal and product warranty". Scope: "The policies adopted by the Group cover all Group consumers without distinction" (page 136).

The one named policy is on privacy (page 137). Data "are processed solely for the purposes stated and with the user's consent", with "technical and organisational measures to prevent unauthorised access". Its scope is "all data collection, processing and storage operations globally along the value chain", covering "consumers, employees, partners and suppliers", and "Data protection management is entrusted to external professionals contracted by the Group".

No commitment referencing the UN Guiding Principles or the OECD Guidelines is cited, and no product-safety policy is named separately.

Engaging consumers and end-users

Reference: page 137 (index row at page 147).

A short disclosure that states the absence of a process:

"Currently, the Group does not have a structured process for directly engaging consumers about actual and potential impacts that affect them. However, as part of the identification and assessment of these impacts, the Quality Assurance, Quality & Compliance and Marketing functions are involved."

So the identification of consumer impacts runs through internal functions rather than through consumers themselves. This is consistent with the materiality methodology, which drew only on internal stakeholders: "For this reporting year, the double materiality assessment process did not involve external stakeholders" (page 81).

No frequency, no named senior accountable person, no use of consumer panels or surveys and no assessment of the effectiveness of engagement is disclosed. Consumer-facing channels do exist and are described under S4-3, but they are complaint and reporting routes rather than engagement about impacts: a dedicated customer service department reachable "via e-mail, telephone and contact forms on the official website", and a platform for reporting counterfeit products accessible "via the company website or through QR codes on products" (page 137). Stakeholder engagement at Group level records customers and consumers as "engaged through product feedback and loyalty initiatives" (page 79).

Remediation and channels for consumers

Reference: pages 137-138.

Two channels (page 137):

• Direct customer service channel, "used to handle complaints about defective products", open "to distributors, stores, and all consumers who buy through direct sales", "active in all geographical areas where the Group operates", and "managed by individual brand companies"
• Platform for Reporting Counterfeiting, accessible "via the company website or through QR codes on products". Reports "may result in actions such as blocking the sale of counterfeit goods, removing online content or involving the relevant authorities"

How reports are handled. Each is "analysed individually through the evaluation of product samples and available information, followed by the drafting of technical reports". Remedies "may include product replacement, improvement of technical features or adjustment of business practices", monitored "through consumer feedback and quality control".

No anti-retaliation policy, and the stated reason (page 138): "The Group has not put in place specific policies to protect individuals from retaliation when using the channels described above, as reports submitted by consumers and end-users help to protect the Group from counterfeiting-related risks and are solely beneficial, making the possibility of retaliation effectively non-existent."

Actions on consumers and end-users

Reference: pages 138-139. "The resources allocated to this initiative were not material in terms of the Group's total CapEx and OpEx".

The material impact is counterfeiting, and the action is labelling. "each product developed and marketed by BasicNet has a label containing all information required under applicable Italian and international regulations, including the Consumer Code (Legislative Decree No. 206/2005), Regulation (EU) 1007/2011 on textile fibre names and labelling". Each label "also includes information that links the product to licensee orders".

BasicLabel "allows consumers to confirm the authenticity of purchased products, ensuring traceability from product creation through to the point of sale", and "has been active for all BasicNet-branded products since 2012" (page 138).

Effectiveness, with a negative result disclosed. Monitoring runs "through direct feedback and the tracking of complaints received". "in 2023... RFID technology was found not to be the most suitable solution for all Group brands. As a result, its use was consolidated exclusively for the K-Way brand... while the QR label was adopted for other brands."

Opportunities: "No additional actions beyond those already described were taken during the year". And: "To date, no material incidents have been reported in relation to the human rights of consumers or end-users" (page 139).

Consumer and end-user targets

Reference: page 139.

No targets are set, but effectiveness is tracked and quantified. "BasicNet has not yet set specific targets related to material impacts, risks and opportunities concerning consumers and end-users. However, it monitors product quality by continuously tracking and analysing customer complaints, reports concerning product quality and counterfeit items." It "has not identified the need to set targets beyond compliance with internal and external regulations".

The 2025 monitoring figures, the only quantified S4 outcomes:

• "three reports concerning counterfeits of Group-branded products were received through the dedicated 'Hunt the Fake' section, accessible on the BasicTrademark.com website"
• "An additional 375 counterfeiting reports were received in 2025 through other channels, such as government authorities"
• "The total number of counterfeit reports in 2025 increased by approximately 11% on 2024 (338 reports) and primarily concerned Kappa brand products (71% of all reports in 2025)"

Data basis: reports "are collected and monitored through an internal database, which consolidates reports received across all Group brands and reporting channels". The statement adds that "The total number of reports received (375) represents the sum of all reports received for all brands and through all channels", which reads inconsistently against the separate count of three "Hunt the Fake" reports.

Business conduct policies and culture

Reference: pages 140-142, with GOV-1 and IRO-1 for G1 at page 140.

Five instruments are named (pages 140-141): the Ethics Code; the Code of Conduct for Sourcing Centres; the whistleblowing procedure; the Organisation, Management and Control Model under Legislative Decree No. 231/2001; and the Related Parties Procedure.

The 231 Model is "a system of rules and procedures designed to prevent the commission of the offences covered by the Decree, through the effective control of corporate processes and the promotion of a culture of legality and business ethics". It "applies to all companies in the BasicNet Group and is adopted by the Parent Company", whose Board "is responsible for updates, while the Supervisory Board monitors the Model's proper implementation".

Reporting. The system "is accessible via a dedicated online platform (https://basicnet.segnalazioni.net/) and other alternative channels, ensuring the anonymity of the reporter"; reports are managed by the Supervisory Board and Internal Audit.

Corruption risk areas from the 231 Model (page 142): production licensees; distribution licensees; procurement; administration, accounting and financial statements; relations with public administration; personnel; charitable donations and gifts; and communication and sponsorship.

Supplier relationships

Reference: page 142.

Selection and qualification. "BasicNet has adopted specific internal procedures governing the selection, qualification and monitoring of suppliers. These procedures require all Sourcing Centres joining the Group's network to sign the Sourcing Agreement, which includes specific clauses on social and environmental compliance, in addition to the Code of Conduct."

Resilience of supply. "for strategic items, the Group requires production to be distributed across at least two or three Sourcing Centres located in different geographic areas, with the alternation of production sources every five years."

Product compliance. "the Group has prepared a Product Compliance and Guidelines document, which outlines requirements, responsibilities and procedures relating to product quality, safety and compliance", supported by "systematic testing activities covering compliance, quality and safety across fabrics, samples and finished products, in addition to the periodic updating of the PRSL (Product Restricted Substances List)".

Payment practices appear here, not under G1-6. "BasicNet adopts a structured system for managing supplier payments... The Company uses a dedicated application to monitor payment due dates, called the 'Supplier Payment Schedule'... Trade payables are normally settled between 30 and 120 days." The DMA found payment practices immaterial (page 83) and G1-6 is not in the index.

Prevention and detection of corruption and bribery

Reference: page 143.

Position. "BasicNet adopts a zero-tolerance approach to all forms of corruption, whether active or passive", through "an integrated system of safeguards that includes the Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001 (231 Model), specific protocols to prevent the risk of corruption, administrative, accounting and financial procedures based on the principles of segregation of functions and traceability of transactions".

A scope limitation the company states itself: "the Group's foreign companies are not subject to the regulations set forth in Legislative Decree No. 231/2001 and therefore have not adopted organisational models", though "they fully share the principles of the Group's Ethics Code".

Independence of investigation. Reports are "handled by the Supervisory Board (SB), which acts independently from the management structure involved in the issue... reporting its findings periodically to the Board of Directors".

Training, with figures. A mandatory programme covers "all personnel within the Group's Italian perimeter". "In 2025, this training involved 30% of the total population included in the risk categories, all operating in Italy (85% in 2024 following the update of the Model 231...)." The Group also states that "100% of functions identified as potentially at risk are covered by training programs".

Targets related to business conduct

Back-filled from the business conduct chapter, where targets fall under the MDR-T/GDR-T disclosures. G1-3 became a standalone DR only in the 2025/2026 ESRS.

BasicNet discloses no business conduct targets. The G1 chapter (pages 140-144) has no targets paragraph, and no G1 targets row appears in the content index (page 147). The Group sets nothing beyond compliance: it "does not have formal, specific targets related to significant product groups, customer categories or geographical areas" (page 78), and says the same for every other material topic.

Consistent with MDR-T's other limb, effectiveness is tracked and partly quantified:

• Training coverage. "In 2025, this training involved 30% of the total population included in the risk categories, all operating in Italy (85% in 2024...)", and "100% of functions identified as potentially at risk are covered by training programs" (page 143). The fall from 85% to 30% is not commented on.
• Independent investigation. The Supervisory Board "acts independently from the management structure involved"; the 231 Model "provides for regular audits and specific controls over business functions most exposed to the risk of corruption" (pages 141, 143).
• Incident monitoring. Convictions, fines and terminations "are recorded and monitored by the Legal and Administration departments" (page 144, Table 27).

No measurable outcome-oriented target or target year is disclosed.

Incidents of corruption or bribery

Reference: page 144. A nil return across every datapoint. "BasicNet received no convictions or related fines for breaches of anti-corruption laws. Likewise, the Group did not report any confirmed incidents of corruption and bribery involving its workforce or business partners that resulted in the termination of contractual relationships."

Table 27, incidents of corruption (page 144), 2025 and 2024 both nil:

• Convictions for violation of anti-corruption and anti-bribery laws: 0 (0)
• Fines for violation of anti-corruption and anti-bribery laws: Euro 0 (0)
• Total confirmed incidents of corruption or bribery: 0 (0)
• Confirmed incidents in which own workers were dismissed or disciplined: 0 (0)
• Confirmed incidents relating to business partner contracts terminated or not renewed: 0 (0)

Monitoring. "Any convictions, fines or termination of business relationships due to breaches related to corruption or bribery are recorded and monitored by the Legal and Administration departments, which promptly inform management accordingly."

Read this alongside G1-3: the Supervisory Board handles reports independently of the management involved, the whistleblowing platform is public, and the Group states that "no specific functions or roles have been identified as being exposed to a particularly high risk of corruption" (pages 141, 143). No figure is given for reports received through the whistleblowing channel in 2025.