Bel SA

The role of the administrative, management and supervisory bodies

Reference: pages 75-77.

Bel SA is administered by a seven-member Board of Directors and a non-voting observer; the Chairman of the Board and the CEO roles have been separated since May 2022. The Board of Directors is responsible for monitoring sustainability impacts, risks and opportunities, relying on Executive Management, which in turn relies on the CSR Operational Committee. A Mission Committee, created following Bel's May 2024 adoption of "Entreprise à Mission" status, "ensures that actions are consistent with the purpose and statutory objectives."

Dedicated CSR bodies include the Investment Committee, Brand Steering Committees, and topic committees (Climate, Water, Regenerative Agriculture, Food Waste, Packaging, Nutrition Scientific, DEI Advisory, Vulnerable Populations, Trust & Ethics). Board members attend a one- or two-day CSR training session every two years (held October 2025, covering nutrition/innovation and social impact/DEI). Following the December 2025 delisting of Unibel shares, Bel's Board appointed a dedicated Audit Committee, which monitors sustainability information alongside financial information.

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: pages 77-78.

The Audit Committee reviews sustainability information and "ensures that processes are in place to identify and analyze CSR impacts, risks, and opportunities, as well as action plans to mitigate them," reporting to the Board, which finalizes the management report on the Committee's recommendations. Each year Executive Management presents its five-year strategic plan, of which CSR commitments are "one of the fundamental pillars"; in 2025 the regenerative agriculture ambition was incorporated for the first time.

Investments above €500,000 go through Investment Committee review including a CSR assessment that "may be decisive for the investment." In 2025 the dedicated CSRD team held quarterly steering committees, presented three progress reports to the Audit Committee including an updated IRO list, and briefed the CSR Operational Committee annually.

Integration of CSR performance into incentive schemes

Reference: page 78.

Senior executives hold a long-term share-based incentive plan with a CSR criterion set by the Board; the plan allocated in 2025 weights water consumption performance at 30% of the plan's allocation criteria. Separately, variable pay (bonuses) for senior executives and eligible employees includes CSR metrics representing at least 30% of variable pay, covering environmental and social matters.

Since 2025 Bel has added a new variable-pay target for its buyers, covering mandatory SBTi training on climate change mitigation and monitoring supplier commitment to decarbonization.

Statement on due diligence

Reference: page 79.

Bel maps the five core elements of due diligence to specific report sections in a table: embedding in governance/strategy/business model (sections 3.1.2, 3.1.3, 3.4.2.3 - Vigilance Plan); collaborating with stakeholders (sections 3.1.3.2, 3.3.1.2.2, 3.3.2.4, 3.3.3.1.1); identifying and assessing negative impacts (sections 3.1.3.3, 3.4.2.3); implementing actions (the "Impact, risk and opportunity management" sections of Environment, Workforce, Governance and the Vigilance plan); and tracking effectiveness (the "Metrics and targets" sections of Environment, Workforce and Business conduct).

The duty of care/Vigilance Plan is "implemented by the Group's Trust & Ethics team" and published within the ESRS G1 section.

Risk management and internal controls over sustainability reporting

Reference: pages 79-80.

Bel's approach draws on COSO framework guidelines for sustainability information, currently covering the risk-assessment and control-activities components, with "all dimensions of the COSO framework relevant to sustainability reporting" to be progressively developed. Identified risk factors are: quality of information, information production processes, and fraud.

In 2025 the Internal Control Department, with the CSR Department, ran a project that mapped existing controls, defined new risk-based controls targeting priority metrics (mostly from the CSR Scorecard), and formalized more than 20 new internal controls into the Group's "BelKey" internal-control framework, to be rolled out via self-assessment from 2026. The Group also operates an IT system for ESG data collection with segregation of input/validation duties and unmodifiable N-1 data. A 2025 fraud management policy "reiterates that internal control helps prevent the risk of fraud."

Strategy, business model and value chain

Reference: pages 80-83.

Bel is a family business of over 160 years, manufacturing dairy, fruit and plant-based portions through five international core brands at around 30 sites on 4 continents. In May 2024 Bel adopted "Entreprise à Mission" status, with its purpose enshrined in its Articles of Association: "By giving people access to healthier and more sustainable food for all, Bel is determined to develop a food model that respects the planet's natural resources..."

The CSR strategy rests on four pillars: Food Transition, Fight for the Planet, Accessible Products For All, and Creating Shared Value For All, each mapped to specific ESRS topics in an infographic (page 82). Products reach more than 415 million people worldwide. In 2025 Bel scored 78/100 in EcoVadis (Gold Medal, top 5% worldwide) and CDP scores of A (climate), A- (water), A- (forest).

Interests and views of stakeholders

Reference: pages 87-90.

Bel maps its main stakeholder groups in a non-exhaustive table (page 87-90): employees, consumers, farmers and partner producers (dairy and fruit), suppliers and subcontractors, customers, investors, NGOs and scientific experts, governments and institutions, academic players, trade unions, and shareholders, each with its dialog mechanisms, topics covered and outcomes cross-referenced to the relevant chapter.

Selected mechanisms include the Farmer's Voice survey, Your Voice employee engagement survey, CDP questionnaires, and partnerships with WWF France, SBTi and the Earthworm Foundation. French and European Works Councils "were consulted on the Company's strategic operations, including the Group's CSR strategy in 2025," during which the double materiality analysis and its results were shared.

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

Reference: pages 92-99 (IRO table); page 103 (materiality matrix).

The 2025 DMA resulted in 144 assessed IROs, of which 70 were rated significant (material), down from 187 total IROs in 2024 following a simplification exercise that merged duplicates and reclassified risks/opportunities into impacts. Material topics are E1, E2, E3, E4, E5, S1, S2, S4 and G1; E3 (water) and S3 (affected communities) were assessed, with affected communities' rights scoring LOW on impact materiality and LIMITED on financial materiality (double materiality matrix, page 103), i.e. below the material threshold for S3.

Each topical chapter opens with a typed IRO table (risk/opportunity/actual or potential impact, value-chain stage, time horizon). Climate risk was additionally assessed via a 2022 TCFD-aligned resilience analysis (detailed under E1).

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

Reference: pages 100-103.

Bel's DMA follows a six-step methodology: defining the universe of issues (per ESRS 1 AR16, prior assessment and sector benchmark, identifying 29 structural topics), identifying IROs, determining scoring scales, scoring (via environmental/social/ethics workshops), stakeholder consultation, and approval by the Executive Committee then the Audit Committee.

Impact materiality (severity x probability, scale 1-4, threshold >2/4) and financial materiality (magnitude x probability, same scale/threshold) are scored separately; human-rights impacts are scored at maximum severity except for affected communities. The 2025 update reduced the total IRO count from 187 to 144, reclassifying three IROs as non-material and reviewing ratings for "more than 30 IROs." "In 2025, the Group had 70 significant IROs out of the 144 assessed." The DMA was first approved by the Executive Committee in 2023, reviewed by the Audit Committee in 2024, and the updated version approved in December 2025.

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

Reference: page 105-106 (cross-cutting policies); pages 227-237, Appendix 3 "Datapoints from other EU legislation."

Appendix 3 states: "This cross-reference table lists all ESRS 2 and material ESRS disclosure requirements for Bel which underpinned the preparation of the sustainability statement," giving, for every ESRS 2 and material topical DR, the internal section reference or, where a sub-topic was assessed as not material, the label "Non material" (used for E3's sustainable-oceans datapoint and for all of S3 - affected communities).

Section 3.1.4.2 separately maps the Group's cross-cutting policies (Code of Good Business Practices, Sustainable Purchasing Charter, Bel Operations Policy, Upstream Dairy Charter, Climate/Pollution/Water/Biodiversity policies, etc.) against the topics (E1-E5, S1, S2, S4, G1) they cover, in a matrix table (page 106).

Transition plan for climate change mitigation

Reference: pages 109-112.

Bel has been an SBTi member since 2017; its 2021 pathway, validated by SBTi in March 2022, targets (vs. 2017 baseline, across the value chain): Scope 1+2 down 55% by 2030 and 75.6% by 2035; Scope 3 down 18% by 2030 and 25% by 2035. FLAG and Net Zero-2050 targets were submitted to SBTi at end-2025, validation expected H1 2026.

Decarbonization levers (waterfall chart, page 111) by contribution: Green factories 3%, sustainable/regenerative dairy 36%, low-carbon products 20%, committed suppliers 19%, eco-designed packaging 5%, optimized downstream transport 5%, other Scope 3 11%. Resourcing: "investments to reduce the environmental footprint of production sites in 2025 amounted to more than €16 million," plus "approximately €30.4 million" in sequestration investments since 2023 (forest/peatland). The plan was "approved by Bel and Unibel's administrative, management and supervisory bodies." Locked-in emissions were assessed and "deemed non-significant... and were therefore not taken into account in the transition plan's projections."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 / the E1 climate risk section, where this content is disclosed in the FY2025 report (pages 112-113). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A 2022 TCFD-aligned analysis used two scenarios: +1.5°C (RCP2.6), assuming coordinated global decarbonization, and +4°C (RCP8.5), assuming policy stasis and unmitigated physical risk, each scored for political/economic/social/technological/environmental/legal factors. Impacts were assessed for 2035 and 2050, across the Group's full value chain, assuming business continuity.

Identified risks/opportunities (table, page 113) include raw-material procurement (physical, 2035), water scarcity (physical, 2035), energy management (physical, 2035), new low-carbon products (transition, 2035) and carbon tax (physical/transition, 2050). In 2025 Bel launched a further study with AXA Climate and Blunomy on climate- and water-related risk in five upstream dairy countries, using IPCC SSP2-4.5 and SSP5-8.5 for 2030/2050; results are due in 2026.

Resilience in relation to climate change

Back-filled from the E1 climate-risk section (ESRS 2 SBM-3 supplement), where this content is disclosed in the FY2025 report (pages 112-113). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Bel's climate resilience work rests on its 2022 TCFD-aligned scenario analysis (two scenarios, 2035/2050 horizons, full value chain) plus a 2025 AXA Climate/Blunomy study on upstream dairy water and climate risk in five countries. The report states plainly that "the resilience analysis as set out in the CSRD is not yet disclosed in full," noting that "work already carried out...remains fully relevant" and that "the in-depth analyses planned over the next three years will primarily aim to further align with the format and level of detail required by the CSRD" (page 73).

Resilience also draws on adaptation measures embedded in the transition plan, notably the water strategy (cross-referenced to the Water policy) and the rollout of regenerative agriculture.

Policies related to climate change mitigation and adaptation

Reference: page 114.

Bel's Group-level climate policy rests on four pillars: measure/raise awareness/manage carbon performance; avoid GHG emissions and ecosystem degradation (deforestation, biodiversity, food waste, food transition); minimize GHG emissions farm-to-fork (upstream dairy, transport, plants, packaging); and sequester residual emissions through carbon projects. The policy covers "all of the Group's activities (from suppliers to end consumers)," is steered by the CSR Operational Committee, and is published on the OpenClimat platform.

At plant level, the Bel Operations Policy's "Nature" component implements the climate policy locally (GHG reduction, climate adaptation, ISO certification, carbon-indicator tracking, stakeholder engagement).

Actions and resources in relation to climate change policies

Reference: pages 114-117, 125-126.

Actions include: a carbon footprint audit tool set (farm-level tools CAP'2ER/FARM ES/CFT, the Bel Carbon Impact Tool, the SC CO2 emissions calculator, and the internal carbon price); a partnership with Root Global (launched 2025) to simplify farm-level carbon assessment; and 95% of partner farms completing an initial carbon audit in 2025 (target 100% by 2030), with 50% completing a second audit.

Resources: the climate transition plan is funded via the Group's five-year carbon strategy plan, covering production, upstream dairy, dairy raw materials, transportation and packaging (75% of the carbon footprint). Employee training runs through Climate Fresk workshops, and 10% of eligible variable pay is tied to CO2-reduction achievement.

Targets related to climate change mitigation and adaptation

Reference: pages 109-111, 123.

Approved, SBTi-validated (March 2022) targets versus a 2017 baseline: Scope 1+2 emissions down 55% by 2030 and 75.6% by 2035; Scope 3 emissions down 18% by 2030 and 25% by 2035. The transition-plan waterfall projects -18% on Scopes 1, 2 and 3 by 2030 and -27% by 2035. In 2025 the Group offset 100% of its Scope 1 and 2 residual emissions via certified carbon credits (African Parks programme via Verra), achieving its 2025 net-offset milestone for plants.

Bel is pursuing SBTi validation of new FLAG and Net Zero-by-2050 targets, submitted end-2025, expected H1 2026; the updated transition plan will appear in the 2026 statement.

Energy consumption and mix

Reference: pages 122-123.

Total energy consumption rose 3% to 359,639 MWh in 2025 (2024: 350,623 MWh), driven by the newly consolidated Shandong JunJun Cheese site. The renewable share held stable at 55% (2024: 54%); fossil-source share fell slightly to 45%. Nuclear-source consumption is 0%. Energy intensity relative to net sales from high-climate-impact-sector activities was 0.21 MWh/€ thousand, unchanged year on year.

Detailed breakdown (table, page 122): fuel from natural gas 298,323 MWh (+3%); purchased renewable electricity/heat/steam 296,102 MWh (+4%); renewable fuel (biomass etc.) 134,991 MWh (flat). All of Bel's activities are classed as a high climate impact sector (NACE C).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 124-125.

2025 emissions: Scope 1: 99,473 tCO2eq (2017 baseline 112,893; -0.7% vs 2024). Scope 2 market-based: 6,022 tCO2eq (2017 baseline 65,683; +33% vs 2024's 4,530, reflecting the year-on-year offset calculation). Scope 3: 4,080,717 tCO2eq (+9%), dominated by purchased goods and services (3,232,129 tCO2eq, 10% growth) and downstream transportation (380,105 tCO2eq, +9%). Total market-based GHG emissions: 4,186,213 tCO2eq (+9% vs 2024's 3,844,161), against a 2017 baseline of 4,459,924.

Bel estimates its 2025 footprint at "4.2 million metric tons CO2 equivalent," or 6.2 tCO2 per tonne of product sold. Scope 3 is measured with a one-year lag (2024 data used for 2025 reporting) and generic emission factors for OpEx/CapEx carry an 80% uncertainty factor, though OpEx/CapEx is only 8% of total emissions.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 125-126.

Bel states its priority is to "avoid and reduce GHG emissions...to reduce total emissions to their lowest possible level," with carbon-credit offsets reserved for residual Scope 1 and 2 emissions at its plants from 2025. 105,496 tCO2eq of carbon credits were cancelled at end-2025 - equal to the year's full Scope 1+2 emissions - on the Verra registry, from the African Parks programme, in February 2026.

Sequestration and removal projects (forest conservation, Jura peatland rehabilitation, Livelihoods) are detailed under E4/biodiversity, with an associated investment of approximately €30.4 million since 2023.

Internal carbon pricing

Reference: page 126.

Bel's internal carbon price, based on IPCC and expert recommendations, launched in 2021 at €50/tCO2eq, rising each year to a planned €270/tCO2eq by 2030; in 2025 it was €200/tCO2eq. The trajectory to 2030 is approved by the Investment Committee.

Made operational in 2022, the price feeds: the Bel Carbon Impact Tool; a "Carbon current operating income" metric linking Group earnings to carbon emissions in euro terms; and financial simulations of investment projects, applying the price to Scope 1/2/3 impacts of simulated projects so that "investment trade-offs and decisions...incorporate this carbon impact pricing." The ESRS E1-recommended carbon-price measurement format "will be available in the coming years."

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Reference: page 126.

Bel states: "The Bel Group is currently working on the assessment of the anticipated financial effects of the impacts, risks and opportunities related to climate change. In line with the current CSRD regulatory framework, and as a first-wave company, Bel continues to benefit this year from the phased-in provisions introduced by the 'Quick Fix' Delegated Act adopted by the European Commission in July 2025...the corresponding data are expected to be available within a two-year timeframe."

No quantified monetary estimate of physical or transition risk exposure is given for FY2025; the qualitative risk/opportunity table under E1-2 (scenario analysis) identifies the relevant risk categories pending quantification.

Policies related to pollution

Reference: pages 127-128.

Bel's pollution policy has four lines of action: identifying the Group's impact on air/water/soil pollution; avoiding it; reducing it; and protecting natural environments from discharges. It is rolled out upstream (methane-reduction solutions for dairy farmers), at plants (discharge control, ISO 14001), and cross-references the Climate (E1), Water (E3), Resource use (E5) and Biodiversity (E4) policies.

At plant level the Bel Operations "Nature" pillar commits to 100% regulatory-compliant water discharge and continued ISO 14001/50001 rollout. The Group "continues to update the list of pollutants monitored," using EU Regulation (EC) No 166/2006 (E-PRTR) as its reference framework.

Actions and resources related to pollution

Reference: pages 128-130.

Own-operations actions: incident prevention, industrial waste treatment to limit pollution risk, and packaging eco-design. Share of ISO 14001-certified industrial sites rose from 62% to 69% in 2025; data on subcontractors' sites is no longer published. Value-chain actions include regenerative agriculture (reducing nitrogen/phosphorus runoff) and certification of raw materials (Vergers écoresponsables, FSC packaging).

To reduce discharges, the Group applies a Group COD-measurement standard and is building/upgrading wastewater treatment capacity at several plants (e.g. a biological treatment project starting 2025 at Lons-le-Saunier), with further investment through 2026 at three plants.

Targets related to pollution

Reference: pages 128-130.

Bel states: "The Group has not defined specific targets related to upstream agricultural pollution" and "has not set specific targets for the reduction of discharges into water and pollution of soil"; its stated objective instead is compliance with local regulations at each operating site, aiming "eventually" for discharge quality close to that of receiving aquatic ecosystems.

The regenerative-agriculture targets (100% of milk and apples transitioning by 2030, extended to key raw materials by 2035) are cited as the practical "drivers of this pollution reduction," even though no discrete pollution-specific numeric target is set.

Pollution of air, water and soil

Reference: pages 128-130.

Own-operations pollutants tracked: chemical oxygen demand (COD), phosphorus, and nitrogen oxides. Wastewater discharge (10 sites with on-site treatment): total organic carbon 69 t (2024: 67t), nitrogen 12t (9t), phosphorus 5t (4t) - each "below the reporting thresholds...in Annex II to Regulation (EC) No 166/2006" (E-PRTR). Sludge applied to soil (5 sites): nitrogen 95t, phosphorus 83t.

Value-chain pollutants identified: nitrogen (livestock effluent runoff), methane (enteric fermentation), phosphorus (palm-oil refining), and bauxite residue (aluminium production, "red mud"). The report notes plainly: "European directives on pollutants and industrial emissions will be taken into account within three to five years," signalling the full regulatory-aligned reporting format is still being built.

Anticipated financial effects from pollution-related impacts, risks and opportunities

Reference: page 131.

Bel states: "Bel is currently working on the anticipated financial effects from pollution-related impacts, risks and opportunities. The data will be available in three to five years. The Group has not set aside provisions for pollution risks. No pollution incidents were recorded in 2025 that had a material impact on the Bel Group's consolidated financial statements."

This follows the general phase-in statement (page 74-75) listing E2-6 among the financial-effects disclosures deferred under the EU "Quick Fix" Delegated Act and its French transposition (the DDADUE Act).

Policies related to water and marine resources

Reference: page 132.

Bel's Water policy, developed with WWF France, is structured around four areas: measuring impact and setting targets; avoiding/reducing water withdrawals; protecting/regenerating water resources; and strengthening resilience. Its ambition is framed as "Be water regenerative," aligned with SDG 6. Governance sits under the Chief Impact Officer, supported since 2023 by a dedicated Water Committee (footprint reduction) and Water Risk Committee (physical risk - drought, flood, scarcity).

The policy covers the full value chain: upstream (regenerative agriculture, supplier engagement), packaging material choice, plant operations (the 5R approach), downstream end-of-life, and regenerative hydrology beyond the value chain.

Actions and resources related to water and marine resources

Reference: pages 132-135.

Bel completed a full value-chain "water footprint assessment" in 2023 (with Quantis), finding Scope 3 accounts for 90-99% of total water-footprint impact (quantity and quality). Fruit/orchard irrigation drives 33% of value-chain water consumption from only 8% of purchased volumes. In 2025 Bel launched an internal water price per site (integrated into CapEx decisions from end-2025) and the "Bel Water Impact Tool" (tracking withdrawal and nitrate pollution at product/country/brand level).

At plants: a 2035 roadmap applies the 5Rs; the Évron plant joined the French State's voluntary "water sobriety" initiative (target: -10% by 2030); a pilot at Sablé is assessing recycled-wastewater reuse. In 2025 Bel achieved an A- CDP water score.

Targets related to water and marine resources

Reference: page 134.

Bel's headline target: reduce water withdrawal intensity by 45% (m3/tonne produced) by 2035 versus 2017, with a 2030 interim milestone; the 2025 KPI table shows -7.4% achieved versus 2017 (2024: -4.9%), against a 2025 objective of -16% and 2030 objective of -33%. No separate numeric target is set for water consumption ("calculated as the difference between withdrawals and discharges"), since "the primary focus is on reducing withdrawals."

The target was "approved by the Executive Committee" and is informed by the WWF Water Risk Filter site-prioritization matrix (2024) and Bel's 2023 SBTN pilot-participant status.

Water consumption

Reference: pages 134-136.

Water withdrawals at Group plants fell 7.4% versus 2017 to 6.60 m3 per tonne produced in 2025 (2024: 6.66 m3/t), equivalent to 1.2 m3 per €1,000 of net sales. Total withdrawal was 4,460 thousand m3 (2024: 4,267), of which 206 thousand m3 in water-scarcity areas (2024: 342) and 662 thousand m3 in severe-scarcity areas (2024: 463). In 2025, 74% of Bel sites were located in vulnerable, water-stress or water-scarcity areas.

No separate consumption figure is disclosed distinct from withdrawal-minus-discharge; the Group states it tracks withdrawal as "a true reflection of our resource use." The Évron plant targets re-using up to 150,000 m3/year of dairy-concentration process water.

Anticipated financial effects from water and marine resources-related impacts, risks and opportunities

Reference: page 137.

Bel states: "In accordance with Delegated Act 'Quick Fix' No. 2025/1416...the Bel Group is currently working on the expected financial implications of the impacts, risks and opportunities related to water and marine resources. The data will be available in three to five years. For example, in 2025, a study was carried out by the Purchasing teams in collaboration with AXA Climate and Blunomy that made it possible to see the projections for these risks on the Group's milk supplies and the consequences on the price of raw materials."

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: page 139.

Bel states plainly: "To date, Bel has not adopted a biodiversity transition plan within the meaning of the CSRD." It adds that it nonetheless "has set itself a bold ambition and is rolling out a policy and action plans on these ecosystem matters," and that "information on this subject required by the standard will be published in the coming years." This follows the Group's general transitional-provisions statement (page 74) that nature-transition-plan and biodiversity indicators (E4-1, E4-5) "will be disclosed within three years" under the EU "Quick Fix" Delegated Act.

The Group's dependence on ecosystem services (pollination, water, soil health) is described qualitatively rather than through a quantified transition plan: "more than 75% of food crops depend on insect pollination."

Policies related to biodiversity and ecosystems

Reference: pages 139-141.

Bel's biodiversity policy, updated in 2024 and co-signed by WWF France, is framed around four of the five IPBES drivers of biodiversity loss (land-use change, overexploitation, climate change, pollution - excluding invasive species as not relevant), within a planetary-boundaries framework. Four pillars: measuring the footprint and engaging stakeholders; avoiding impacts; reducing impacts through collective action; restoring biodiversity.

Complementary instruments: the Upstream Dairy Charter (regenerative agriculture, 100% milk target by 2030), the Forest and Natural Ecosystems Policy (2019, with WWF, covering soybean/palm-kernel meal, palm oil and paper/cardboard), and the Forestry Charter (December 2023, FSC-aligned, audited by an independent third party).

Actions and resources related to biodiversity and ecosystems

Reference: pages 141-145.

Bel completed SBTN methodology steps 1-2 (Assess, Interpret & Prioritize) in 2023 with WWF France, and was selected from 200+ candidates as one of 17 pilot undertakings globally testing SBTN (focused on land and freshwater use); results confirmed dairy has the greatest biodiversity impact. Regenerative-agriculture pilots run in Portugal, the US, France (Normandy/Poland with Mars Petcare) and orchards; agroforestry has planted 60,000 trees across 77 ruminant farms (2020-2025) and 25,000 trees via the Kiri brand (28 projects since 2022).

Ecosystem-restoration projects: the Nature Impact fund with WWF (5 projects, 5,400 ha, 16,000+ trees protected, 85,000 tCO2eq additional sequestration, 99-year commitments), and a Boticas (Portugal) restoration covering nearly 60 hectares. Bel achieved an A- CDP Forest score in 2025.

Targets related to biodiversity and ecosystems

Reference: pages 138, 144-145.

Explicit targets: 100% of milk sourced from farms transitioning to regenerative agriculture by 2030 (2025: 8% of volume achieved); 100% of apples from regenerative-transition farms by 2030 (2025: 12%); and the Forest/Natural Ecosystems policy's zero-deforestation commitment, with the CSR Scorecard reporting "25% of the land required to produce the monitored raw materials is at risk of deforestation" (page 138).

Quantified, science-based biodiversity targets under the SBTN framework are not yet set: "Bel is now awaiting the new updated versions of the methodology," expected for publication in 2026, with a stated goal of "setting quantified targets in the long-term."

Impact metrics related to biodiversity and ecosystems change

Reference: page 146.

Bel states: "In accordance with Delegated Act 'Quick Fix' No. 2025/1416...the Bel Group will disclose the metrics required by the standard within two to four years." This follows the general transitional-provisions statement (page 74) naming E4-5 (biodiversity indicators) among the items deferred under the "Quick Fix" relief.

The company notes separately that it "does not currently have the information necessary to provide a detailed description of the physical sites and activities affecting biodiversity-sensitive areas" (page 139), though its 2023 SBTN-based site-prioritization study (steps 1-2) is presented as the qualitative groundwork for this future metric.

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Reference: page 146.

Bel states: "The Bel Group will work on the anticipated financial effects from biodiversity and ecosystems-related impacts, risks and opportunities. The data relating to anticipated financial impacts will be available in three to five years," under the same "Quick Fix" Delegated Act phase-in relief applied to the other topical financial-effects disclosures.

Policies related to resource use and circular economy

Reference: pages 148-150.

Bel's circular-economy approach is built on five Rs (inspired by the Ellen MacArthur Foundation "butterfly" model): Reduce, Re-use, Recycle, Regenerate, Recover, formalized through the Sustainable Portions policy (packaging, revised 2023), the Bel Charter to fight against food waste, and the Bel Operations policy (plant-level industrial waste). All are approved by the Executive Committee, with dedicated CSR Packaging and Food Waste Committees.

Quantity of raw materials and packaging purchased is not disclosed as a tonnage figure: "The tonnages of raw materials and packaging are not disclosed, as they constitute technical data related to the Group's industrial know-how. Bel therefore opts for a qualitative presentation of its resource management, in line with ESRS requirements."

Actions and resources related to resource use and circular economy

Reference: pages 150-155.

Packaging actions under the 5Rs: eliminating unnecessary plastic (CGF commitment, not yet met for the Babybel net); limiting flexible-packaging headspace to 30% (achieved 2025); lighter fruit-pouch caps (-40% plastic, ~1,265 t/year savings); bulk-packaging trials via the "Défi Vrac" coalition; a new paper Babybel pack (UK, 2025); and 91% ASI-certified aluminium sourcing. Food-waste actions include the CGF Food Waste coalition (Bel is co-chair from 2025) and the long-running "Too Good To Go" labelling partnership.

Waste management: a new Group waste-management standard (2025) and an e-learning module; total waste generation rose to 57,126 tonnes (2024: 54,307t). Zero-landfill was achieved in Europe/US/most other countries by the 2025 target date.

Targets related to resource use and circular economy

Reference: pages 151-155.

Packaging: 100% recyclable-ready and/or home-compostable by 2030 (2025: 82%, against a 90% 2025 objective - missed, attributed to delayed Squeeze-pouch rollout). Food waste: halve the rate of food loss and waste in operations by 2030 versus 2021 (2025: 3.4%, down from 4% in the 2021 base year and 3.5% in 2024). Industrial waste: zero landfill (excluding ultimate waste) for Europe/US/Canada plants by 2025 - achieved - and for remaining plants by 2035 at the latest.

Bel also participates in the global 10x20x30 initiative (halve operational food waste by 2030 vs. 2021) and the CGF's SDG 12.3 commitment.

Resource inflows

Reference: page 150.

Bel discloses its resource-inflow categories qualitatively rather than as tonnages: dairy raw materials (including raw milk), apples and other fruit-based raw materials, palm oil and other vegetable fats, packaging materials, water, and energy - each cross-referenced to its dedicated management section. The Group states directly: "The tonnages of raw materials and packaging are not disclosed, as they constitute technical data related to the Group's industrial know-how," and confirms separately (page 73) that it "is not in a position to report the percentage of organic materials from sustainable sources specifying the certification system used."

Bel does disclose specific sustainability-certification rates for some inflows elsewhere in the statement (e.g. 91% ASI-certified aluminium, 91% zero-deforestation-compliant paper/cardboard), though not a consolidated ESRS-format resource-inflow table.

Resource outflows

Reference: pages 151-155.

Packaging: 73% paper/cardboard, 19% plastic, 4% aluminium, 4% other by weight (2025); 82% recyclable-ready and/or home-compostable (unchanged from 2024, below the 90% 2025 objective). 12 initiatives supported to improve recycling infrastructure (CELAA, AREME, COAALI, AIRE).

Food waste: the rate of food loss and waste (share of edible food sent to a "waste destination" relative to total food processed) was 3.4% in 2025 (2024: 3.5%; 2021 base year: 4%), measured per the WRAP/10x20x30 harmonized framework and the FLW Protocol. Surplus handling follows a hierarchy: sale/donation (>99% of finished products sold or donated), animal feed, methanization/composting/land application, and incineration with energy recovery as a last resort.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reference: page 155.

Bel states: "In accordance with Delegated Act 'Quick Fix' No. 2025/1416...the Bel Group is working on the expected financial implications of the impacts, risks and opportunities related to resource use and the circular economy. The data will be available in three to five years."

Waste

Reference: page 151; accounting policies pages 73-74.

Total waste generation at Bel plants was 57,126 tonnes in 2025 (2024: 54,307 tonnes). The report states explicitly that the detailed ESRS breakdown is not yet available: "The Group has set a time horizon of three years to comply with the CSRD regarding the requested industrial waste management metrics," and separately (page 73) that for resource outflows measured per ESRS methodology, "the Group is currently working to collect and validate source data. It should be able to provide comprehensive reporting on this data within three years."

No split of hazardous/non-hazardous/radioactive waste, nor diversion-from-disposal figures, is given for FY2025; those appeared in the Appendix 3 datapoint table as "Not disclosed this year" (total/percentage non-recycled waste; total hazardous waste) and "Not applicable" (radioactive waste).

Policies related to own workforce

Reference: pages 165-167.

Bel's "Nurture" value proposition structures own-workforce policy around four pillars: Be Well (health/safety, well-being, pay, benefits - Safe@Bel, Fair Wage@Bel, Hybrid Work@Bel), Belong (DEI - We All Belong), Become (skills/careers - Talents@Bel), and Believe (engagement/impact - We Share, Actors for Good). It commits to the UN Global Compact, OECD Guidelines, ILO Fundamental Principles, and UN Guiding Principles on Business and Human Rights, and is governed by the CSR Operational Committee with the Chief People Officer accountable for progress.

A dedicated health and safety policy targets "zero accidents or occupational illnesses," applying to all employees and to subcontractors/visitors on Group sites.

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

Reference: page 175.

A global Charter for Social Dialog (since 2016) governs engagement principles across all regions. The European Works Council (established 2019, renewed 2023 for four years) covers sites with 20+ employees in 10 EEA/Switzerland/UK countries; its 21 representatives meet at least annually with Executive Management on transnational topics. In the Americas, a monthly meeting covers structure, training, mobility and working conditions.

The annual "Your Voice" anonymous engagement survey (since 2021) feeds local and Group action plans; 2025 participation was 86% (2024: 84%), with a commitment score of 78/100.

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

Reference: pages 176-177.

The Bel Ethics Line is available to employees for reporting concerns, including on behavior inconsistent with Group values; in 2025 a new report-management system was introduced, with Human Resources and Organization now responsible for employee-related reports, supported by the Trust & Ethics Committee. Reports may be anonymous or named.

Incidents, complaints and severe human rights impacts (2025 vs 2024): Ethics Line reports concerning employees rose from 37 to 40; OECD National Contact Point complaints: 0 (both years); serious human rights incidents (excluding discrimination): 0 (both years); discrimination/harassment incidents: 0 recorded in 2025 (no 2024 comparator, new metric).

Taking action on material impacts on own workforce

Reference: pages 166-174.

Health and safety actions include monthly monitoring of accident frequency, systematic incident reporting across sites, Behavior Safety Visits (4-5 per employee per year at industrial sites, target 6), and an ergonomics framework covering 16 defined limits (workstation risk reduced 30% in 2025). DEI actions include the "Inclusive Behaviors" program, a Respectful and Inclusive Behavior Charter, and collective agreements on diversity in France. Training/development runs through Talents@Bel and the new "BLOOM" platform (launched September 2025).

Financial incentives tie eligible employees' variable pay to CSR performance (30%+ of bonus), including health and safety (5%) and gender-parity targets (10%).

Targets related to own workforce

Reference: pages 165-174.

Headline workforce targets for 2030 include: accident frequency rate target of 3 (Bel definition), achieved at 2.57 in 2025; employee engagement score of 80/100 (2025: 78); inclusion score of 85/100 (2025: 79); gender parity in management of 40%/40%/20% flexible (2025: 34% women in Top Management, against a 35% 2025 objective); 30% of senior corporate managers from countries other than France by 2030; and 100% of eligible employees having at least one development-related conversation per year (2025: 86%).

Most targets are tracked through the annual "Your Voice" survey and the CSR Scorecard, with progress reported against both 2025 interim and 2030 final objectives.

Characteristics of the undertaking's employees

Reference: page 178.

At 31 December 2025, Bel employed 11,147 people (2024: 11,046) across 34 countries, with France (39%) and the United States (13%) each exceeding 10% of the workforce. Gender: 3,911 women / 7,236 men. Contract type: 9,763 permanent, 1,384 temporary; 10,850 full-time, 297 part-time; no non-guaranteed-hours employees. Workforce split: 75% non-managers / 25% managers; by age, 21% under 30, 57% 30-50, 22% over 50.

The employee turnover rate was 12% in 2025 (2024: 13.4%; 1,354 departures vs. 1,455), attributed partly to fewer departures and to the Shandong JunJun Cheese scope change. The Group states it "is not currently in a position to include non-employee profiles...in the scope of their reporting" for this workforce table.

Characteristics of non-employee workers in the undertaking's own workforce

Reference: page 178; transitional provisions, page 75.

Bel states explicitly: "The Bel Group is not currently in a position to include non-employee profiles (temporary staff, self-employed people, etc.) in the scope of their reporting." This follows the general transitional-provisions statement that "the following social data: number of non-employees (S1-7)...will be disclosed within two years" under the EU "Quick Fix" Delegated Act phase-in relief.

No headcount, FTE, or category breakdown of non-employee workers (temporary agency staff, self-employed, subcontracted site personnel) is given for FY2025.

Collective bargaining coverage and social dialog

Reference: page 175.

As of 31 December 2025, 66% of the Group's employees are covered by collective bargaining agreements, "mainly located in the European Economic Area (EEA)." Separately, 99% of EEA employees benefit from having workers' representatives in their workplace. A breakdown table (page 175) presents coverage and representation by region band (0-19%, 20-39%, 40-59%, 60-79%, 80-100%), placing France and EEA countries generally in the higher bands and the Americas/APAC/EMEA-excl-EEA in lower bands.

Diversity metrics

Reference: pages 170-171.

Percentage of women in Top Management: 34% in 2025 (2024: 32%), against a 2025 objective of 35% and 2030 objective of 40%. Gender distribution in absolute terms: Board of Directors 6 men/2 women; Executive Committee 5 men/5 women (2024: 6/5); Top Management overall 102 men/52 women (66%/34%). Bel's France (Cheese) gender-equality index score was 95/100 in 2025 (up slightly from 2024); Materne/Mont-Blanc scored 85/100 (down from 2024).

Age-band diversity metrics appear under S1-6 (workforce characteristics); no separate disability-inclusion percentage is reported here (see S1-12).

Adequate wages

Reference: page 167.

Bel was certified "Global Living Wage Employer" by the Fair Wage Network (first in 2023, renewed January 2026), confirming it "pays all its employees more than the minimum and enough to cover their expenses for housing, food, transportation, health and education, and to enable them to save for unexpected events, even in a period of inflation." Subsidiaries conduct regular market salary surveys with specialized firms.

No employees are reported as paid below the applicable adequate-wage benchmark; no country-level shortfall figures are disclosed.

Social protection

Reference: pages 168-169; transitional provisions, page 73.

Bel's social-coverage table (2025 vs 2024): health coverage 97% (98%); unemployment income-loss coverage 90% (90%, unchanged); death/disability coverage 97% (99%); parental-leave income-loss coverage 99% (2024: new metric, no prior data); retirement income-loss coverage 100% (78% in 2024, coverage newly extended). Bel notes it is "working on harmonizing the definition of social protection to establish shared criteria," underpinning a new "Bel Care" program.

Bel separately flags a gap against the full ESRS format: "Social protection metrics, as required by ESRS, are not published" and that coverage data "are, to date, obtained based on declarations as part of the annual reporting" rather than the country-by-country breakdown the standard contemplates.

Persons with disabilities

Reference: pages 171-172.

At 31 December 2025, 3.9% of the Group's workforce in countries with a legal reporting obligation were employees with a disability, covering 83% of the Group's total workforce (i.e. the countries where such reporting is legally required). This is the first year the metric is calculated Group-wide beyond France alone: "In its first sustainability statement, Bel only presented the employment rate of employees with disabilities at its sites in France." No numeric target has yet been set: "Targets have yet to be defined."

A digital-accessibility IT standard took effect in June 2025 for all new work tools.

Training and skills development metrics

Reference: page 174.

Average training hours per employee: 15.0 in 2025 (2024: 13.7), split by gender (female 15.5, male 14.7) and by status (executive 20.8, non-executive 13.0). 86% of eligible employees had a development-related conversation in 2025 (2024: 84%; excludes non-desk employees). 91% had an individual performance-assessment interview (2024: 93%).

Training is delivered through "Bel University," Business Line Academies, and the new "BLOOM" digital platform launched September 2025, which is only accessible to employees with internet access.

Health and safety metrics

Reference: pages 166-167.

Bel discloses two frequency-rate definitions side by side: its historical "Bel FR" (broader-scope accidents requiring medical treatment beyond first aid) was 2.57 in 2025 (2024: 2.42), against a medium-term target of 3; the CSRD-aligned frequency rate, disclosed for the first time in 2025, was 8.5 for employees and 9.1 including temporary staff. Work-related accidents (CSRD definition, employees): 105 in 2025 (no 2024 comparator, new methodology); days lost: 1,041 (2024: 1,498); fatalities: 0 (both years).

The Group states: "The Group does not currently have consolidated data relating to the number of occupational illnesses for the entire workforce," consistent with the general transitional-provisions note that occupational-illness data (S1-14) "will be disclosed within two years."

Work-life balance metrics

Reference: pages 169, 174.

Bel tracks work-life balance qualitatively through the annual Your Voice survey, where it is cited among the Group's identified strengths in 2025, supported by the Hybrid Work@Bel program. The Appendix 3 content index marks the quantitative ESRS work-life-balance datapoints (family-related leave entitlement/uptake by gender) as "Not disclosed this year" for 2025.

No percentage of employees entitled to family-related leave, nor uptake rate by gender, is published for FY2025; these are part of the "new social metrics" roadmap the Group is progressively building out.

Compensation metrics (pay gap and total compensation)

Reference: page 168.

Gender pay gap: 33% in 2025 (women earning on average 33% more than men), attributed to "the Group's workforce structure: women are proportionally more numerous in the most skilled positions and in countries where remuneration levels are highest." Annual total remuneration ratio: 26. Bel notes: "The pay gap metrics were measured for the first time this year, using payroll data as at May 31, 2025 and, for simplification purposes, taking into account only the base salaries of eligible employees" - i.e. a first-year, simplified calculation rather than full-population total compensation.

Incidents, complaints and severe human rights impacts

Reference: pages 176-177.

Ethics Line reports concerning employees: 40 in 2025 (2024: 37). OECD National Contact Point complaints: 0 (both years). Serious human rights incidents (child labor, forced labor, modern slavery), excluding discrimination: 0 (both years). Discrimination/harassment incidents: 0 in 2025 (new metric, no 2024 baseline). Fines from the above: 0 in 2025 (new metric).

Bel maintains longstanding commitments to the UN Global Compact (since 2003) and ILO fundamental conventions on forced labor, child labor and discrimination, reaffirmed through the Code of Good Business Practices.

Policies related to value chain workers

Reference: page 182.

Bel does not yet have a standalone value-chain-workers policy: "In the years ahead, the Group is looking to introduce a policy specific to workers in our value chain...Pending the formalization of this policy," coverage runs through the Code of Good Business Practices, the Sustainable Purchasing Charter, and the Sustainable Dairy Upstream Charter (for dairy producers specifically), each aligned with the UN Guiding Principles on Business and Human Rights and ILO Fundamental Principles. The OECD Guidelines will be incorporated into the next Sustainable Purchasing Charter revision, due 2026.

Processes for engaging with value chain workers about impacts

Reference: page 185.

Bel operates a table of dedicated engagement channels by worker category (page 185): dairy producers via the Farmer's Voice survey (rolled out in Poland, Portugal, France, Iran, Slovakia; 100% coverage targeted by 2030, excluding the US and Canada where Bel works through intermediaries); apple growers via regular cross-industry contact; microentrepreneurs in the Rising Communities program via local representatives; and other value-chain workers via the Bel Ethics Line, where no dedicated mechanism exists.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 185.

The same engagement table (page 185) doubles as the remediation pathway, naming a responsible party per worker category: the Group Milk Purchasing Director and dairy-basin teams (dairy producers), local purchasing departments (apple growers), the Head of Inclusive Business (microentrepreneurs), and the Purchasing Department and Trust & Ethics for other value-chain workers via the Bel Ethics Line. "In 2025, no serious human rights incidents were reported concerning workers in the value chain" (page 182).

Taking action on material impacts on value chain workers

Reference: pages 182-184.

Dairy: 90% of farms received at least one technician visit and an annual-meeting invitation in 2025 (2024: 88%); milk price has been 100% indexed to farmers' production costs since 2023 via the Ipama index, with price-revision clauses for 2026. Apples: 100% of French-purchased apples are certified "éco-responsable," requiring minimum-wage and working-condition standards for orchard workers. Other suppliers: a new 2025 CSR and anti-corruption risk analysis (covering integrity, social, climate, water) identified at-risk suppliers for 2026 action plans; subcontractors are asked to pursue ISO 45001 certification.

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

Reference: page 183.

100% of partner farmers visited and invited to an annual meeting by 2030 (2025: 90%, against a 100% 2025 objective - not yet met). 100% of partner producers to have access to the Farmer's Voice survey by 2030 (excludes US/Canada dairy basins, where Bel works through intermediaries). 100% of countries to have a "Generational Renewal" program for young farmers in place by 2025 - stated as achieved by year-end. No separate numeric target is set for apple-grower or other-supplier remediation coverage.

Policies related to consumers and end-users

Reference: pages 188-189, 198.

Bel's Food Safety and Food Defense policy combats unintentional contamination and intentional/malicious tampering respectively, underpinned by the Bel Group Site Safety Standard (5A method: Assessment, Accountability, Armor, Awareness, Alert, updated 2025) and GFSI-recognized certifications (IFS Food, BRC, FSSC 22000, SQF). A Consumer Care Policy (since 2019) commits to accessible contact channels, qualified personnel, clear answers, and data-privacy protection. Nutrition, accessibility, and responsible-communication policies (covered under S4-4/S4-5) sit alongside these.

Processes for engaging with consumers and end-users about impacts

Reference: pages 197-198.

A Consumer Care manager, reporting to the Head of Consumer Customer Citizen Care, coordinates consumer dialog Group-wide, supported by local Consumer Care correspondents. Satisfaction surveys run in 38 countries, covering 86% of contacts received; negative reviews trigger automatic notification to Consumer Services. A biennial (or annual, if results are unsatisfactory) telephone audit of consumer services is conducted per country. An inclusive website platform for deaf/hearing-impaired users operates in France.

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

Reference: pages 197-198.

WeCare, the Group's consumer-feedback system, centralizes complaints, comments, compliments and suggestions across subsidiaries (excluding US/Canada Squeeze), tracked via a Power BI tool used by over 1,000 employees by end-2025. Customer complaints in the Cheese scope fell 7% in 2025 (2024: 0% change). The Bel Ethics Line is also open to consumers: "In 2025, no reports submitted via the Bel Ethics Line revealed any impact involving a consumer of the Group's products. No serious incidents relating to respect for the human rights of consumers were identified, and no fines were incurred."

Taking action on material impacts on consumers and end-users

Reference: pages 188-198.

Food safety: full raw-material-to-finished-product traceability; 26 industrial sites GFSI-certified (100% excluding subcontractors, 95% including them, up from 94% in 2024); 71% of plants AEO "FULL" certified (2024: 62%). Nutrition: the "Positive recipes" metric (Nutri+ criteria or 0-1 additive, children/family range) rose to 91% in 2025 (2024: 88%). Accessibility: Bel targets 500 million consumers reached by 2030 (2025 base: 415 million). Responsible communication: the CGF-aligned EU Pledge restricts advertising to under-12s; a third-party provider monitors advertising compliance.

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

Reference: pages 188, 198.

Bel's headline consumer-reach target is 500 million consumers by 2030 (from ~415 million currently). Nutritional-quality progress is tracked via the "Positive recipes" KPI (2025: 91%, up from 88% in 2024, part of the CSR Scorecard's 2025/2030 objective ladder). No single consolidated numeric target covers food-safety or marketing-practice outcomes; these are instead tracked through certification-coverage rates (GFSI, AEO) and complaint-trend monitoring (Cheese-scope complaints, -7% in 2025) as the effectiveness measure in the absence of a stated numeric target.

Business conduct policies and corporate culture

Reference: pages 200-202.

Bel's corporate culture rests on three values - Dare, Care, Commit - assessed annually via Your Voice. The Code of Good Business Practices (2012, updated 2023) sets seven principles: comply with laws/standards; protect consumers; respect the environment; protect employees' rights; prevent conflicts of interest/fraud/corruption; promote fair business relations; protect confidentiality of financial information. The "Think Ethics" program (launched 2024-2025) adds an anti-fraud policy, an anti-corruption procedure, and a Gifts/Hospitality procedure, overseen by the newly created Ethics, Compliance & Litigation Department (July 2025) and the merged Trust & Ethics Committee.

Management of relationships with suppliers

Reference: pages 211-213.

Framework: the Sustainable Purchasing Charter (10+ years, updated 2023 to strengthen biodiversity/animal welfare/human-rights requirements) and the Code of Good Business Practices, both embedded via a "CSR and Ethics" contract clause. Suppliers have been EcoVadis-assessed since 2009 (21 criteria, re-assessment every 2-3 years): Bel's average supplier EcoVadis score rose to 64/100 in 2025 (2024: 60), above the EcoVadis peer-panel average of 56.8 and the Group's own 2025 target, against a 2030 target of 65. A Sapin II-aligned digital integrity-screening tool now applies to new supplier onboarding above a spending threshold.

Prevention and detection of corruption and bribery

Reference: pages 214-215.

Bel applies a "zero tolerance policy with regard to active or passive corruption," underpinned by an anti-corruption procedure (updated 2024) and a 2023 anti-corruption risk-mapping exercise (190+ employee questionnaire respondents, ~35 interviews/workshops) that produced a consolidated Group risk map, finalized in 2025 with a mapping of functions most exposed to corruption risk. 56% of employees in at-risk positions had received anti-corruption training by end-2025 (face-to-face or distance). Reports may be filed via the Bel Ethics Line: "No corruption-related reports were identified in 2025."

Targets related to business conduct

Back-filled from the G1 business-conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement under the 2023 ESRS the statement was prepared against.

Bel does not state a quantified outcome target (e.g. a future percentage or deadline) for corruption prevention. Consistent with MDR-T's "effectiveness tracked in the absence of a target" limb, the Group instead tracks: anti-corruption training coverage of at-risk employees (56% at end-2025); completion of its anti-corruption and functional risk-mapping exercise (finalized 2025); and outcome monitoring via "0 corruption-related reports identified in 2025" and "no convictions or fines for non-compliance with anti-corruption or bribery legislation" (G1-4). The wider Business Conduct section summary (page 215) sets 2026 priorities including "roll-out of the ethics and anti-corruption training plan" but without an attached numeric target.

Incidents of corruption or bribery

Reference: page 215.

Bel states: "In 2025, the Group was not subject to any convictions or fines for non-compliance with anti-corruption or bribery legislation." No corruption or bribery incidents are reported for the period. The Bel Ethics Line is identified as the Group's reporting channel for such incidents, alongside employee training and the Sustainable Purchasing Charter's preventive role.

Political influence and lobbying activities

Reference: page 215.

Bel is registered in the EU Transparency Register (ID 043760293792-48). Total lobbying expenses (internal and external) were €99,200 in 2025, covering agency fees and Mouvement Impact France membership, managed by a full-time Senior Public Affairs Manager. Lobbying topics include the European Green Deal/"Farm to Fork," nutrition/health-claim labeling, unfair commercial practices, Green Claims, the Packaging and Packaging Waste Regulation, food law, the common agricultural policy, and animal welfare. Memberships include the European Dairy Association, EUROPEN, EU Pledge, ANIA and ILEC. "In 2025, the Group made no political contributions, either financial or in kind," and reports no governance-related conflicts of interest.

Payment practices

Reference: pages 212-213.

Default payment terms (absent a contract/purchase-order term) are 50 days from a 10-day invoicing period, per Article D.441-6 of the French Commercial Code; the same terms apply to SMEs, as Bel "does not have a specific policy dedicated to this category of suppliers." In 2025, 72% of payments were made within contractual terms, and the average payment term was 45 days. Dairy producers receive preferential 10-day settlement to support cash-flow management. No legal proceedings were pending regarding late payments at the end of 2025.