Bekaert

Reference: page 193

Board composition is disclosed largely by cross-reference to the Corporate Governance Statement (pages 49 and 53). Directors are selected against a skills matrix that "covers various areas, including sustainability and cybersecurity expertise"; 36.36% are independent; and "In accordance with Belgian law, NV Bekaert SA has no employee representation at Board level" (p.193).

Oversight is split across the existing committee structure: overall responsibility rests with the Board, with specific responsibilities assigned to 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 Double Materiality methodology, process and outcome are reviewed and discussed by the Audit, Risk and Finance Committee and validated by the Board", and the Board "has appointed one lead Director for sustainability matters" (p.193).

Executive Management deploys the strategy and monitors target progress through annual strategic planning cycles, and "The Business Units' Divisional CEOs are accountable for the implementation of the sustainability strategy (including the progress towards the targets) within their respective business strategies" (p.193). A Board education programme covering sustainability matters is available to Directors.

Reference: page 194

A short disclosure that works mainly through cross-reference. "The main subjects reviewed by the Board of Directors and Board Committees and how the Board is made aware of these are listed in the Corporate Governance Statement", subsections Board of Directors (page 49) and Committees of the Board of Directors (page 50) (p.194).

Bekaert states that "Sustainability has 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", and points to the double materiality assessment on page 202 for the list of material impacts, risks and opportunities (p.194).

The incorporation-by-reference table confirms the approach, listing GOV-2 against the Corporate Governance Statements and the IRO-1 double materiality assessment process (p.191). The statement does not set out the frequency of sustainability reporting to the Board, nor which specific IROs were addressed at which meeting during 2025, so the disclosure is thinner than the cross-references imply.

Reference: page 194

"An ESG basket (CO2e reduction scope 1 and 2 and safety performance (TRIR), both with equal importance) with a weight of 10% is part of the the long-term incentives (period 2025-2027) of the senior management and the Executive Management" (p.194). The same disclosure is repeated at the head of the E1 chapter as E1-GOV-3 (p.214). Detail is cross-referenced to the Remuneration Report section "Statement of the remuneration policy used in 2025 for the Board of Directors and members of the BGE" on page 58.

Two points a reader should note. The link is to long-term incentives only; no short-term or annual bonus link to sustainability performance is disclosed. And the basket covers only climate (Scope 1 and 2 CO2e) and safety (TRIR), so none of the other five material topics - hazardous substances, water, circular economy, value chain workers or business ethics - carries a remuneration link. Information about prior-year schemes is referred to previous Annual Reports rather than restated (p.214).

Reference: page 194

The due diligence statement is a pure cross-reference: "A detailed description of our due diligence process is disclosed in S1-4 on page 252 and in S2-2 on page 269" (p.194). The incorporation-by-reference table repeats this mapping (p.191).

The substance sits in those two sections. S1-4 reports the 2024 human rights impact and gap assessment, which identified, "in line with the requirements of the United Nations Guiding Principles on Business & Human Rights, the potential and actual most severe adverse ('salient') human rights impacts in Bekaert's operations and value chain", and a three-year improvement action plan continuing into 2026 (p.252). S2-2 sets out upstream supply chain due diligence, prioritising suppliers "based on a combination of the risks identified and the dependency in the relationship between our two companies", with Prewave or SEDEX self-assessments, action plans and on-site audits (pp.269-270).

Bekaert does not print the ESRS 2 GOV-4 mapping table that sets each core due diligence element against its location in the statement.

Reference: page 194

"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 the second line of defense control assurance activities" (p.194). The named risk domains are "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 and/or unethical behavior". Controls are defined at corporate and entity level.

On assurance: "Internal audits are conducted within Bekaert throughout the year to provide assurance around the accuracy and completeness of our sustainability reporting. On a periodic basis, results of these audits are presented to the Executive Management and the Bekaert Audit, Risk and Finance Committee" (p.194). Separately, BP-2 records that "Except for third-party verified Life Cycle Assessments (LCA), all reported metrics have been independently verified solely by the Statutory Auditor" (p.190).

The disclosure does not report the findings of those internal audits, so a reader learns the design of the controls but not their tested effectiveness.

Reference: page 195

"Bekaert is a company with a global footprint, employing over 19 000 people, providing a variety of products and solutions and offering services to a wide international customer base in established and emerging markets", with the business model and sales breakdown cross-referenced to About Us on page 9 and Segment Reporting on page 100 (p.195). The four business units are Steel Wire Solutions, Bridon-Bekaert Ropes Group, Rubber Reinforcement and Specialty Businesses (pp.15-17, 230).

The strategy rests on three pillars: Protect the planet, Put people first and Act with integrity (p.195).

Bekaert then qualifies its own ambition plainly: "We are observing a slower-than-anticipated pace of decarbonization in certain regions in the world"; achieving the targets "depends on several critical factors beyond our direct control, such as the geopolitical and economical context, technological advancements, a more diversified and affordable energy mix"; and "We are evaluating our ambition and targets as part of our strategic planning cycles and are considering making updates" (p.196). That caveat is repeated in footnotes to the E5-3, S1-5 and S2-5 targets.

Reference: pages 196-197

Bekaert presents a six-row stakeholder table covering employees, customers, investors and analysts, partners, suppliers (marked "Including value chain workers") and local communities, each with type of engagement, purpose, summary of insights and how views are taken into account (p.197). Channels named include the employee survey, Town Halls, Viva Engage and works councils; satisfaction surveys and co-innovation projects; Capital Markets Day, analyst calls and ESG ratings; supplier trainings and co-development; and volunteer work, educational support, disaster relief, local employment and tax payments.

Stakeholder input feeds the materiality assessment directly: "a representative number of our stakeholders were interviewed during our double materiality assessment to determine and confirm which topics they consider most material" (p.196), and IRO-1 records that 10 additional external stakeholders were interviewed in the 2025 update, "covering customers, suppliers and the reference shareholder of Bekaert" (p.202).

The Board is informed through business-unit strategy deep dive sessions, and "the outcome of the double materiality assessment has been reviewed and discussed by the Audit, Risk and Finance Committee and validated by the Board" (p.196).

Reference: pages 198-201

"The double materiality process resulted in 7 material sustainability topics" (p.198): climate change mitigation, hazardous substances and materials, water, circular economy and resource use, own workforce, workers in the value chain, and business ethics. The IRO overview table on pages 199-200 gives each IRO a type label, a description of effect, response and resilience, and flags own operations (O), upstream (U) or downstream (D), time horizon, actual or potential, and whether the impact is inherent to the business (I) or embedded via strategic plans (E).

Examples from the table: "Our production processes are energy intensive and we emit CO2e, primarily indirectly through our use of purchased electricity but also directly where we use gas. Our wire rod suppliers (Bekaert's main raw material) have a high carbon footprint"; and upstream, "Our upstream supply chain, primarily for our main raw material, can be a harsh working environment due to the type of business (metals), with industry-specific health and safety exposures" (pp.199-200).

Bekaert then states: "All material impacts, risks and opportunities are covered by ESRS disclosure requirements. There are no additional entity-specific disclosures", and "At this stage, there are no known material risks and opportunities which would require a material adjustment within the next reporting period" (p.201).

Reference: pages 202-203

"In 2023, Bekaert conducted its first double materiality assessment in line with the CSRD guidelines, ESRS standards and guidelines issued by the European Financial Reporting Advisory Group". The 2025 update "followed a four-phase approach": analyse context changes, stakeholder engagement, refine and update assessments, validate outcome (p.202). Bekaert interviewed 10 additional external stakeholders and reviewed policies, strategy documents, sector and peer reports, customer and supplier data, ERM outcomes and supplier risk due diligence findings.

Thirteen clustered sustainability topics were assessed: climate change adaptation, climate change mitigation, pollution, hazardous substances and materials, water, biodiversity, circular economy, own workforce, workers in value chain and human rights, local communities, cyber and data security, product stewardship, and business ethics (p.202).

Thresholds are disclosed numerically, which is unusual and useful: "Impact materiality: scoring from 0 to 15 ... Topics that scored 8 and above were considered material. Financial materiality; scoring ranges from 0 to 5 ... Topics that scored 3 and above were considered material" (p.203). "The whole update process, assessment and outcome was reviewed by an external consultant", and the outcome was validated with Executive Management and the Board via the Audit, Risk and Finance Committee.

Reference: page 203, index on pages 276-277

"The table with disclosure requirements that Bekaert reports on is disclosed in the section Content Index on page 276" (p.203). The index is a genuine ESRS concordance: "Based on the outcome of the double materiality exercise and according to the corresponding ESRS standards, Bekaert reports on the following disclosure requirements", followed by DR number, title and page (p.276).

It covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), EU Taxonomy, E1 (E1-1 to E1-8), E2 (E2-1, E2-2, E2-3, E2-5), E3 (E3-1 to E3-4), E5 (E5-1 to E5-5), S1 (S1-1 to S1-7, S1-9, S1-11, S1-13, S1-14, S1-16, S1-17), S2 (S2-1 to S2-5) and G1 (G1-1, G1-3, G1-4). E4 and S3 do not appear at all, and S4 was removed this year.

Four entries carry their own qualification: S1-16, S1-17, G1-3 and G1-4 are each labelled "(not material IRO topic)", and the corresponding sections repeat that they are disclosed "for transparency reasons requested by customers, ratings and investors" (pp.265, 266, 275). Bekaert also prints a separate incorporation-by-reference table on pages 191-192.

Reference: pages 214-215

"Our science-based GHG reduction targets were independently validated by the Science Based Targets initiative (SBTi)" (p.214). The plan runs to a 46.2% reduction in combined Scope 1 and 2 emissions by 2030 against 2019, a 19.7% reduction in Scope 3 purchased goods and services emissions by 2035 against 2019, and "the ambition to reach Carbon Net Zero by 2050".

On governance and embedding: "We have a 2030 transition plan outlining the steps and actions required by the business and the various functions to achieve our environmental targets. The 2030 transition plan has been approved by both the Executive Management and the Board of Directors. The 2030 transition plan is embedded in the 2030 business plans of each business unit in Bekaert including the financial means needed to meet the targets" (p.214).

Locked-in emissions are addressed directly: "the assets with a potential carbon lock-in are mainly limited to gas fired furnaces or baths ... We may experience carbon lock-in if fossil-fuel assets are not replaced by green technologies" (p.214). The roadmap is sized by project count: "more than 1 000 individual projects, of which over 200 have already been identified as viable" (p.215). A linked portfolio target aims for "65% of our consolidated sales to come from sustainable solutions by 2030", with 2025 EU Taxonomy aligned revenue at 49% (p.214).

Reference: pages 216-220

Back-filled from E1 SBM-3 and E1 IRO-1, where this content is disclosed in the FY2025 report (pages 216-220). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification is explicit: "Climate-related opportunities and risks have been mapped in accordance with the classification framework of the Task Force on Climate-related Financial Disclosures (TCFD), covering both transition and physical risks and opportunities over the short, medium and long term" (p.216).

On scenarios: "Three climate scenarios (representative concentration pathways 2.6, 4.5 and 8.5) based on the IPCC Fifth Assessment Report and mapped to AR6 SSPs were analyzed, representing global warming of 1.5 degrees C, 2-3 degrees C, and >4 degrees C increase in the global average surface temperature by 2100", assessed for present day, 2030 and 2050 (p.217).

Methodology is asset-level: insurance-industry climate risk models plus "tailored value-at-risk modeling for direct physical damage and business interruption", drawing on "WTW's Global Peril Diagnostic and Climate Diagnostic tools, Munich Re hazard data, and IPCC research" (p.218). The study ran over 2022-2023 and was refined in 2024-2025 by "mapping key supplier exposures" (p.217).

Gap: the named scenarios are physical-risk RCP pathways. No transition scenario is named, so transition risks are mapped qualitatively only.

Reference: page 217, with pages 201 and 219-220

Back-filled from ESRS 2 SBM-3 and the E1 SBM-3 subsection headed "Resilience in relation to climate change", where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience statement is explicit about the mismatch between Bekaert's trajectory and the policy trajectory: "By adopting 1.5 degrees C-aligned targets for our own operations, while the stated government policies trend above 2 degrees C, we demonstrate that resilience and long-term sustainability are at the core of our strategy" (p.217, footnoted to the UN Emissions Gap Report 2024). Five steps are integrated into strategic planning "looking at medium-term impact (up to 2030)", including applying "a structured approach and adopt different scenarios", and considering "the entire value chain and all our material physical and transition risks and opportunities".

Adaptive capacity is described hazard by hazard on pages 219-220, with current risk, the 2050 RCP8.5 projection and the response. "We will define the necessary investments to address these risks and implement them through a phased risk-based approach" (p.219).

Two limits: the results are qualitative, with no value-at-risk figure published although the methodology says one was modelled (p.218); and areas of uncertainty are not labelled as such, though the dependencies at pages 196 and 226 serve that purpose.

Reference: page 220

"Our goal is to protect the planet with two focus areas in mind: making Bekaert a more sustainable company and contributing to a more sustainable world with our sustainable solutions. Our ambition is to reduce our carbon footprint by increasing our use of renewable energy and improving our energy efficiency" (p.220).

The policy instrument and its governance are named: "Our energy and climate change policy is designed to align our organization with our decarbonization roadmap. The policy applies to all consolidated Bekaert operations and businesses. The Chief Operating Officer (COO) oversees formulating the policy. Divisional CEOs with the support of the relevant corporate functions are responsible for ensuring this policy is implemented in their respective business and operations. The policy is available in English on our website" (p.220). The incorporation-by-reference table confirms that the policy text itself sits on the website (p.191).

This is the full extent of the E1-2 disclosure, which is short for a policy DR. It does not name third-party standards or initiatives the policy refers to, does not say whether stakeholder interests were considered in setting it, and is silent on whether the policy covers adaptation as well as mitigation despite the DR title.

Reference: pages 221-226

The most quantified part of the climate chapter. "We have developed a decarbonization roadmap, covering the period from our baseline year 2019 to 2030, in line with the end year of our Scope 1 & 2 CO2e SBTi approved target and compatible with limiting global warming to 1.5 degrees C" (p.221). Progress and remaining effort are both sized: "In the period 2019-2025, our actions led to a reduction of CO2e emissions by about 380 000 tons", and "By 2030, we aim to reduce an additional 590 000 tons of CO2e emissions by various levers. Around 57% of this future effort is covered by already defined actions."

Resourcing: "we have spent over 9 million EUR in 2025 and estimate spending over 40 million EUR in cumulative Capex over the coming years ... Based on current levers in place, there is no significant Opex to be reported" (p.221).

Renewable electricity reached 40% of consumption, and the PPA and on-site table names every asset with annual output and abatement, for example "Kings Plain, US (wind farm) installed in 2020" at 125 GWh/year and 41 500 t CO2e (pp.221-222).

The You Know WATT efficiency programme reports 3 sites covered, 89 new initiatives identified, 225 implemented and 41 kt CO2e saved in 2025 (p.223). On Scope 3, "66% of our wire rod suppliers now provide direct, comprehensive emissions data, representing over 70% of upstream Scope 3 emissions linked to wire rod" (p.224).

Reference: page 226

Two SBTi-validated targets plus a net-zero ambition. "Absolute scope 1 ... and market-based scope 2 ... target: we target to reduce our combined absolute emissions by 46.2% by 2030 compared to 2019 baseline year. This target is in line with the 1.5 degrees C-target defined in the Paris agreement of 2015." And "Absolute scope 3 (Category 1 purchased goods and services) target: we target to reduce scope 3 emissions from purchased goods and services by 19.7% reduction by 2035 compared to 2019 baseline year. This target is aligned to a 2 degrees C pathway" (p.226). In addition, "we aim to achieve Carbon Net Zero by 2050".

The table gives absolute values: Scope 1 and market-based Scope 2 of 1 650 627 tCO2e in 2019 falling to 888 037 tCO2e by 2030; Scope 3 purchased goods and services of 5 077 121 tCO2e falling to 4 076 928 tCO2e by 2035.

Progress is reported against both: Scope 1 and market-based Scope 2 "reduced by 23% compared to 2019, in line with our roadmap", and Scope 3 purchased goods and services "reduced by 11% compared to 2019". Relevant gases are CO2, CH4, N2O and HFCs, "with emissions of all other GHGs being zero". Note the Scope 3 target is 2 degrees C aligned rather than 1.5, and covers Category 1 only.

Reference: pages 227-228

Total energy consumption was 3 807 860 MWh in 2025, down from 3 894 661 MWh in 2024 and 4 481 545 MWh in the 2019 base year. The mix: fossil 2 595 859 MWh (68%), nuclear 237 884 MWh (6%), renewable 974 117 MWh (26%), of which self-generated non-fuel renewable energy 50 445 MWh (p.227). Natural gas at 1 178 517 MWh is the largest fossil line; fuel from renewable sources including biomass and hydrogen is zero.

"All of Bekaert's activities are classified as high climate impact sectors as our activities belong to sector 'C Manufacturing' of Annex I to Regulation (EC) No 1893/2006" (p.227). Energy intensity for those activities was 1 028 MWh per million EUR net revenue, up from 984 in 2024 and down from 1 167 in 2019 (p.228). Renewable electricity was 40% of electricity needs, against 41% in 2024.

On contractual instruments: "In 2025, 12.1% of the purchased electricity came from contractual elements such as onsite PPAs, offsite (v)PPAs and green tariffs. We do not use unbundled electricity attribute certificates" (p.227). Estimation is disclosed: "Some figures for the last months of the year 2025 have been estimated (<5% of data)", grid renewable shares are estimated from Ember country data, and fuel consumption is extrapolated from one representative plant.

Reference: pages 229-234

Full inventory against a 2019 base year and a 2024 comparative. Gross Scope 1 was 243 656 tCO2e (2024: 247 835; 2019: 291 248). Gross Scope 2 was 1 075 346 tCO2e location-based and 1 027 860 tCO2e market-based. Total gross Scope 3 was 5 418 848 tCO2e, and total GHG emissions 6 737 850 tCO2e location-based and 6 690 364 tCO2e market-based (p.229).

All fifteen Scope 3 categories are listed with values or zeros. Purchased goods and services dominates at 4 518 323 tCO2e, then fuel and energy-related activities at 295 091, capital goods 120 674, processing of sold products 119 300, downstream transportation 106 994 and use of sold products 61 469.

Combined Scope 1 and market-based Scope 2 fell to 1 271 516 tCO2e: "Our Scope 1 & market-based scope 2 emissions were 23% lower than our reference baseline 2019, in line with our roadmap to meet our target." Total intensity was 343 tCO2e per million EUR net revenue market-based, against 430 in 2019, though up from 323 in 2024.

Two method points: "We are not under any regulated emission trading schemes (ETS) ... We are not emitting biogenic emissions" (p.230); and "Due to new emission factors, improved methodology, accuracy and coverage of emission estimates for a number of categories, our scope 3 data for all years disclosed have been updated" (p.234). Scope 2 uses IEA country factors (p.231).

Reference: page 234

A nil return, and a complete answer to the disclosure requirement: "GHG removals and GHG mitigation projects financed through carbon credits are not applicable to Bekaert", tagged to ESRS E1-7 paragraphs 56, 58 and 59 (p.234).

The Content Index lists E1-7 at page 234, so this is a claimed disclosure rather than an omission (p.276). It is consistent with the rest of the climate chapter: the E1-4 targets are absolute reduction targets with no removals or credits component. BP-2 also names the EU Climate Law as the only Appendix B EU legislation applicable to Bekaert, cross-referring to "section E1-1 on page 214 and section E1-7 on page 234" (p.190).

A reader should note the boundary of the nil statement. It rules out removals in own operations and the value chain and any use of carbon credits, but it does not separately address whether the abatement figures in the E1-3 renewable energy table rest on market instruments beyond the contractual elements disclosed under E1-5, where Bekaert states that 12.1% of purchased electricity came from onsite PPAs, offsite (v)PPAs and green tariffs and that "We do not use unbundled electricity attribute certificates" (p.227).

Reference: page 234

"We have developed an internal carbon price within our internal global capital expenditure program. An internal carbon price of 100 EUR/Ton CO2e is being used as a shadow price when calculating the business case for capital projects and is applied for Scope 1 and 2" (p.234).

Bekaert explains both calibration and application. On calibration: "We benchmarked against projected ETS prices, industry studies and peers to define the current appropriate internal carbon price for Bekaert." On where it bites: "Due to the fact that the majority of our Scope 1 and 2 emissions is related to our production processes, we mainly apply the internal carbon price for portfolio selection of capital projects as these have the largest impact on our carbon footprint."

Two limits are visible. The price is a shadow price for investment appraisal, not an internal fee or transfer charge, so no funds are raised or redistributed. And it covers Scope 1 and 2 only, which leaves the 5 418 848 tCO2e of Scope 3 emissions reported under E1-6 outside the mechanism, including the purchased wire rod that drives more than 75% of upstream Scope 3 (pp.229, 224). Bekaert does not state the share of gross emissions or of capital expenditure covered by the price, nor how the price is expected to change over time.

Reference: page 235

The policy is the group Safety, Health and Environment policy, titled in the index as "Policies related to pollution" and in the chapter as "Policies related to substances of concern". "Via our Safety, Health and Environment policy, Bekaert is committed to protect the people and the environment including prevention of pollution and management of substances of concern. The Bekaert Safety, Health and Environment policy applies to all employees and anyone working at or visiting our premises" (p.235). Management sets the framework for objectives and targets and ensures employees, contractors and visitors comply.

Two specifics lift this above a generic statement. Internal limits that can exceed law: "we have 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 we operate in." And external anchoring: "Our production plants operate in accordance with their environmental permit and the company's environmental management system. We operate our assets globally in accordance with ISO 14 001 and, where applicable, ISO 45 001 and their relevant emergency procedures" (p.235). The policy text itself is on the website (p.191).

Reference: pages 235-236

Actions are built around a product stewardship framework covering "standardized chemical management, environmental compliance of both raw materials and finished products, and related customer expectations" (p.235).

The operational core is a global standard with a supporting tool: "We have a global chemical management standard and a global chemical management software tool in place which allows an efficient implementation of the standard, a strict governance process, inventory management and more proactive chemical product compliance. Our chemical management software tool has been deployed in all production sites to keep track of use and control of chemicals, including substances of concern." Exposure is monitored rather than assumed: "we monitor at least on a yearly basis the exposure of employees to these substances of concern to assure exposure is limited to the minimum."

On regulation and substitution: "At Bekaert, we closely monitor the EU REACH regulation to confirm compliance in a proactive way related both to the raw materials we are using and to our finished products ... Furthermore, we identify substances of concern and start proactive phase-out programs" (p.236). Where regional hazard classifications differ, Bekaert applies its own classification and exposure limits as the mandatory floor, supported by "A dedicated regulatory team ... at corporate level". No spend figure is attached to the E2 actions.

Reference: page 236

Bekaert answers the targets requirement with a stated absence and a reason, which is a complete MDR-T answer rather than a gap: "We have not set specific external targets on substances of concern, as we follow a risk-based approach supported by internally defined exposure limits for relevant hazardous chemicals and agents. This ensures a consistent and high level of care for all employees worldwide" (p.236). The section is tagged to ESRS E2-3 paragraph 23d, the provision covering the case where no target is set.

The framing is occupational rather than environmental: "Bekaert's global safety approach aims to create a no-harm-to-anyone working environment", and the control mechanism is the internal exposure limit standard described under E2-1, which is "in line with, and at times go beyond, the most stringent limits in any of the countries we operate in" (p.235).

What a reader should take from this: progress on the material hazardous substances IRO is not tracked against any numeric or dated objective, and no proxy measure of effectiveness is published in the E2 chapter. The closest quantified series, the hazardous waste intensity target of minus 25% by 2030 from 37.7 kg per tonne in 2019, reaching 31.7 kg per tonne in 2025 (p.245), is presented under E5 and not under E2.

Reference: page 236

Bekaert answers both limbs of ESRS E2 paragraph 34 and presents substances of very high concern separately as paragraph 35 requires. Inflow: substances of concern procured were 18 536 tonnes in 2025 (2024: 17 996), and substances of very high concern procured 801 tonnes (2024: 1 033). Outflow: "Amount of substances of concern that leave facilities as part of products" was 15 237 tonnes (2024: 14 579), and for substances of very high concern the figure is zero in both years (p.236).

Hazard classes are given: the substances of concern fall under "chronic hazard to the aquatic environment" and the substances of very high concern under "reproductive toxicity", with the note that "substances of very high concern are a subset of substances of concern. Hence substances that belong to both hazard classes are disclosed in each category."

Scope and method are disclosed: "In scope for our data collection are the amounts of base metals procured and the amounts of these metals remaining on our products produced", used for coating steel wires or as a production aid, and "The amount of substances that leave our facility have been calculated by multiplying the procured volumes with average scrap rates." Bekaert limits its own figures, excluding substances present in mixtures and cautioning that "the hazard class of the reported substances does not reflect the actual risk to the environment or human health", since the metals are solids rather than water-soluble salts.

Reference: page 237

"At Bekaert, we are committed to reducing our impacts related to water withdrawal, consumption and discharge, especially in water stressed regions", via three named commitments: "Monitoring water withdrawal, including the use and sourcing of water in our operations; Building internal awareness on the importance of water conservation; Implementing programs to reduce our water usage in both production processes and supporting cooling processes, including reuse and recycling of water" (p.237).

Discharge quality is addressed: "After use and reuse many times over, water that cannot be further recycled is treated according to best industry practices and compliant with local legal requirements before it leaves our premises", and a risk management programme is in place "to prevent water pollution resulting from our operations".

Governance mirrors the other environmental policies: "Our water policy is designed to align the organization with our water target. It applies to all consolidated operations and businesses. The Chief Operating Officer oversees formulating the policy. Divisional CEOs with the support of relevant corporate functions are responsible for ensuring this policy is implemented", and the policy sits in the Bekaert Document Management System and in English on the website. The disclosure does not address marine resources, consistent with the IRO table, which identifies water use and access rather than any marine impact (p.199).

Reference: page 238

Actions fall into three operational categories within production sites: "Infrastructure-related consumption (e.g. water leakage management, control of evaporation losses, steam condensate reuse)", "Process water use (e.g. conductivity-controlled rinsing, wastewater recovery)" and "Sanitary water controls (e.g. water saving faucets in bathrooms)" (p.238).

A named site example is given: "One of our sites in Turkey started using recycled industrial wastewater (from the municipality line) instead of well water in our operations. By shifting to recycled water, we are significantly reducing our impact on local groundwater resources."

Delivery runs through the same programme as energy: "Our program You Know WATT moves from plant to plant, supporting local teams in building awareness on water savings and identifying water consumption saving opportunities. Water savings programs are prioritized with focus on water stressed areas and included in our Capex roadmap."

Resources are quantified, modestly: "In 2025 a total of 146 000 EUR was spent on water saving projects. Additional water saving projects are planned", footnoted to Property, Plant and Equipment in Financial Statements section 6.3. Cumulatively, "Since 2021 we implemented 39 water savings projects and saved 0.27 m3 per ton product."

Reference: page 238

A single quantified, dated target with progress against it: "Our ambition is to reduce our relative freshwater intake in water stressed areas by -15% by 2030 compared to 3.87 m3/ton in 2019. This target has been set on a voluntary basis. At the end of 2025, we reached 3.49 m3/ton or -10% reduction versus 2019, compared to 3.56 m3/ton at the end of 2024 or -8% versus 2019" (p.238). Footnotes define the basis: relative means measured against tonnes of final product produced, and "Reducing freshwater intake offers the most significant impact taking into account the characteristics of our industry."

The lever is named: "One of the key levers for this reduction is our practice of recycling and reusing water multiple times until it can no longer be recycled."

Bekaert links the target to the impact it addresses: it "focuses on reducing the impact of our operations especially, but not limited to, water stressed areas as well as on safeguarding the water quality via treatment of water before it leaves our facilities."

Two points of substance. The target is intensity-based and restricted to freshwater intake in water-stressed areas, so it does not cap absolute group withdrawal, which was 6 372 875 m3 in 2025 (p.239). And progress is slightly ahead of a straight line to 2030, with 10 of the 15 percentage points delivered by the end of 2025.

Reference: pages 239-240

"Total water consumption was 3 342 902 m3 of which 1 699 977 m3 from areas with water stress", against 3 477 816 m3 in 2024 (p.239). Consumption is defined as total withdrawal minus total discharge. Intensity was 902 m3 per million EUR net revenue, up from 879 in 2024 and 782 in 2023.

Withdrawal and discharge are given in full. Total withdrawal was 6 372 875 m3 (2024: 6 588 020; 2019 baseline: 7 960 995), of which 2 811 357 m3 from areas with water stress, split by source into surface water 398 743 m3, groundwater 1 520 007 m3 and third-party water 4 454 124 m3. Total discharge was 3 029 973 m3, of which 1 111 380 m3 to areas with water stress, broken down by destination across surface water, sea water and third-party water and split between freshwater and other water (pp.239-240).

Two further metrics: "Total water recycled and reused" was 100 186 m3, which Bekaert qualifies as "only for plants with zero liquid discharge", and total water stored was 2 800 m3 with no change in storage.

Definitions and method are stated: water stress is where "the ratio of total annual water withdrawal to total available annual renewable water supply is high (40-80%) or extremely high (>80%)", and "Water withdrawal data and water discharge data were calculated based on either invoices or water meter readings."

Reference: pages 241-242

"Bekaert's Resource Use and Circular Economy Policy outlines our commitment to minimizing the use of virgin materials, enhancing resource efficiency, and embedding circularity across our value chain", built on two pillars (p.241).

Sustainable Operations: "We prioritize the use of recycled materials in manufacturing to reduce reliance on virgin resources. By implementing systems that recycle and reuse materials like water and packaging, and partnering with local recyclers to achieve 100% recycling of steel scrap, we minimize waste and optimize resource use."

Sustainable Solutions: "We design our products with durability, recyclability, and adaptability in mind, reducing both waste and the carbon footprint of our customers. While we do not have control over the end-of-life of our solutions, our focus on circularity enables us to collaborate with partners across the value chain to develop and implement circular business models." Bekaert grounds this in the material: "Products made from steel can significantly contribute to a circular, low carbon future because steel is the most recycled material globally."

The policy is framed against a named external framework: "Through these efforts based on the 9Rs framework (Refuse, Rethink, Reduce, Repair, Refurbish, Remanufacture, Repurpose, Recycle and Recover), Bekaert addresses material impacts and risks." The COO oversees formulation, Divisional CEOs implement, and the policy is on the website (p.242).

Reference: pages 242-244, 247

Actions split between sustainable operations and sustainable solutions. On inputs, the priority is wire rod, which "represents more than 75% of the related emissions (based on 2019 emissions)", and Bekaert adopts "techniques in our product and process design that support the use of scrap-based steel wire rod" (p.242).

Packaging actions are quantified: "In 2025, we achieved high spool reuse with 97% of tire cord spools being reused. 100% of the tire cord cardboard boxes we purchase and use in China, India, and Indonesia are made from recycled paper"; one project cut cardboard layers "resulting in savings of more than 100 tons of material", another reduced plastic bag thickness by 20% while increasing recycled content by 30%, and a project is cutting plastic pallet weight by 9% (p.244).

Waste actions: a waste acid recycling unit at Weihai (China) "reduces the disposal of hazardous waste acid from this plant's operation by more than 75%". Cumulative waste reduction projects rose from 4 in 2022 to 35 by 2025, delivering 6.81 kg less hazardous waste per tonne of end product, and "In 2025 a total of 334 000 EUR was spent on waste reduction projects."

Product initiatives include Dramix Loop, "second-life steel fibers for concrete reinforcement made entirely from end-of-life tires", third-party LCA and EPD certified (p.242), and a Bridon-Bekaert Ropes Group pilot in Chile recycling used mining shovel ropes into low-carbon construction steel (p.247).

Reference: page 245

Two quantified targets, both voluntary. On solutions: "We aim to achieve 65% of our consolidated sales from sustainable solutions by 2030. In 2025, we reached 49%. These solutions are defined and classified according to the EU Taxonomy ... This target has been set on a voluntary basis" (p.245). On operations: "Bekaert has set a target to reduce the quantity of its three main categories of disposed hazardous waste relative to the amount of final product with 25% by 2030 compared to 37.7 kg/ton in the base year 2019. At the end of 2025, we reached 31.7 kg/ton or -16% reduction compared to 2019." Bekaert places the waste target in the regulatory hierarchy: "This target focuses on the layer 1, prevention of waste, of the waste hierarchy cfr. Article 4(1) of the Directive 2008/98/EC on waste."

Four further focus areas carry no numeric target, including "Partnering with local recyclers: Ensuring 100% recycling of steel scrap."

Bekaert qualifies the solutions target twice, and a reader should weigh both. In the text: "Although fundamentals remain sound, we are experiencing rephasing of customer projects and delays in clean-energy deployment, which affect short-term momentum." And in footnotes: "We will evaluate our ambition and targets as part of our next strategic planning cycle", and "The internal criteria for classifying sustainable solutions are under review to align with frameworks used by peers."

Reference: pages 245-246

"Our major material resource inflows consist of steel wire rod, base metals (primarily copper, zinc) and packaging. These are the materials we determined most relevant to track in terms of circularity as they are the core materials used in the majority of products we deliver to our customers, are connected to finite resources and have high potential for recycling and re-use" (p.245). Other materials named but not tabled are lubricants, other chemicals, polymers and plastics.

The table gives tonnage and recycled share. Wire rod: 1 920 132 tonnes in 2025 with 541 166 tonnes (28%) secondary recycled content, against 2 016 119 tonnes and 27% in 2024. Base metals: 20 562 tonnes with 7 352 tonnes (36%) recycled, against 17 928 tonnes and 29%. Packaging: 46 341 tonnes with 3 958 tonnes (9%) recycled, against 36 008 tonnes and 5% (p.246). Both restatements are footnoted: wire rod 2024 values were updated "due to broader scope and updated recycled-content information."

Method and coverage are disclosed: "Applying the ISO 14 021 definition, the total of pre-consumer and post-consumer recycled content in wire rod was 28% in 2025", from granular supplier data supplemented by international databases and steel-making-technology estimates. For base metals, "we covered more than 99% of the base metals volume." Packaging is ferrous metal spools, paper and cardboard, plastic and wood, and "We do not source any biological materials."

Reference: page 246

The resource outflows disclosure on products and materials is qualitative throughout, and Bekaert explains why in each case rather than leaving gaps unexplained.

On durability: "The majority of our products are embedded in end-products, making it challenging to provide publicly available industry averages for each product group. However, we ensure that our products are designed for long-term durability, aligning with or exceeding industry standards where applicable" (p.246).

On repairability: "Due to the nature of our product offerings, which are often integral components of larger systems or products, the repairability of the final product or solution is out of our control. Consequently, no established rating system for repairability exists for our products."

On recyclable content: "While we do not have direct control over the end-of-life of our solutions, we strive to collaborate across the value chain with circularity in mind. Our primary raw material, steel, is the most recycled material globally. It should be technically possible to recycle our steel products at the end of their lifecycle."

Bekaert opens by pointing to the design work behind this: "We integrate circular economy principles into the design of our production processes and products, focussing on durability, material efficiency and compatibility with established recycling routes." No rates for recyclable content, recycled content in products or expected durability are published.

Reference: page 247

Bekaert reports the ESRS E5-5 waste datapoints in a separate subsection headed Waste, with a full table for 2024 and 2025.

Total waste generated in 2025 was 87 623 tonnes hazardous and 111 175 tonnes non-hazardous, against 90 860 and 100 549 tonnes in 2024. Diverted from disposal: recycling took 64 349 tonnes of hazardous and 102 819 tonnes of non-hazardous waste, and incineration with energy recovery 479 and 278 tonnes; preparation for re-use was nil in 2025, against 2 014 tonnes hazardous and 1 927 tonnes non-hazardous in 2024. Directed to disposal: landfill 18 667 tonnes hazardous and 7 950 tonnes non-hazardous, and incineration without energy recovery 4 127 and 128 tonnes. Total non-recycled waste was 31 630 tonnes, or 16%, down from 33 272 tonnes and 17% (p.247).

The headline claim is consistent with the table: "All steel scrap from our processes is being recycled and returned to steel mills for reuse ... In 2025, 84% of all our total waste generated is being recycled."

Composition is named: the main hazardous contributors are "Spent acid from pickling of steel wires", "Spent water based lubricants from wire drawing" and "Sludge from our wastewater treatment plants, containing metal hydroxides", while non-hazardous waste "consists mainly out of scrap metal and packaging material". Quantities are calculated from "invoices from waste handling companies or certificates from local authorities". Radioactive waste is not mentioned.

Reference: pages 249-250

Seven policy instruments are described, each with an owner and an approval level, which is a stronger-than-average S1-1 disclosure.

The Human Rights Policy commits Bekaert to "alignment with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions identified in the Declaration of the International Labor Organization on Fundamental Principles and Rights at Work and the International Bill of Human Rights", as its means of implementing Article 18 of the EU Taxonomy Regulation. It "has been approved by the Executive Management" (p.249).

The Code of Conduct "covers, among other elements, key areas regarding human rights, non-discrimination, child labor and forced labor, cybersecurity and data privacy, ethics and integrity principles in the workplace", was approved by the Board of Directors, and is "available on our website in the language of the countries where we operate".

The rest are a global hybrid working guideline, a global parental care program setting "a minimum parental leave standard across all countries", diversity and inclusion principles, a global learning and development procedure, and the Safety, Health and Environment policy approved by the CEO (p.250).

Reference: page 251

Engagement is reported with figures rather than description alone: "Bekaert conducts a global employee engagement survey annually ... The survey is run by an external provider ensuring that all input is confidential. In 2025, we reached a participation rate of 84% (+3% compared to 2024) and an engagement rate of 72% (+3% compared to 2024)" (p.251). Results feed improvement goals directly. Other channels include quarterly CEO and CFO webcasts at financial news releases, global, regional and business-unit Town Halls, the intranet and Viva Engage.

On collective representation: "We recognize the right of any employee to join or to refrain from joining a labor union. 74% of our employees worldwide are covered by collective bargaining agreements." Agreements are concluded locally and typically cover personal protective equipment, the "right to refuse unsafe work", inspections, audits and accident investigations, joint management-employee health and safety committees, working hours, training and education, a complaints mechanism and periodic inspections.

Worker representation in health and safety is structural: "Our integral workforce is represented in our Safety, Health and Environmental Councils which consists of joint management-worker committees that cover health & safety and environmental topics." Operational responsibility sits with the Chief Human Resources Officer. Note the 74% is disclosed here under S1-2, not as an S1-8 metric.

Reference: page 252

"All stakeholders, such as employees and external stakeholders including members of local communities and workers along Bekaert's value chain are able to and encouraged to raise their integrity concerns and/or grievances via the Speak Up tool" (p.252).

Awareness is described concretely: the Speak Up process features in the Code of Conduct e-learning in approximately 15 languages, "Other employees, mainly operators, are informed during onboarding and reminded on a regular basis afterwards", and a continuous campaign runs through materials in offices and plants.

On handling and remedy: "Our Investigation Protocol ensures the quality and consistency of our investigations ... Remedial measures are taken for all substantiated cases and for those cases where improvement areas are revealed", with anti-retaliation measures, and Group Ethics and Compliance "reports internally on the higher risk or negative impact cases to the Regional and Group Compliance Committee."

Volume is reported: "In 2025, 149 integrity allegations were reported through our integrity reporting channels." No outcome breakdown or substantiation rate is published, and Bekaert does not report whether it tracks worker trust in the channel.

Reference: pages 252-257

Human rights actions follow a 2024 assessment that identified, "in line with the requirements of the United Nations Guiding Principles on Business & Human Rights, the potential and actual most severe adverse ('salient') human rights impacts in Bekaert's operations and value chain": the right to life and health "related to industry specific safety exposures", and the right to freedom of thought, conscience and religion arising from the geographical footprint.

Health and safety dominates, and Bekaert does not soften it: "Three fatal work-related accidents happened in Bekaert in 2025 ... Thorough root cause investigations have been performed and we have renewed our absolute commitment to safety" (p.253).

BeCare framework actions include a review of five global safety standards, among them Permit to Work and Working at Heights; "During 2025, 40 sites were visited by the Group SH&E team for inspections using a standardized methodology"; ten Life-Saving Rules; and a global safety climate assessment using the "NOSACQ-50" methodology (pp.253-254).

Well-being and development actions include an employee assistance program to which "100% of the employees in the Bekaert subsidiaries have access", and Bekaert University with "over 400 courses ... organized in 11 active Bekaert Academies" (pp.255-256).

On resources, the funds "are integrated into the budgets of the respective functions or business units", so no spend figure is given (p.257).

Reference: page 257

Three quantified targets with current performance, and one material sub-topic tracked without a numeric target.

Mental health: "We want 100% of the employees in the Bekaert subsidiaries to have access to this employee assistance program ... We have achieved this target."

Learning and development: "Bekaert is committed to provide a minimum of 30 hours training on average per employee annually. In 2025, on average each employee received 34 hours of training", monitored through the learning management system and "consolidated on a quarterly basis".

Gender diversity: "Our target is to achieve a ratio of 40% by 2030. 28.4% of the managers and salaried professionals of the Bekaert subsidiaries are female (as per year-end 2025), compared to 29% at the end of 2024, a slight decrease mainly driven by the divestment of our Steel Wire Solutions activities in Costa Rica, Ecuador and Venezuela." A footnote adds that Bekaert "will evaluate our ambition and targets as part of our next strategic planning cycle".

Health and safety, the sub-topic carrying the fatalities reported under S1-4, has no numeric target: "Bekaert aims to create a no-harm, risk-free working environment ... We track our performance against this aim through a central management system. Safety performance is part of our performance dashboard and is a fixed agenda topic during local and global town halls".

Reference: pages 257-259

Headcount at 31 December 2025 was 18 421 employees, 15 896 male and 2 525 female, with the note that "The category 'other' and 'not reported' are not applicable" (p.257). The fall is explained: "The overall number went down from 19 701 in 2024 mainly due to the divestment of our Steel Wire Solutions entities in Costa Rica, Ecuador and Venezuela and smaller footprint changes in other regions."

Two countries meet the ESRS threshold of at least 50 employees representing at least 10% of the total: China with 6 350 and Slovakia with 2 006.

Contract and working-time breakdowns are given by region and gender: 16 491 permanent and 1 930 temporary employees, 18 213 full-time and 208 part-time, and no non-guaranteed-hours employees in any region. In summary, "90% of people employed by Bekaert have a permanent contract ... 10% has a temporary contract", and "99% of the Bekaert employees work full-time" (pp.258-259). A voluntary breakdown shows 13 574 blue collars, 3 303 salaried professionals and 1 544 management.

Turnover is reported twice over, which is useful: 642 voluntary leavers (4%) and 1 246 taking into account all personnel exits including dismissal, retirement and death in service (7%), with a female all-exits rate of 10% against 7% for men (p.259). Full-time equivalents are cross-referenced to Segment Reporting on page 101.

Reference: page 259

"Non-employees are workers who are not on our payroll, but who complement our employee workforce. They provide temporary services mostly through agencies or consulting firms" (p.259). Headcount at 31 December 2025 was 701, comprising 599 male and 102 female, broken down by region and category: 638 blue collars, 49 salaried professionals and 14 management, with Asia Pacific the largest region at 535 and EMEA next at 89.

The year-on-year movement is explained and sizeable: "In 2025, the number of non-employees was aligned with capacity needs (down from 1 094 in 2024)." Working time is given: "98% of the non-employees work full-time."

The S1 SBM-3 definition is consistent, and Bekaert states that "Our disclosures cover all individuals within our own workforce who could be materially impacted" (p.248).

Two points for a reader comparing years. The table does not distinguish self-employed people from workers provided by employment agencies, which ESRS S1-7 asks for separately. And on-site contractors, who are not in this 701, are nonetheless included in the safety metrics: "Although contractors are considered 'Workers in the value chain (S2)' according to ESRS, we include contractors working at our sites in our safety data" (p.264), and two of the three 2025 fatalities were contractors (p.262).

Reference: page 260

Gender diversity is reported at four leadership levels for both 2025 and 2024, which makes the direction of travel visible. Board of Directors: 11 people, 7 male and 4 female, 64% to 36%, against 9 people at 56% to 44% in 2024. Executive Management: 8 people, 7 male and 1 female, 87% to 13%, against 9 people at 78% to 22%. Senior Vice Presidents (B16-B18): 14 people, 86% to 14%, against 93% to 7%. Next leadership level (B13-B15): 61 people, 75% to 25%, against 76 people at 76% to 24%. Total leadership team: 94 people, 77% to 23%, unchanged in percentage terms from 108 people in 2024 (p.260).

Age distribution is given for the whole employee population and by category: "Total Bekaert employees" 11% under 30, 70% aged 30 to 50 and 19% over 50. Management skews older at 3%, 66% and 31%, while blue collars are youngest at 13%, 70% and 17%.

A reader should note two things. Female representation at Executive Management fell in absolute terms, from 2 of 9 to 1 of 8, while the Board moved from 4 of 9 to 4 of 11, so both top-table ratios worsened in 2025 even as the Senior Vice President level improved from 1 to 2 women. And the 23% leadership figure is not the same population as the 28.4% female managers and salaried professionals reported against the 40% by 2030 target under S1-5 (p.257).

Reference: page 260

"We offer competitive salaries and benefits designed to enhance the financial, physical and overall well-being of our employees and their families. Our offerings differ from country to country and are often adapted to local social security policies. We provide a wide range of employee benefits that may include retirement benefits, healthcare plans, service awards, labor accident disability coverage and paid leave", with detail cross-referenced to Financial Statements section 6.16 (p.260).

A benefits matrix is given for the five significant locations, defined as "locations with > 1 000 employees on the payroll (part-time, full-time, definite, indefinite)".

Bekaert states the scope limit plainly: "These benefits are applicable to (payroll) employees - not to non-employees", which excludes the 701 non-employees reported under S1-7 (p.259).

On statutory cover: "Bekaert complies with all applicable local social security schemes in each country where it operates. Employees are covered in accordance with the mandatory social protection schemes of their country of employment." Note the disclosure is organised by benefit type rather than by the ESRS major life events framing, and covers only the five largest countries.

Reference: pages 261-262

Two metric sets. On performance reviews: 99% of managers received a review in 2025, male and female alike, and 98% of salaried professionals, giving totals of 98% for both men and women (p.261). Bekaert states what this excludes and why: "Operators do not follow the People Performance Process that applies to our salaried professionals. Operators discuss performance on a very frequent basis, in local meetings", covering quality, safety and process improvements plus one-on-one sessions with shift leaders. Since blue collars are 13 574 of 18 421 employees (p.258), most of the workforce sits outside the reported percentages.

On training: "On average, each employee received 34 hours of training in 2025 of which 33 for female employees and 34 for male employees, well above our target" of 30 hours (p.262). A three-year table breaks hours down by region, category and gender, showing for example EMEA blue collars at 49 hours male and 40 female in 2025. Composition is given: 4 hours of mandatory training, 7 hours of safety training and approximately 0.5 hour of well-being training per employee.

Method is disclosed, including a quirk worth noting: "Calculation methodology: Total number of training hours divided by headcount (including employees and non-employees) at 31 December 2025", so the denominator is wider than the employee population used in S1-6, and training hours of the divested Costa Rica, Ecuador and Venezuela entities have been excluded.

Reference: pages 262-264

Bekaert reports the safety outcome in full, including the year's worst result. "In 2025, three fatal work-related accidents occurred on our premises (one employee and two contractors). Two fatalities were related to working at height and one resulted from electrocution. We recorded four serious injury accidents, three involving hand and finger injuries, and one fore-arm injury" (p.262).

Rates moved in two directions: "The combined 2025 safety-related key performance indicators show a decrease in LTIFR (-37%), and in TRIR (-24%). These improvements were however overshadowed by an increase in our SI rate (+30%). The number of serious incidents resulting in fatality or life-altering injuries rose from six in 2024 to seven in 2025." For consolidated entities plus on-site contractors, TRIR fell to 3.22 from 4.69, LTIFR to 1.75 from 2.91, and the serious injury rate rose to 0.11 from 0.08.

Absolute counts: "In 2025, we had 181 recordable work-related accidents (including joint ventures (JVs)). The number of lost days resulting from work-related injuries reduced from 6 651 in 2024 to 3 569 days in 2025 ... The number of days lost from fatalities was 1 095 days."

Coverage is stated: "All our own workers are covered by our Health & Safety management system" (p.254), with ISO 45001 certification at "31 sites (48% of the manufacturing plants)" (p.263). No work-related ill-health metric is published.

Reference: page 265

Bekaert opens with its own caveat: "While this sustainability matter is not material for Bekaert, we disclose below information for transparency reasons requested by customers, ratings and investors" (p.265). The Content Index lists S1-16 at page 265 and labels it "(not material IRO topic)" (p.277), so this is a voluntary disclosure the company nonetheless claims.

Representation: female share by salary band runs from 13% at Executive Management and 14% at Senior Vice President level, through 25% Senior Management, 18% Mid Level Management and 26% Junior Management, to 31% of Salaried Professionals, for a total of 28%.

Pay gap: "The global Gender Pay Gap at Bekaert is -3.67% (compared to -3.85% in 2024 and -2.40% in 2023)", with EMEA at -4.42%, Latin America at 0.19%, North America at -5.83% and Asia Pacific at -5.67%.

The methodology matters for comparison. "The gender pay gap ratio covers pay gap for salaried and management professionals, and excludes blue collar workers", because blue collar wages are set by local collective labour agreements. Each employee's base pay is compared to the midpoint of their salary band, and "The median of the resulting female compa ratios to the median of male compa ratios are compared, and the difference is the pay gap %." That is a compa-ratio measure within bands, not the ESRS gross hourly pay gap, it excludes most of the workforce, and the annual total remuneration ratio is not disclosed.

Reference: page 266

Again flagged as voluntary: "While this sustainability matter is not material for Bekaert, we are committed to respect human rights. Therefore we disclose below information for transparency reasons" (p.266).

On incidents and complaints, Bekaert reports the channel and the volume: "Bekaert has a central case reporting and investigation management tool in place. The Speak Up channel, which allows all employees and third parties to report concerns or raise questions, is one of several communication vehicles ... In 2025, 149 integrity allegations were reported and investigated through our integrity reporting channels." Investigation quality is governed by the Investigation Protocol, and "Bekaert takes all necessary measures to protect employees against any form of retaliation when reporting a concern."

One category is broken out: "In 2025, two reported cases included allegations of harassment involving female employees. Both matters were investigated by the Ethics and Compliance team, and appropriate remedial actions were implemented."

On severe human rights impacts the answer is a nil return: "There were no human right breaches reported to us connected to our own workforce."

Two gaps a reader should note. The 149 allegations are not broken down by type beyond the two harassment cases. And no figure is given for fines, penalties or compensation for damages resulting from incidents and complaints, which ESRS S1-17 asks for alongside the counts.

Reference: pages 267-268

Three policy instruments cover value chain workers. The Human Rights Policy "reflects our commitment to uphold and advance human rights throughout our operations and across our entire value chain" and "is highly relevant for the way we engage with our upstream supply chain" (p.267).

The Supplier Code of Conduct "outlines environmental, social and governance requirements, that suppliers should comply with. Child and forced labor requirements are included ... The Chief Operating Officer (COO) oversees formulating and implementing the policy." It was revised this year "to ensure alignment with our Code of Conduct, integrate feedback from our stakeholders and adhere to industry best practices", and now "differentiates mandatory requirements from expected goals".

The Policy on Responsible Minerals Sourcing applies to all suppliers delivering minerals "potentially originating from conflict-affected and high-risk areas" (p.268).

Compliance figures are reported for the highest-risk group: "In 2025, 100% of suppliers covered by the Responsible Minerals Initiative (RMI) signed the Bekaert Supplier Code of Conduct ... and 100% of our tin and tungsten suppliers completed a Conflict Minerals Reporting Template (CMRT) ... this group of suppliers are at a high risk of child and/or forced labor."

Reference: pages 268-271

"Bekaert manages supply chain sustainability through a tiered approach which is aligned with our Supplier Relationship Management (SRM) framework. Supply chain due diligence is applicable to all direct suppliers, including adherence to policies and risk assessment" (p.268).

"The process begins with a broad screening and monitoring of all Bekaert's new and existing direct suppliers ... The suppliers we engage are prioritized based on a combination of the risks identified and the dependency in the relationship between our two companies. Adding dependency as a factor ensures that we focus our efforts both where the impact to Bekaert and our end customers is highest and where we have the ability to effect meaningful change." Prioritised suppliers "will typically be invited to complete either a Prewave or SEDEX (Supplier Ethical Data Exchange) questionnaire", leading to action plans or on-site audits (p.269).

On direct engagement with workers, and its limits: "The two primary ways we engage directly with value chain workers is through our Speak Up channel and via on-site audits (2nd and 3rd party)", while most risk-assessment information comes from "official supplier communication channels, adverse media or externally available structured datasets".

Tooling was upgraded at the end of 2024, bringing "full data coverage through inherent risk analysis, targeted deeper AI analysis for higher risk suppliers, automated tier-N mapping" (p.270).

Reference: page 271

Remedy for value chain workers runs through the same central channel as for employees. "Bekaert has 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/or grievances via the Speak Up tool", with detail cross-referenced to S1-3 on page 252 (p.271).

The contractual layer sits alongside it: "The Bekaert Supplier Code of Conduct outlines environmental, social and governance requirements, that suppliers should comply with. Child and forced labor requirements are included. The Bekaert Supplier Code of Conduct is applicable to all suppliers", with further detail in S2-1 on page 267.

From the referenced S1-3 section, the channel supports "confidential two-way communication between Group Ethics and Compliance and any anonymous or named reporter in 15 languages", every allegation is investigated under an Investigation Protocol, and anti-retaliation measures apply (p.252). S2-1 adds that "We provide and enable remedy for human rights impacts on value chain workers through our Speak Up channel and our supply chain due diligence program" (p.268).

What is missing is value-chain-specific evidence of use. Bekaert reports 149 integrity allegations in 2025 in total (p.252) but does not say how many came from value chain workers, and does not report whether those workers are aware of or trust the channel.

Reference: pages 271-272

"Bekaert's 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) is the owner of the supply chain due diligence process, undertaking risk identification and coordinating the overall process. Where necessary, the relevant supplier manager, based upon the category, segment and region of the supplier is responsible to take actions together with the supplier to mitigate identified risks or impacts. Group compliance and the central sustainability team are consulted as and where needed" (p.271).

The action itself is the due diligence process described under S2-2, which Bekaert cross-references.

Audit activity is quantified: "Bekaert annually drafts an audit planning for supplier audits. We conducted 111 supplier audits in 2025 compared to 104 in 2024. Supplier audits are scheduled and prioritized based on quality assurance, changes to or expansions of critical supplier processes, and risk of not meeting the applicable target criteria." Long-term agreements are a further lever: "Concluding Key Supplier Agreements remains very important for the purchase of wire rod and other supply categories."

On resources: "The financial resources required for the listed actions are integrated into the budgets of the respective functions or business units" (p.272), so no spend figure is given.

Reference: page 272

Bekaert replaced its previous targets this year and says so: "In 2025, we replaced our sustainable procurement targets with a new target to align with stakeholder expectations and evolving regulatory requirements: we aim to achieve more than 99% due diligence coverage of our active suppliers, by assessing potential negative sustainability impacts and risks and prioritizing actions. By the end of 2025, we have screened more than 99% of our active suppliers", footnoted as those "with spending more than 5 000 EUR" (p.272).

Three standing expectations accompany the target: "We conduct due diligence screening, prioritize risks, and monitor mitigation actions. We expect our supplier to adhere to the Bekaert Supplier Code of Conduct. We request relevant suppliers to comply with the Bekaert Policy on Responsible Minerals sourcing."

The minerals requirement is specific: "We require our suppliers to provide components, parts or materials containing tantalum, tin, tungsten, gold, graphite, lithium, nickel, copper, cobalt and/or natural mica from conflict and child and forced labor free sources only ... We require our suppliers to complete the Conflict Minerals Reporting Template (CMRT) and Extended Minerals reporting Template (EMRT) ... In 2025, all covered suppliers complied with these requirements."

A reader should weigh what the target measures.

Reference: pages 273-274

Four policies are described with owners and approvers. The Code of Conduct was "approved by the Board", and "In 2025, the Code was further refined to ensure continued alignment with evolving international standards" (p.273).

The Anti-Bribery and Corruption Policy "applies to all Bekaert employees as well as to those representing Bekaert", requiring compliance with "the United Nations Convention against Corruption (UNCAC), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and the local laws in every country in which we do business", and was approved by the Executive Management.

Training is risk-targeted and its scope quantified: "100% of the functions at risk are in scope for the mandatory eLearnings; eg. General Management, Finance, Procurement, Sales, Supply Chain, Plant Maintenance." In 2025 Bekaert also deployed regional e-training on discrimination and anti-harassment, and "All managers completed a newly developed eLearning on Human Rights".

On culture and assurance: "In 2025, we assessed our compliance program by performing compliance health checks. Through surveys and interviews with relevant groups of employees, we assessed the program's effectiveness and identified certain risks and gaps" (p.274), and Group Internal Audit "regularly audits adherence to the respective policies and procedures".

Reference: page 275

Flagged as voluntary, and indexed as such: "While this sustainability matter is not material for Bekaert, we disclose below information for transparency reasons requested by customers, ratings and investors" (p.275).

On training: "We have a mandatory anti-bribery and anti-corruption course in place that all managers at Bekaert and salaried professionals employed in departments that have frequent contacts with third parties must follow bi-annually. The last course was done in 2024 with a completion rate of 100%." Because the cycle is two-yearly, no 2025 completion figure exists, which a reader should note when comparing years.

On reporting lines and escalation: "The Board's Audit, Risk and Finance Committee (ARFC) receives quarterly reviews of Bekaert's compliance program in relation to the Code of Conduct. Higher risk substantiated cases are reported to the Audit, Risk and Finance Committee. High risk and medium risk cases, which were found substantiated are reported to the Compliance Committee that is composed of dedicated members of the Executive Management, on a quarterly basis."

Investigator independence is stated in the adjacent G1-4 section: "The investigator or investigation committee is always separate from the chain of management involved in the matter." Not disclosed: the proportion of functions at risk covered by anti-corruption training by category, or whether the policy is communicated to suppliers in the same terms.

Reference: pages 273-275, 253

Back-filled from the business conduct chapter, where this content is disclosed in the FY2025 report (pages 273-275). G1-3 Targets related to business conduct is a standalone disclosure requirement only from the 2025/2026 ESRS; under the 2023 ESRS the report was prepared against, business conduct targets fell under MDR-T.

Bekaert states no numeric or dated business conduct target. What it does disclose is effectiveness tracking, which is MDR-T's other limb. The clearest example is a formal programme assessment run this year: "In 2025, we assessed our compliance program by performing compliance health checks. Through surveys and interviews with relevant groups of employees, we assessed the program's effectiveness and identified certain risks and gaps. The ultimate aim of this exercise is to further improve our compliance culture and enhance the program's efficiency. We have implemented several improvement actions as a direct result of this risk assessment" (p.274).

Three further mechanisms are reported. Independent assurance: Group Internal Audit "regularly audits adherence to the respective policies and procedures and recommends corrective actions where necessary" (p.273).

Two limits: none of these has a base year and target year, so there is no trajectory to assess; and the long-term incentive ESG basket covers only Scope 1 and 2 CO2e and safety TRIR (p.194), so business conduct carries no remuneration link.

Reference: page 275

Flagged as voluntary and indexed as such: "While this sustainability matter is not material for Bekaert, we disclose below information for transparency reasons requested by customers, ratings and investors" (p.275). The Content Index lists G1-4 at page 275 with the label "(not material IRO topic)" (p.277).

The incident disclosure is specific about number, nature and outcome: "Two allegations reviewed in 2025 involved a breach of Bekaert's Anti-Bribery and Corruption Policy. None of these resulted in a fine nor a conviction for violation of anti-bribery and corruption laws. These breaches concerned the provisions of entertainment or small gifts that did not comply with our policy. Extensive remediation measures were taken following the investigations. The actions underscore our zero-tolerance approach."

The reporting infrastructure is described: a central case reporting and investigation management tool open to employees and third parties, allowing "confidential two-way communication between Group Ethics and Compliance and any anonymous reporter", with alternative routes through HR, Group Legal, Group Ethics and Compliance, Internal Audit or a direct manager.

For context, Bekaert reports 149 integrity allegations across all categories in 2025 (pp.252, 266), of which these two concerned bribery and corruption. No separate nil line is given for convictions and fines beyond the statement that neither case led to one.