Bekaert

Bekaert operates under a Belgian one-tier Board of Directors. The number of executive and non-executive members, their sector, product and geographical experience, and diversity of gender, age and nationality are disclosed in the Corporate Governance Statement (Board of Directors on page 42, Diversity on page 45). In accordance with Belgian law, NV Bekaert SA has no employee representation at Board level, and 33.33% of Directors are independent. Oversight of sustainability and cybersecurity is integrated into the existing Board and Board Committee structure. Overall responsibility rests with the Board, supported by the Audit, Risk and Finance Committee (process and controls, assurance, disclosures and reporting) and the Nomination and Remuneration Committee (Board skills, talent and culture, accountability and link to executive pay). The Audit, Risk and Finance Committee reviews the Double Materiality methodology, process and outcome and reports to the Board. Directors are selected via a Board skills matrix covering sustainability and cybersecurity, supported by a Board education program. The Bekaert Group Executive deploys the strategy, and Divisional CEOs are accountable for implementing the sustainability strategy and targets.

The main subjects reviewed by the Board of Directors and its Committees, and how the Board is made aware of them, are listed in the Corporate Governance Statement, in the Board of Directors subsection (page 42) and the Committees of the Board of Directors subsection (page 43). Sustainability and cybersecurity have become an integral part of the matters reviewed by the Board of Directors. The Board considers impacts, risks and opportunities when overseeing strategy, making decisions on major transactions, and managing risks. The list of material impacts, risks and opportunities is disclosed in the company's Double Materiality Assessment on page 182 of the report.

An ESG basket, made up of CO2e reduction (scope 1 and 2), sustainable solutions as a percentage of sales, and a safety target, carries a weight of 10% and applies to the long-term incentives (period 2024-2026) of the senior managers and the Bekaert Group Executive. Further detail is in the Remuneration Report section on the remuneration policy used in 2024 for the Board of Directors and members of the Bekaert Group Executive on page 51. In addition, a gender diversity target with a weight of 10% was included in the short-term incentive targets for management and the Bekaert Group Executive with respect to 2024, with more information disclosed in section S1-5 on page 231.

Bekaert states that a detailed description of its sustainability due diligence process is disclosed in section S1-4 on page 228, covering its own workforce, and in section S2-2 on page 242, covering workers in the value chain. These sections describe how the company takes action on material impacts, engages with affected stakeholders and their representatives, and addresses human rights and supply chain due diligence, including its supplier risk due diligence, human rights findings and supplier code of conduct programs referenced in the material topics on workers in the value chain.

Bekaert has defined and deployed detailed process flows to support ESG data collection. An adequate risk and control framework based on the COSO framework has been put in place to reinforce second line of defense control assurance activities. The framework addresses potential risks related to ESG reporting across commonly accepted risk domains, such as outdated process flows; incomplete, inaccurate and inconsistent data reporting; inaccurate reconciliation and reporting; improper access management and unauthorized modification of data; and conflict of interest or unethical behavior. Controls have been defined from both a corporate perspective and an entity-level perspective. Internal audits are conducted throughout the year to provide assurance on the accuracy and completeness of sustainability reporting, and on a periodic basis the results are presented to the Bekaert Group Executive and the Bekaert Audit, Risk and Finance Committee.

Bekaert is a company with a global footprint, employing 20,795 people and providing a variety of products and services to a wide international customer base in established and emerging markets. A breakdown of total sales by business unit is given in the Segment Reporting section of the Financial Statements on page 88, and further information is in the About Us section on page 9. Sustainability is an integrated part of the business strategy, with the ambition to be the leading partner for shaping the way we live and move, safe, smart and sustainable. The sustainability strategy rests on three pillars: Protect the planet (driven by climate change, dematerialization, resource depletion, circularity, energy transition and green technologies, offering sustainable solutions for new mobility, sustainable construction and clean energy); Put people first (a diverse, inclusive and safe environment for employees and communities); and Act with integrity (transparency, ethical and compliant practices, and supplier and customer partnerships with supplier risk management). Bekaert notes a slower than expected pace of decarbonization in some regions, driven by factors outside its control, which may affect its ability to reach some targets, to be re-evaluated in the next strategic planning cycle.

Bekaert creates value for its stakeholders by delivering on its strategy and objectives, both in financial performance and in addressing society's environmental and social opportunities and challenges. As a publicly listed company with a global business scope and footprint, it engages with parties that have an interest in the organization, with engagement organized through various channels depending on the stakeholder. Information about stakeholders is in the Our stakeholders section on page 17, and more detail on how their interests are integrated into strategy is included in the topical disclosures. A representative number of stakeholders were interviewed during the double materiality assessment to determine and confirm the topics they consider most material. External ESG driving forces and expectations from key stakeholders are taken into account during the strategic review and planning process. Through Business Unit specific strategy deep dive sessions, the Board of Directors is informed on the views and interests of stakeholders, and the double materiality assessment outcome was reviewed and discussed by the Audit, Risk and Finance Committee and reported to the Board.

Bekaert's reporting is based on its double materiality assessment, taking both impact materiality (positive or negative, actual or potential impact on environment and society) and financial materiality (potential financial risks and opportunities) into account. The process resulted in 8 material sustainability topics, clustered per ESRS topic and linked to the three strategic pillars. The material topics are Climate change mitigation (E1), Hazardous substances and materials (E2 Pollution), Water (E3), Circular economy and resource use (E5), Own workforce (S1), Workers in the value chain (S2), Cyber and data security (S4 Consumers and end-users), and Business Ethics (G1). A table describes each IRO, its effect, response and resilience, whether it relates to own operations (O), upstream (U) or downstream (D) value chain, the time horizon, whether actual (A) or potential (P), and whether inherent (I) or embedded (E) in strategic plans. All material IROs are covered by ESRS disclosure requirements with no additional entity-specific disclosures, and there are no known material risks or opportunities with a significant risk of material adjustment within the next annual reporting period. Resilience is ensured through the ERM framework, the double materiality assessment and physical climate risk studies, with a medium-term horizon up to 2030.

Bekaert performed its first double materiality assessment at the end of 2023 in line with the CSRD and the ESRS, and made a minor update in 2024 to fine-tune disaggregation, map connections between impacts and dependencies, and capture the 2024 ERM outcome. A 5-step approach was used. Phase 1 defined purpose and scope and mapped the value chain, key affected stakeholders and activities upstream and downstream. Phase 2 identified sustainability topics and their impacts, risks and opportunities through stakeholder consultation and document analysis; more than 60 internal and external stakeholders (including suppliers, customers, financial institutions and sector organizations) were interviewed with an external advisor. Phase 3 assessed the IROs across 13 sustainability topics using impact materiality (severity via scale, scope and remediability, plus likelihood) scored 0 to 15 with topics scoring 8 or above material, and financial materiality (magnitude and likelihood, aligned with ERM) scored 0 to 5 with topics scoring 3 or above material, using EFRAG thresholds. Phase 4 reviewed, calibrated and validated the outcome with the Steering Committee, the Bekaert Group Executive and the Board via the Audit, Risk and Finance Committee. Phase 5 produced a final report. The process is embedded in the ERM data collection tool for periodic updates and monitoring.

The disclosure requirements that Bekaert reports on, based on the outcome of the double materiality exercise and the corresponding ESRS standards, are set out in the Content Index on page 253. The index lists the ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and IRO-2), the EU Taxonomy, the environmental standards E1 Climate change, E2 Pollution, E3 Water and marine resources and E5 Resource use and circular economy, the social standards S1 Own workforce, S2 Workers in the value chain and S4 Consumers and end-users, and the governance standard G1 Business conduct, together with the page references for each disclosure requirement.

Bekaert's transition plan (E1-1) rests on science-based GHG reduction targets independently validated by the Science Based Targets initiative (SBTi), through which Bekaert joined the UN Climate Champions' Race to Zero. It targets a 46.2% reduction in Scope 1 & 2 emissions by 2030 versus 2019, a 19.7% reduction in Scope 3 emissions from purchased goods and services by 2035 versus 2019, and Carbon Net Zero by 2050. A 2030 transition plan, approved by the Group Executive and the Board of Directors, is embedded in each business unit's 2030 business plans including the financial means needed. The decarbonization roadmap comprises more than 1000 individual projects, with short-term levers being increased renewable electricity via on-site generation and offsite (virtual) PPAs plus reduced production energy. Potential carbon lock-in is mainly limited to gas-fired furnaces and baths, to be addressed through electrification. Bekaert also aims for 65% of sales from sustainable solutions by 2030 (EU Taxonomy-aligned revenue reached 45% in 2024).

Bekaert's energy and climate change policy (E1-2) is designed to align the organization with its decarbonization roadmap, with the ambition to reduce the carbon footprint by increasing use of renewable energy and improving energy efficiency. The policy has two focus areas: making Bekaert a more sustainable company and contributing to a more sustainable world through sustainable solutions. It applies to all consolidated Bekaert operations and businesses. The Chief Operating Officer (COO) oversees formulating the policy, while Divisional CEOs, supported by relevant corporate functions, are responsible for ensuring implementation in their respective businesses and operations. The policy is available in English on Bekaert's website.

Bekaert's actions (E1-3) follow a decarbonization roadmap covering baseline year 2019 to 2030, aligned with the Scope 1 & 2 SBTi target end year. Key levers are energy efficiency (the 'You Know Watt' program), on-site renewable generation, and green electricity via offsite (v)PPAs. Actions in 2019-2024 reduced CO2e emissions by about 333,000 tons; by 2030 Bekaert aims to cut an additional 380,000 tons. Reaching the 2030 target is estimated to require over EUR 30 million capital expenses and over EUR 10 million operating expenses (cumulative). In 2024, 40% of electricity consumed came from renewable sources. Bekaert installed 29 MWp of solar at its Jiangyin (China) campus in 2024, and has signed PPAs including Kings Plain US wind (125 GWh/year, 41,500 tCO2e abatement) and India solar farms. You Know Watt delivered 49 kt CO2e savings in 2024 across 5 sites, with 257 initiatives implemented.

Bekaert's climate targets (E1-4) follow the Greenhouse Gas Protocol (WRI). It targets a 46.2% reduction in combined absolute Scope 1 and Scope 2 emissions by 2030 versus 2019, aligned with the Paris Agreement 1.5-degree pathway, and a 19.7% reduction in absolute Scope 3 emissions from purchased goods and services by 2035 versus 2019. Both are validated by the Science-Based Targets initiative (SBTi); Bekaert also aims for Carbon Net Zero by 2050. Relevant GHGs are CO2, methane and HFCs. Base-year Scope 1+2 emissions were 1,652,835 ktCO2e (2019), with a 2030 target of 889,225 ktCO2e; Scope 3 purchased goods and services were 5,119,630 ktCO2e in 2019 with a 2035 target of 4,111,063 ktCO2e. In 2024, Scope 1 & market-based Scope 2 emissions fell 5.1% versus 2023 and 20.2% versus 2019; Scope 3 purchased goods and services fell 7.2% versus 2023 and 12.5% versus 2019.

Bekaert's total energy consumption (E1-5) was 3,887,005 MWh in 2024 (2023: 4,006,133 MWh). Of this, fossil sources totalled 2,638,984 MWh (68%), nuclear 262,709 MWh (7%), and renewables 985,313 MWh (25%). Fossil breakdown for 2024: natural gas 1,188,561 MWh; crude oil and petroleum products 66,550 MWh; other fossil sources 26,047 MWh; and purchased fossil electricity, heat, steam and cooling 1,357,825 MWh. Renewable consumption comprised 952,539 MWh purchased renewable electricity/heat/steam/cooling and 32,774 MWh self-generated non-fuel renewable energy (equal to renewable energy production; no non-renewable production). In 2024, 40% of electricity needs came from renewable sources (up from 38% in 2023), and 12.6% of purchased electricity came from contractual elements such as onsite PPAs, offsite (v)PPAs and green tariffs. All Bekaert activities are in high climate impact sectors (sector C Manufacturing). Total energy intensity was 982 MWh per mln EUR net revenue in 2024. Bekaert does not consume coal.

For 2024 (E1-6), gross Scope 1 GHG emissions were 252,727 tCO2e (2019: 299,964), with 0% from regulated emission trading schemes. Gross location-based Scope 2 was 1,123,825 tCO2e and gross market-based Scope 2 was 1,066,791 tCO2e. Total gross indirect Scope 3 emissions were 5,408,832 tCO2eq in 2024 (2019: 6,094,234), dominated by purchased goods and services (4,478,390 tCO2e); other material categories include capital goods (110,826), fuel and energy-related activities (311,874), upstream transportation (136,353), and processing of sold products (120,448). Total GHG emissions were 6,785,384 tCO2eq location-based and 6,728,351 tCO2eq market-based. Combined Scope 1 & market-based Scope 2 emissions were 1,319,519 tCO2e in 2024 (down 5.1% versus 2023, 20.2% versus 2019); location-based Scope 1 & 2 were 1,376,552 tCO2e. Scope 1 uses DEFRA emission factors; Scope 2 uses IEA factors. Bekaert is under no ETS.

Bekaert reports that GHG removals and GHG mitigation projects financed through carbon credits (E1-7) are not applicable to the company. No removals within its own operations or value chain, and no carbon credits, are disclosed.

Bekaert has developed an internal carbon price (E1-8) within its internal global capital expenditure program and will start using it from 2025. An internal carbon price of EUR 100 per ton CO2e will be applied as a shadow price when calculating the business case for capital projects, covering Scope 1 and Scope 2. Bekaert conducted a peer analysis to define the appropriate current internal carbon price. Because the majority of its Scope 1 & 2 emissions relate to production processes, the internal carbon price is applied only to capital projects, as these have the largest impact on Bekaert's carbon footprint.

Bekaert's Safety, Health and Environment (SHE) policy commits the company to protecting people and the environment, including prevention of pollution. The policy applies to all employees and anyone working at or visiting Bekaert premises, with roles and accountabilities clearly described, and is available in English on the company website. To guarantee a consistent level of care for all employees worldwide, Bekaert has implemented a global standard with internal exposure limits for a set of relevant hazardous chemicals and agents. These internal exposure limits are in line with, and at times go beyond, the most stringent limits in any of the countries where Bekaert operates. Production plants operate in accordance with their environmental permit and the company's environmental management system. Assets are operated globally in accordance with ISO 14001 and, where applicable, ISO 45001. (ESRS E2-1 paragraphs 14, 15 b, c.)

Bekaert operates a product stewardship framework with related capability building, covering standardized chemical management, environmental compliance of both raw materials and finished products, and related customer expectations. A global chemical management standard and a global chemical management software tool enable efficient implementation, strict governance, inventory management and proactive product compliance; the software tool has been deployed in all production sites to track use and control of chemicals, including substances of concern. Under the chemical exposure standard, employee exposure to relevant hazardous chemicals and agents is monitored at least yearly, with additional mitigating or protective measures taken if necessary. A company-wide life cycle management process, aligned with ISO 14001, identifies potentially significant environmental impacts across the supply chain. Bekaert monitors EU REACH regulation for both raw materials and finished products, expects suppliers to verify REACH compliance, identifies substances of concern and starts proactive phase-out programs. A dedicated regulatory team has been set up at corporate level within the SHE organization. (ESRS E2-2 paragraphs 16, 18.)

Bekaert's global safety approach aims to create a no-harm-to-anyone working environment. The company states it has not set specific external targets on substances of concern. However, Bekaert has defined internal exposure limits for a set of relevant hazardous chemicals and agents in order to guarantee the same level of care for all its employees worldwide. (ESRS E2-3 paragraph 23d.)

Bekaert discloses amounts of substances of concern and substances of very high concern by hazard class (chronic hazard to the aquatic environment and reproductive toxicity). Total substances of concern procured: 17,986 ton (chronic aquatic hazard) and 1,033 ton (reproductive toxicity). Substances of concern leaving facilities as part of products: 14,579 ton (chronic aquatic hazard) and 0 ton (reproductive toxicity). Total substances of very high concern procured: 1,033 ton in each category. Substances of very high concern leaving facilities as part of products: 0 ton in both categories. In scope are amounts of base metals procured and remaining on products; these metals represent the majority by weight of the substances of (very high) concern used and processed, either producing coatings on steel wires or as a production aid. Reported amounts include only pure substances, not those in mixtures, based on safety data sheet hazard classes; amounts leaving facilities are calculated using procured volumes multiplied by average scrap rates. Bekaert notes the hazard class does not reflect actual risk, since these are solid metals not water-soluble salts, and substances of very high concern are a subset of substances of concern. (ESRS E2-5 paragraphs 32, 34, 35.)

Bekaert is committed to reducing its impacts related to water withdrawal, consumption and discharge, especially in water stressed regions, through: monitoring water withdrawal including the use and sourcing of water in operations; building internal awareness on water conservation; and implementing programs to reduce water usage in both production and cooling processes, including reuse and recycling of water. After being used and reused many times, water that cannot be further recycled is treated according to best industry practices and in compliance with local legal requirements before leaving Bekaert premises. A risk management program is in place (detailed in E3-2) to prevent water pollution from operations. The water policy is designed to align the organization with water targets and applies to all consolidated operations and businesses. The Chief Operating Officer oversees formulating the policy; Divisional CEOs, supported by relevant corporate functions, are responsible for implementation. The policy is available internally via the Bekaert Document Management System (BDMS) and in English on the website. (ESRS E3-1 paragraphs 11, 12, 13.)

Bekaert uses water in production processes and implements programs to reduce water usage, especially but not exclusively in water stressed areas. Prevention and risk management activities include programs to reduce water withdrawal and consumption, and protection against soil and groundwater contamination with physical primary and secondary containment, condition monitoring and preventative maintenance. Actions focus on infrastructure-related consumption (water leakage management, control of evaporation losses, steam condensate reuse), process water use (conductivity-controlled rinsing, wastewater recovery), and sanitary water controls (water saving faucets in bathrooms). Since 2021 Bekaert implemented 30 water savings projects and saved 0.26 m3 per ton product. The global program "You Know Watt" aims to further reduce energy use, water consumption and waste generation in a structured way (more detail in section E1-3). As a resource, the You Know Watt program moves from plant to plant, supporting local teams in building awareness and identifying water saving opportunities. Water savings programs are prioritized with focus on water stressed areas and included in the Capex roadmap. (ESRS E3-2 paragraphs 17, 18, 19.)

Bekaert's ambition is to reduce its relative freshwater intake in water stressed areas by -15% by 2030 compared to 3.87 m3/ton in 2019 (measured against ton of final product produced). This target has been set on a voluntary basis. At the end of 2024, Bekaert reached 3.56 m3/ton, or a -8% reduction versus 2019, compared to 3.69 m3/ton at the end of 2023 (-5% versus 2019). One of the key levers for this reduction is the practice of recycling and reusing water multiple times until it can no longer be recycled. The target, together with the actions defined in section E3-2, focuses on reducing the impact of operations especially, but not limited to, water stressed areas, as well as safeguarding water quality via treatment of water before it leaves Bekaert facilities. (ESRS E3-3 paragraphs 22, 23a, c, 25, AR23a.)

Bekaert discloses water data for consolidated plants only, aligning with its water target and CSRD reporting scope (previously water data included joint ventures). Water consumption is defined as total water withdrawal minus total water discharge. In 2024, total water consumption was 3,477,816 m3, of which 1,756,768 m3 came from areas with water stress (where the ratio of total annual water withdrawal to total available annual renewable water supply is high, 40-80%, or extremely high, over 80%). Prior years' total water consumption: 3,920,629 m3 (2021), 3,870,611 m3 (2022) and 3,386,448 m3 (2023); water stress area consumption was 1,510,132 m3 (2021), 1,728,473 m3 (2022) and 1,693,203 m3 (2023). In 2024, total water recycled and reused was 112,314 m3 (only for plants with zero liquid discharge), total water stored was 2,800 m3, and changes in storage were 0. Water consumption intensity (m3 per million euro net revenue) was 940 (2021), 774 (2022), 782 (2023) and 879 (2024). Total water withdrawal in 2024 was 6,588,020 m3 (2019 baseline 7,960,995 m3). (ESRS E3-4 paragraphs 28, 29.)

Bekaert's Resource Use and Circular Economy Policy commits to minimizing the use of virgin materials, enhancing resource efficiency, and embedding circularity across the value chain, built on two pillars. Sustainable Operations prioritizes recycled materials in manufacturing, recycles and reuses materials such as water and packaging, and partners with local recyclers to achieve 100% recycling of steel scrap. Sustainable Solutions designs products for durability, recyclability, and adaptability to reduce waste and customers' carbon footprints, and collaborates on circular business models for recycling and reuse, noting steel is the most recycled material globally. Efforts follow the 9Rs framework (Refuse, Rethink, Reduce, Repair, Refurbish, Remanufacture, Repurpose, Recycle and Recover). The policy applies to all consolidated operations and businesses. The Chief Operating Officer oversees formulating the policy, and Divisional CEOs are responsible for implementation. The policy is available in English on the company website. (ESRS E5-1)

In 2024 Bekaert advanced circularity through operations and solutions. Total recycled content in wire rod was 24% in 2024, a 4% increase versus 2023, supporting its SBTi Scope 3 target to cut purchased goods and services emissions by 19.7% by 2035 (wire rod is over 80% of related emissions). 50% of wire rod suppliers now provide direct full-scope emissions data, covering over 70% of upstream Scope 3 wire rod emissions. 100% of all steel scrap is returned to the steel industry for recycling; water is recycled and reused. In tire reinforcement, Bekaert published its Recycled Content Standard and scaled high recycled content (HRC) products (minimum 50% for tire cord, 70% for bead wire), with over 20 HRC products across 10 plants. Packaging: 97% of tire cord spools were reused; one initiative saved more than 100 tons of cardboard. Waste management: a waste acid recycling unit in Weihai (China) cut hazardous waste acid disposal by more than 75%. Cumulative hazardous waste reduction reached 5.44 kg/ton end product by 2024 across 21 projects; EUR 1.45 million was spent on waste reduction projects in 2024. (ESRS E5-2)

Bekaert set targets on resource use and circular economy. For sustainable solutions, it aims to achieve 65% of sales from sustainable solutions by 2030, reaching 45% in 2024; these solutions are defined and classified according to the EU Taxonomy, which includes circular economy among its six environmental objectives. To reach this, the company focuses on increasing circular product design (durability, dismantling, recyclability), raising the circular material use rate through recycled materials, sustainable sourcing and use of renewable resources, and collaboration across the value chain. For sustainable operations, Bekaert set a voluntary target to reduce the quantity of its three main categories of disposed hazardous waste relative to final product by 25% by 2030 versus 37.7 kg/ton in the base year 2019. At end of 2024 it reached 31.4 kg/ton, a 16.6% reduction versus 2019. This target focuses on layer 1 (prevention) of the waste hierarchy per Article 4(1) of Directive 2008/98/EC. Other focus areas include effective waste management, minimizing virgin materials, recycling water and packaging, and ensuring 100% recycling of steel scrap. (ESRS E5-3)

Bekaert's major material resource inflows are steel wire rod, base metals (primarily copper and zinc) and packaging, selected as core materials connected to finite resources with high recycling and reuse potential; other inputs include lubricants, chemicals, polymers and plastics. In 2024 the overall total weight of materials used was 2,004,683 tons of wire rod, 17,928 tons of base metals, and 36,008 tons of packaging (in ton product). The weight of secondary recycled components was 476,513 tons for wire rod (24%), 5,230 tons for base metals (29%), and 1,687 tons for packaging (5%). Applying the ISO 14021 definition, total pre-consumer and post-consumer recycled content in wire rod was 24% in 2024, a 4% increase compared with 2023 due to a shift toward steel with significantly higher recycled content. In 2024 Bekaert requested recycled content information from base metal suppliers under ISO 14021 and, combined with internal data, covered 95% of base metals volume. Packaging consists of ferrous metal (spools), paper and cardboard, plastic and wood. Bekaert does not source any biological materials. (ESRS E5-4)

Bekaert serves a broad portfolio of products across various end-markets and integrates circular economy principles into the design of its production processes and products. On durability, most products are embedded in end-products, making publicly available industry averages difficult to provide, but products are designed for long-term durability, aligning with or exceeding industry standards where applicable. On repairability, because products are often integral components of larger systems, repairability of the final product or solution is out of Bekaert's control, and no established rating system exists for its products. On recyclable content, while Bekaert does not have direct control over the end-of-life of its solutions, it collaborates across the value chain with circularity in mind; its primary raw material, steel, is the most recycled material globally, so it should be technically possible to recycle its steel products at end of life even when integrated into a final product. Further recyclability initiatives are described in section E5-2. (ESRS E5-5)

All steel scrap generated in Bekaert's processes is recycled and returned to steel mills for reuse. In 2024, 82% of all total waste generated was recycled. Total waste generated was 90,860 tons hazardous and 100,549 tons non-hazardous (in ton product). Waste diverted from disposal: preparation for re-use 2,014 tons hazardous and 1,927 tons non-hazardous; recycling 61,760 tons hazardous and 92,436 tons non-hazardous; incineration with energy recovery 931 tons hazardous and 171 tons non-hazardous. Waste directed to disposal: incineration without energy recovery 3,565 tons hazardous and 78 tons non-hazardous; landfill 22,590 tons hazardous and 5,937 tons non-hazardous. Total non-recycled waste was 33,272 tons, or 17%. Main contributors to hazardous waste are spent acid from pickling of steel wires (high iron content), spent water-based lubricants from wire drawing, and sludge from wastewater treatment plants containing metal hydroxides. Non-hazardous waste consists mainly of scrap metal and packaging material. Quantities are based on amounts disposed by sites in 2024 per invoices from waste handling companies or certificates from local authorities. (ESRS E5-5)

Bekaert reports policies covering its own workforce. In 2024 it rolled out and publicly published a Human Rights Policy, implementing Article 18 of the EU Taxonomy Regulation and aligning with the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the eight ILO fundamental conventions and the International Bill of Human Rights. The policy was approved by the Bekaert Group Executive and applies to all employees. The Code of Conduct, approved by the Board of Directors, covers human rights, non-discrimination, child and forced labor, and ethics, and outlines the publicly available Speak Up grievance mechanism. Additional policies include a global hybrid working guideline (approved by the CHRO), a global parental care program setting a minimum parental leave standard worldwide (approved by the Group Executive), a global learning and development procedure (approved by the VP Talent, D&I and Organization Effectiveness), Diversity and Inclusion principles (approved by the CHRO), and a global Safety, Health and Environment policy approved by the CEO.

Bekaert engages its workforce through an annual global employee engagement survey run by an external provider ensuring confidentiality. In 2024 the participation rate was 81% (up 3% versus 2023) and the engagement rate was a stable 69%. Quarterly, the CEO and/or CFO host internal webcasts for managers and salaried professionals at financial news releases, alongside Communication Town Halls (global, regional and by business or function) hosted by the CEO, Group Executive members and country leadership. The Bekaert Intranet, Viva Engage social platform, video platform and internal news bulletins support two-way communication. The Chief Human Resources Officer has operational responsibility for employee engagement initiatives. Communication also includes negotiations with labor unions; 75% of employees worldwide are covered by collective bargaining agreements. The integral workforce is represented in the Safety, Health and Environmental Council, consisting of formal joint management-worker committees covering Health and Safety and environmental topics.

Bekaert operates a central Speak Up reporting tool that all stakeholders, including employees and external stakeholders such as local communities and value chain workers, are encouraged to use to raise integrity concerns and grievances. Reports are treated confidentially by the dedicated Ethics and Compliance department, and the tool allows confidential two-way communication in 15 languages for anonymous or named reporters. Employees may alternatively reach out to their HR representative, Internal Audit, or their direct manager or supervisor. Awareness is enhanced through the Code of Conduct eLearning deployed in approximately 15 languages, onboarding for operators with verbal Code updates every three years, CEO and senior management communications, and a continuous Speak Up campaign in offices and plants. An Investigation Protocol ensures quality and consistency; remedial measures are taken for substantiated cases, employees are protected against retaliation, and higher-risk cases are reported to the Regional and Group Compliance Committee. In 2024, 165 integrity allegations were reported and investigated; none constituted a violation by Bekaert employees related to discrimination, bribery or corruption.

In 2024 Bekaert performed a human rights impact and gap assessment in line with the UN Guiding Principles, identifying salient human rights impacts in operations and the value chain, either inherent to industry characteristics (right to life and health, safety exposures) or geographical footprint (right to freedom of thought, conscience and religion). On integrity, the Board's Audit, Risk and Finance Committee meets quarterly to review the compliance program, and integrity case statistics are reported twice yearly to the BGE and ARFC; 100% of managers and 100% of salaried professionals renewed their commitment to the Code of Conduct in 2024. On health and safety, the BeCare global safety program (launched 2016) and BeCare Pro development program continued rollout, Life-Saving Rules were improved to cover 10 hazardous situations, a safety investment program runs 2022 to 2025, and a global Health and Safety Week in 2024 focused on Finger and Fire safety. All own workers are covered by the Health and Safety management system. Other actions cover D&I, well-being, learning and development, and secure employment with redeployment, outplacement and severance during restructuring.

Bekaert sets targets across several workforce areas. On mental health, it targeted 100% of employees in Bekaert subsidiaries having access to the Employee Assistance Program, a target reached as of April 2024. On learning and development, Bekaert is committed to a minimum of 30 hours of training on average per employee annually; in 2024 each employee received on average 37 hours, exceeding the target. On diversity and inclusion, Bekaert targets a 40% share of female managers and salaried professionals by 2030, a target also added to the 2024 short-term incentive targets for management and Executives; at year-end 2024, 29% of managers and salaried professionals of Bekaert subsidiaries were female. On health and safety, Bekaert aims for a no-harm, risk-free working environment, tracked through a central management system with safety performance featured on the performance dashboard and as a fixed agenda topic at local and global town halls and shop floor meetings.

At year-end 2024 Bekaert employed 19,701 employees (head count): 16,961 male and 2,740 female; the categories other and not reported are not applicable. By region: EMEA 7,684; North America 1,510; Latin America 1,369; Asia Pacific 9,138. Permanent employees totaled 17,731 and temporary 1,970, with zero non-guaranteed hours employees. Full-time employees numbered 19,456 and part-time 245. By category: Blue Collars 14,414; Salaried professionals 3,615; Management 1,672. Countries with at least 50 employees representing at least 10% of the total were China (6,506) and Slovakia (2,095). Overall, 90% of employees have a permanent (indefinite) contract and 10% a temporary contract; 99% work full-time. Turnover in 2024 (consolidated entities, excluding definite-duration contracts and collective dismissals): voluntary leave 773 (4%; male 639/4%, female 134/6%); all personnel exits 1,433 (8%; male 1,211/8%, female 222/9%). Workforce records are held in a central HR system with FTE cross-referenced to Segment Reporting on page 89.

Bekaert reports non-employee workers, defined as workers not on its payroll who complement the employee workforce, mostly providing temporary services through agencies or consulting firms. At 31 December 2024 there were 1,094 non-employees (head count): 910 male and 184 female. By region: EMEA 159; North America 9; Latin America 30; Asia Pacific 896. By category: Blue Collars 1,008; Salaried professionals 69; Management 17. Of the non-employees, 99% work full-time. Combining employees (19,701) and non-employees (1,094), Bekaert's total own workforce at year-end 2024 was 20,795.

Bekaert reports gender and age diversity indicators. Gender diversity in top management at 31 December 2024: Board of Directors 9 people, 56% male / 44% female; Bekaert Group Executive (BGE) 9 people, 78% male / 22% female; Senior Vice Presidents (B16-B18) 14 people, 93% male / 7% female; next leadership level (B13-B15) 76 people, 75% male / 25% female. The total leadership team of 108 people was 78% male and 22% female. Age diversity of employees at 31 December 2024: total employees 12% under 30 years old, 70% aged 30-50, and 18% over 50. By category, Blue collars were 13% / 70% / 16%; Salaried professionals 10% / 69% / 21%; and Management 3% / 67% / 31% across the three age bands.

Bekaert reports on social protection. It offers competitive salaries and benefits designed to enhance the financial, physical and overall well-being of employees and their families, adapted to local social security policies. The range of benefits may include retirement benefits, healthcare plans, service awards, labor accident disability coverage and paid leave; detailed information is referenced to Financial Statements section 6.16. A table of benefits provided to payroll employees in significant locations (locations with more than 1,000 employees on the payroll) covers Belgium, China, Indonesia, Slovakia and the US. Life insurance, disability coverage, parental leave and retirement provision are provided in all five locations. Health care is provided in Belgium, China, Indonesia and the US but not in Slovakia. Stock ownership is not offered in any of the five locations. These benefits apply to payroll employees and not to non-employees.

Bekaert reports training and skills development metrics. Percentage of employees who received a performance review in 2024: Managers 98% (male 98%, female 98%) and Salaried professionals 98% (male 98%, female 97%). Operators do not follow the People Performance Management process but discuss performance frequently in local team sessions and one-on-one meetings with shift leaders. On learning, each employee received on average 37 hours of training in 2024, of which 34 hours for female and 37 hours for male employees, well above the target. A regional table breaks down average training hours by gender and category for 2022, 2023 and 2024 across EMEA, Latin America, North America and Asia Pacific. Additionally, each employee received on average 4 hours of mandatory training, 11 hours of safety training and 1 hour of well-being training in 2024.

Bekaert reports health and safety metrics for own workforce (consolidated entities) plus on-site non-own workforce. For 2024, TRIR was 4.62, LTIFR 2.91 and SI rate 0.08 (versus 2023 TRIR 4.84, LTIFR 3.01, SI rate 0.14). For combined entities (consolidated plus joint ventures) plus on-site non-own workforce, 2024 TRIR was 4.27, LTIFR 2.57 and SI rate 0.10. Safety KPIs decreased in 2024: LTIFR -3.7, SI rate -33.3 and TRIR -0.5. The number of serious incidents leading to life-altering injuries fell from nine in 2023 to six in 2024, all related to hand and finger injuries. No fatal work-related accidents occurred on premises in 2024 (employees, non-employees or subcontractors), so days lost to fatalities was zero, and no fatal accidents occurred commuting. There were 251 recordable work-related accidents including JVs, and 5,668 lost days from work-related injuries including JVs. All own workers are covered by the Health and Safety management system; 35 sites (51% of manufacturing plants) hold ISO 45001 certification. In 2024, 13 plants achieved 1 year, 6 plants 2 years, 2 plants 5 years, and 2 plants 10 or more years without recordable incidents.

Bekaert states that this sustainability matter is not material for the company but discloses remuneration information for transparency at the request of customers, ratings and investors. The gender pay gap covers salaried professionals and managers and excludes blue collar workers (whose wages follow local collective labor agreements). Proportion of female employees per salary band at Bekaert: Bekaert Group Executive 22% female; Senior Vice Presidents 7%; Senior Management 25%; Mid Level Management 19%; Junior Management 25%; Salaried Professionals 31%; Total 29% female (71% male). The gender pay gap, based on comparing median female and male compa ratios (base pay to salary-band midpoint), was: EMEA -4.51%, Latin America -4.51%, North America -7.40%, Asia Pacific -5.35%, and Total -3.85%. Bekaert states the global gender pay gap of -3.85% is lower than the global, European and sector average, with many countries showing no pay gap.

Bekaert states that this sustainability matter is not material for the company but discloses information for transparency, being committed to respecting human rights. It has a central case reporting and investigation management tool. The Speak Up channel allows all employees and third parties to report concerns confidentially through two-way communication with Group Ethics and Compliance, for anonymous reporters and those who share their identity. Employees may alternatively reach out to their HR representative, Group Legal, Internal Audit or their direct manager or supervisor. The Investigation Protocol ensures quality and consistency of investigations, all reports are handled with the highest confidentiality, each allegation is thoroughly investigated, employees are protected against retaliation, and remedial measures are taken where improvement areas are revealed. In 2024, 165 integrity allegations were reported and investigated; none constituted a violation by Bekaert employees related to discrimination, bribery or corruption. There were no human rights breaches reported connected to Bekaert's own workforce.

During 2024 Bekaert developed and implemented a Human Rights Policy, formalizing its commitment to respect human rights and highly relevant to how it engages its upstream supply chain (further detail in S1-1, page 225). The Bekaert Supplier Code of Conduct sets environmental, social and governance requirements for all suppliers, including child and forced labor requirements. The Chief Operating Officer oversees formulating the policy and the Central Procurement Department ensures implementation; it forms part of supplier relationship management and evaluation, and is available on the website in 15 languages. At the end of 2024 this supplier commitment represented 94% of spend. The Bekaert Policy on Responsible Minerals Sourcing applies to all suppliers delivering minerals potentially originating from conflict-affected and high-risk areas and to all wholly and majority owned subsidiaries, with grievance mechanism described in the policy. In 2024, 100% of suppliers covered by the Responsible Minerals Initiative signed the Code of Conduct or proved adherence, 100% signed the Responsible Minerals Sourcing policy, and 100% of tin and tungsten suppliers completed a Conflict Minerals Reporting Template. Remedy is enabled through the Speak Up channel and supply chain due diligence program.

Bekaert manages supply chain sustainability through a tiered approach aligned with its Supplier Relationship Management (SRM) framework. Due diligence applies to all direct suppliers, including policy adherence and risk assessment. Since 2023 procurement implemented an improved upstream due diligence process evaluating, prioritizing and mitigating Environmental, Social and Governance risks, with the Chief Operating Officer holding operational responsibility. The process begins with broad screening and monitoring of all new and existing direct suppliers; suppliers are prioritized on identified risks and dependency. Following risk validation, suppliers are typically invited to complete an EcoVadis assessment or SEDEX (Supplier Ethical Data Exchange) questionnaire, with action plans or on-site audits following. The two primary ways Bekaert engages directly with value chain workers are the Speak Up channel and on-site audits (2nd and 3rd party). In the second half of 2024 Bekaert reviewed its due diligence process, screened market solutions and began implementing a new solution offering full data coverage, targeted AI analysis for higher-risk suppliers, automated tier-N mapping and integrated action management. Strategic suppliers (Partners, Preferred, Monitored segments) are expected to reach an EcoVadis score above 45 within the past 3 years; 51% of 2024 strategic supplier spend met these expectations, a 10% improvement since 2023. SEDEX supports SMETA third-party on-site audits.

The Bekaert Supplier Code of Conduct outlines environmental, social and governance requirements that suppliers should comply with, including child and forced labor requirements, and applies to all suppliers (more detail in S2-1, page 242). Bekaert operates a central Speak Up reporting tool, widely available for everyone to file a concern. All individuals, including workers along Bekaert's value chain, are able and encouraged to raise their integrity concerns and grievances via the Speak Up tool. Further information on the Speak Up channel is disclosed in section S1-3 on page 227 of the report.

Bekaert has a robust process for evaluating, prioritizing and mitigating upstream supply chain risks related to Environmental, Social and Governance factors (detailed in S2-2, page 242). The central procurement department is responsible for upstream supply chain due diligence, including taking action on material impacts on value chain workers. The procurement center of excellence (COE) owns the due diligence process, undertaking risk identification and coordinating the overall process. Where necessary the relevant supplier manager, based on category, segment and region, takes actions together with the supplier to mitigate identified risks or impacts; supplier managers can be local buyers or part of global category management teams. Group compliance and the central sustainability team are consulted as needed. Bekaert annually drafts an audit plan; it conducted 104 supplier audits in 2024 compared to 74 in 2023, prioritized on quality assurance, critical supplier process changes and risk. Key Supplier Agreements remain important for wire rod and other categories. At the end of June 2024 Bekaert held an online event on sustainability requirements for wire rod suppliers, including certified CO2e emissions intensity; 42 steel suppliers were invited with 30 participants attending across two sessions.

Bekaert expects suppliers to adhere to the Supplier Code of Conduct, lead in ESG ratings (minimum EcoVadis score of 45), and comply with the Policy on Responsible Minerals Sourcing. Bekaert aims for 100% of its spend to be with suppliers who sign off the Supplier Code of Conduct by 2030; in 2024 this commitment represented 94% of spend. It expects 100% of strategic suppliers to lead in ESG ratings by 2030, asking them to join EcoVadis and achieve a minimum score of 45; suppliers scoring below 45 must provide an action plan monitored via the EcoVadis platform. 51% of 2024 strategic supplier spend was with suppliers meeting these expectations, a 10% improvement since 2023. Bekaert requires suppliers to provide components, parts or materials containing tantalum, tin, tungsten, gold, cobalt and/or natural mica from conflict and child and forced labor free sources only, and to complete the latest Conflict Minerals Reporting Template (CMRT) and Extended Mineral Reporting Template (EMRT) from the Responsible Minerals Initiative. In 2024 all covered suppliers complied. Bekaert notes it will evaluate its ambition and targets as part of its next strategic planning cycle.

The Bekaert Code of Conduct describes how Bekaert values are put into practice and the behaviors expected from every employee, covering key areas including data privacy protection and cyber security principles; it was approved by the Board of Directors (more detail in S1-1, page 225). Privacy rights of individuals are protected through comprehensive data privacy policies, processes and a governance structure built around a dedicated data privacy office headed by the Global Data Privacy Officer, supported by a global privacy manager and department-level privacy champions in several regions. Three policies apply: the Personal Data Privacy policy, the Personal Data Breach Notification procedure, and the Data subject request procedure, all approved by the Chief Digital and Information Officer. Bekaert operates a comprehensive cybersecurity program adhering to standards including ISO 27001, NIST CSF, IEC 62443 and COBIT, with a designated Head of Cybersecurity (Chief Information Security Officer) and a dedicated corporate cybersecurity team; cybersecurity policies are approved by the Chief Digital and Information Officer. During 2024 Bekaert developed and implemented a Human Rights Policy. There were no human rights breaches identified connected to consumers and end-users.

Bekaert has published privacy notices for external stakeholders covering processing details and how to contact the Data Protection Office to exercise their rights and raise privacy-related questions and concerns. The data subject rights management process starts with validation of the external individual and any authorized representatives to ensure only a legitimate requestor receives the requested information. Beyond regular customer engagement channels, there are no specific data privacy or security related engagement processes in place. Bekaert has implemented digital channels, internally via Solve (its service portal) and externally via the Bekaert website, to report security concerns, risks, incidents and vulnerabilities. Dedicated teams and processes handle such events on a 24/7 basis, and the data privacy breach notification process defines the steps in the breach forensics and reporting process.

Bekaert has established a robust data privacy incident management process covering breach forensics, risk assessment, regulatory reporting and remediation. A breach incident can be reported through multiple channels including a dedicated privacy e-mailbox, the Speak Up reporting channel and the information security incident reporting channel. The process starts with a preliminary risk and impact investigation and regulatory reporting analysis, with every incident escalated to the information security team for security assessment and remediation planning. Breach incident reports are kept under a central reporting mechanism, summarized for governance meetings, and each incident and its remediation actions are tracked until closure. A data privacy technology solution supports systematic assessments, response collection, risk categorization, remediation planning and observation closure. For data security, Bekaert has 24/7 detection and response services and a dedicated Incident Management team, plus a defined Cyber Crisis Management plan with periodic training. Measures include data classification, encryption, access management and employee training. Bekaert also operates a central Speak Up reporting tool through which all individuals, including external stakeholders, local communities and value chain workers, can raise integrity concerns and grievances (more detail in S1-3, page 227).

The data privacy office has a dedicated budget for training and awareness, including bi-annual e-learning programs, awareness training for the information security team and its external members, personalized training and risk-based training, focused primarily on the data privacy awareness needs of internal and external stakeholders. Bekaert's Data Privacy program covers four major pillars: Governance and Culture, Educate, Examine and Enforce, with progress tracked through KPIs covering regulatory change tracking, a system-based approach to privacy operations, strong incident management and reporting, and enhanced privacy awareness. A dedicated resource manages program-level activities using privacy automation technology. On data security, Bekaert has an annual cybersecurity training and awareness program managed by the Corporate Cybersecurity team using multiple communication channels, with quarterly phishing awareness training and simulations conducted for all employees and non-employees, results tracked through a dedicated solution. The program educates individuals on protecting organizational data and recognizing risks such as phishing, malware and social engineering, ensuring compliance with policies and regulations and reducing human error. There were no human rights breaches identified connected to consumers and end-users.

Bekaert has no external targets related to data privacy and security other than the transparent visibility of data processing details for external stakeholders. The data privacy office has established internal time-bound and outcome-based KPIs to ensure compliance with industry best practice standards and applicable laws globally, tracked periodically through global governance meetings. The privacy KPIs focus on regulatory changes in major privacy laws, a robust and timely incident management process, initiatives to enhance continuous privacy awareness, and utilization of industry best privacy solutions for managing privacy operations and privacy records. In addition, there are internal targets to improve Bekaert's data security maturity level year-on-year with milestones and progress tracking.

In December 2023 Bekaert issued a new Code of Conduct, approved by the Board, reflecting its revitalized values, purpose and brand identity and covering new and updated areas including sustainability, antitrust, diversity and inclusion (further detail in S1-1 page 225 and S1-4 page 228). Bekaert also maintains an Anti-Bribery & Corruption Policy applying to all employees and those representing Bekaert, approved by the Bekaert Group Executive and available on its website, plus a supplier Code of Conduct. Extensive compliance training covers anti-bribery and anti-corruption, antitrust, data privacy, compliance awareness, conflict of interest, speak up culture and trade compliance (economic sanctions), delivered through a risk-based mix of live and online modules tailored to roles. In 2024 Bekaert re-deployed a mandatory anti-bribery and anti-corruption course to all managers and to salaried professionals in departments with frequent third-party contact, deployed a new Conflict of Interest eLearning to managers and employees in higher risk countries, and ran targeted antitrust and anti-harassment training. Group Internal Audit regularly audits adherence. The central Speak Up reporting tool, available to employees and external stakeholders, is underpinned by an Investigation Protocol and anti-retaliation measures. CEO and senior leaders reinforce integrity through quarterly town halls and an annual engagement survey measuring ethics.

Bekaert flags prevention and detection of corruption and bribery as a sustainability matter that is not material for the company, but discloses the information for transparency reasons requested by customers, ratings and investors. Bekaert provides extensive compliance training to employees on key topics including anti-bribery and anti-corruption, antitrust, data privacy, compliance awareness, speak up culture and trade compliance (economic sanctions). It reports that 100% of the functions at risk are in scope for the mandatory eLearnings, for example General Management, Finance, Procurement, Sales, Supply Chain and Plant Maintenance. The training program combines classroom/live training and online modules using a risk-based approach tailored to roles, and is modified through the year to reflect compliance trends and lessons learned from internal investigations. A mandatory anti-bribery and anti-corruption course applies to all managers and to salaried professionals in departments with frequent third-party contact (further detail in G1-1 page 250). Commitment to integrity starts with the Board and the Bekaert Group Executive; the Board's Audit, Risk and Finance Committee (ARFC) receives quarterly reviews of the compliance program relating to the Code of Conduct. Higher risk substantiated cases are reported to the ARFC, while substantiated high and medium risk cases are reported quarterly to a Compliance Committee composed of dedicated Bekaert Group Executive members.

Bekaert flags incidents of corruption or bribery as a sustainability matter that is not material for the company, but discloses the information for transparency reasons requested by customers, ratings and investors. In 2023 Bekaert implemented a new central case reporting and investigation management tool that allows all employees and also third parties to report concerns or raise questions, enabling confidential two-way communication between Group Ethics and Compliance and anonymous or identified reporters. Reporters may alternatively reach out to their HR representative, Group Legal, Group Ethics and Compliance, Internal Audit or their direct manager or supervisor. An Investigation Protocol ensures the quality, consistency and reporting of investigations. In 2024, 165 integrity allegations were reported through the integrity reporting channels. None of the allegations constituted a violation by Bekaert employees of integrity breaches related to discrimination, bribery or corruption. Each allegation was thoroughly investigated, and remedial measures were taken as necessary for all substantiated cases and for cases where improvement areas were revealed. All incoming reports are handled with the highest level of confidentiality, and Bekaert takes all necessary measures to protect employees against retaliation when reporting a concern. No fines or convictions for corruption or bribery are reported.