bpost NV/SA

Reference: page 94

A Board of 12 members including the CEO, otherwise non-executive; "50% of the members of the Board of Directors are independent" (page 94). Composition and diversity ratios are incorporated by reference to the Corporate Governance Statement, section 5.1 (page 93).

Committees (pages 95-96). Four advisory committees: Strategic, ESG, Audit Risk & Compliance (ARCC) and Remuneration and Nomination. The ESG Committee is responsible for "reviewing and approving the Double Materiality Assessment (DMA)", monitoring initiatives and advising the Board; at 31 December 2025 it had three members - Ann Vereecke (Chair), Denis Van Eeckhout and Jules Noten - whose expertise and contribution to IROs are tabulated individually.

Worker representation (page 94). "bpost NV/SA does not have a designated worker representative within its Executive Committee or Board of Directors"; workforce matters are carried at ExCo level by the Chief Human Resources Officer.

A Delegation Policy effective 1 January 2025 requires Board approval for major sustainability matters and gives the ESG team "a consultative role in all key decisions" (page 96). Strategic policies are reviewed under the Policy Governance Framework, in force since March 2025; internal audit undergoes "an external quality review every five years" (page 97).

Reference: page 97

The administrative, management and supervisory bodies "are informed about all the material impacts, risks, and opportunities (IROs) and the implementation of due diligence, as well as results & effectiveness of policies, actions, metrics and targets" (page 97).

Frequency. The ESG Committee meets twice a year to review material sustainability impacts, risks and opportunities; ESG topics are also addressed ad hoc by other Board committees - the ARCC for risk management and compliance matters with sustainability implications, and the Remuneration and Nomination Committee for incentive plans carrying sustainability performance criteria (page 97). At management level the ESG Steerco (ExCo) "meets monthly and selects key topics for the ESG Committee of the Board" (page 135).

Trade-offs. "These bodies assess potential trade-offs associated with sustainability impacts, facilitating decisions that balance short-term operational needs with long-term sustainability goals" (page 97).

Escalation runs through the ERM process: the most material short-term risks identified in the DMA are integrated into the ERM and, where relevant and based on the risk appetite statement, escalated to the ARCC and the responsible ExCo member (page 135).

Reference: page 98

The Remuneration policy, "last reviewed and updated by the Board in 2023", incorporates sustainability metrics through a Short-Term Incentive Plan (STIP) and a three-year Long-Term Incentive Plan (LTIP); ownership rests with the Board on the recommendation of the Remuneration and Nomination Committee (page 98).

Population covered (page 98). Around 2,100 employees are eligible for the STIP (1,650 at bpost NV/SA, 396 at Radial EU, 71 at Landmark Global); approximately 130 employees, including ExCo and Senior Executives, are eligible for the LTIP (about 65 in EU entities, 50 at Radial US, 15 at Landmark Global). "The compensation for board members is based on fixed fees and meeting tokens, with no variable component tied to ESG performance."

Weighting (page 99). "The total percentage of remuneration tied to ESG factors is significant, with 10% of the STIP and 50% of the LTIP linked to sustainability performance in 2025." The LTI is assessed on market performance (50%, Total Shareholder Return), environmental performance (30%), "Measured by CO2 reduction targets... against the reduction of Scope 1 and Scope 2 emissions", and governance performance (20%, the Strategic Risk Monitoring and Mitigation plan and Group Key Controls). The STI ESG component "focuses on employee development, measured through participation in training sessions aligned with our new leadership model".

Reference: page 100

Bnode aims "to adhere to the principles outlined in the United Nations (UN) Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises in all operations" and states it is "working to enhance our due diligence processes by embedding human rights and environmental considerations throughout our operations, supply chain, and corporate governance" (page 100).

Mapping table (pages 100-101). A two-page table maps each core element of the due diligence process to the sections of the statement where it is reflected:

• Embedding due diligence in governance, strategy and business model - GOV-2, GOV-3, SBM-3
• Engaging with affected stakeholders - SBM-2, IRO-1, S1-2, S2-2, S4-2, G1-1
• Identifying and assessing negative impacts - SBM-3, the topical E1/S1/S2/S4 SBM-3 sections and the six topic-level ESRS 2 IRO-1 sections
• Taking actions - E1-3, E2-2, E5-2, the three S1-4 action sections, S2-4, S4-4, G1-1
• Tracking effectiveness and communicating - E1-4 to E1-6, E2-3, E5-3 to E5-5, the S1 metrics (S1-6 to S1-17), S2-5, S4-5, G1-6, G1-4, G1-5

The mapping is the disclosure; no separate narrative on due diligence outcomes is given under GOV-4.

Reference: page 102

Risk management runs through the group ERM framework, which "incorporates at least a bi-annual top risk review" by the ERM team with top executives and operational managers, focused on "the evolution of key ESG-linked risks, such as regulatory compliance (including the risks related to the sustainability reporting process), climate change, governance practices" (page 102).

Structure. The review engages an ERM Community of senior management and "about 50 dedicated ERM SPOCs" plus 10 ERM coordinators designated by ExCo members. Bnode applies the three lines of defence model, with dedicated reporting lines from the ERM and Compliance Directors to the ARCC Chair (page 102).

Mitigations specific to the reporting process (page 103). Risks identified are "potential incompleteness, errors, data inaccuracies, and regulatory non-compliance", addressed by upskilling the ESG team, strengthening data management - "leveraging Visier for HR data and developing in-house solutions for GHG emissions, and waste and packaging data" - and "clear segregation of responsibilities and control mechanisms across data streams collected from different entities".

Main features of the risk management and internal control system are incorporated by reference to section 5.2 (page 93).

Reference: page 104

Bnode - the corporate brand adopted on 9 December 2025, when "The name of Bpostgroup indeed changed to Bnode" (page 10) - is "Belgium's leading postal operator and a growing parcel & omni-commerce logistics partner in Europe, North-America and Asia" with "nearly 34,000 employees"; it "generates over 90% of its business in the postal, logistics & transportation sector" and "does not have any banned products in any market" (pages 104-105).

Three business units (page 104): Bpost (last mile), Paxon (third-party logistics and fulfilment) and Landmark Global (cross-border), plus retail, press distribution, government services and document flow management in Belgium.

Revenue / end-year headcount by area (page 105, EUR million): Belgium 2,322.8 / 25,755; France 288.9 / 1,235; Other Europe 663.4 / 2,887; USA 1,087.8 / 3,278; Rest of World 119.6 / 377.

Objectives embedded in strategy (page 105): decarbonising the e-commerce and parcel-sized 3PL supply chain with "a renewed 'post Staci acquisition' SBTi target... to reduce Scope 1 and 2 emissions by 71.3% and Scope 3 emissions by 38.2% by 2035 (compared to 2024) as well as a net-zero target on all scopes by 2050"; reducing adverse impacts on air quality; recyclable and reusable packaging.

Five value chains were defined in the DMA and "Together, they represent the entirety of Bnode's revenues" (page 132).

Reference: page 112

"In 2023, Bnode conducted an extensive internal and external stakeholder engagement process as part of the Double Materiality Assessment (DMA). This exercise was extended in 2024 to reflect the acquisition of Staci and was refreshed in 2025" (page 115).

Groups and channels (page 114). A table gives, per group, the relevance of engagement, encounter opportunities and an example outcome: shareholders and investors (annual meetings, Investor Day, quarterly calls - outcome the June 2025 Investors day and the rebranding to Bnode); customers (annual satisfaction surveys, account management - outcome the "Renewed SBTi net zero decarbonation path Commitment post STACI acquisition"); employees (bi-annual wellbeing measurement, Joint Industrial Committee, monthly consultations with social partners); suppliers (SBTi awareness raising, a study of transport suppliers' decarbonisation plans, the "Carbon Coach" pilot); media; and authorities, including the postal regulator.

Interests fed into strategy (pages 115-117). Per group, the material need and the response - investors' interest in "Development of a resilient business model in light of climate change", answered by a transition plan to 2035 and "A detailed climate vulnerability analysis (focus flood & heatwave)... for all bpost SA/NV strategic sites in Belgium"; employees' health and safety interest, answered by "The introduction of a new safety target by 2030"; value chain workers' health and safety, answered by "Deployment of an enhanced Supplier Code of Conduct and Subcontractor Policy approved early 2025".

Reference: page 118

"Bnode assessed its own operation and its entire value chain (downstream and upstream) as part of the Double Materiality Assessment (DMA). The most significant impacts, risk and opportunities include: Climate change; Health & Safety risks; Privacy and cyber-security" (page 118). The DMA yields eight ESG priorities across environment, social and governance.

Change versus prior year (page 118). "although certain evolutions were identified across several sub-subtopics, the list of material sub-subtopics remains unchanged from the 2024 annual report."

IRO table (pages 119-121). 25 material sub-sub-topic rows by standard, with category, value chain position and time horizon: E1 (GHG Scope 1-2, GHG Scope 3, energy), E2 (pollution of air), E5 (packaging inflow, waste outflow), S1 (seven rows), S2 (five rows, all upstream), S4 (non-discrimination and equal access; privacy) and G1 (five rows).

Entity-specific (page 122). "Based on the DMA, no entity-specific disclosures are required; however, certain entity-specific KPIs are included within the ESRS disclosures", listed for S1 and G1-2.

Financial effects (pages 123-125). Climate mitigation investment "exceeding of around 52 million Euros" in 2025; adaptation measures "could represent climate-adaptation investments of EUR 1.5-3.0 million over the 2026-2030 period"; 29,754 lost days representing "an estimated financial impact of approximately EUR 4.4 million"; "Bnode did not incur any costs or damages related to extreme weather events in 2025" (page 123).

Resilience (page 130). "Overall, Bnode considers its strategy and business model to be resilient in addressing its material IROs over the short, medium, and long term.

Reference: page 131

"Bnode performed its DMA in 2 stages, first in 2023 and then it was refined in 2024 at sub-subtopic level and to integrate Staci. During the summer of 2025, Bnode reviewed its DMA" (page 131). It "is fully integrated with the Group's Enterprise Risk Management (ERM) framework".

Three steps (page 132). Understanding the context, including five value chains, one per type of business; identifying IROs through "an extensive analytical and consultative process in 2023" producing a long list "prepared in accordance with ESRS 1-AR16"; scoring at sub-subtopic level with an external expert.

Thresholds (page 134). "Impact Materiality = Severity * % Likelihood" (severity being the average of scale, scope and remediability) and "Financial Materiality = Magnitude * % Likelihood"; severity and magnitude scored 0-5, likelihood 0-6. Impact threshold 2.5, financial threshold 1.5.

Consultation (page 133). June-September 2023: "Internal interviews with 11 members of the top management; Internal stakeholder panels, 3 hybrid workshops; External stakeholder panel, 1 face to face in Brussels office; Online survey", involving suppliers, clients, unions, the Belgian postal regulator and "nature represented by an NGO".

2025 review (page 136). By the Group Sustainability Team "based on their experience, consultation of 23 internal stakeholders, 2 workshops". "Without changing the materiality conclusion, the financial magnitude score has been adjusted for Climate Change Adaptation (from minor to moderate)."

Stated limitation (page 132). For value chain workers, "Currently, there is limited visibility on this topic".

Reference: page 142

The index is delivered by cross-reference: "As a result of the Double Materiality Assessment the list of disclosures covered and related page number can be found in the table of content on the very top of this report. For the table of all the data points that derive from other EU legislation, see Appendix 9.6" (page 142).

That table of content (pages 87-89) is the operative ESRS index, listing each DR by code and title against a page: ESRS 2 BP-1 to IRO-2 (90-142), E1-1 to E1-9 (152-185), E2-1 to E2-6 (186-190), E5-1 to E5-6 (191-208), the S1 disclosures (221-272), S2-1 to S2-5 (275-282), S4-1 to S4-5 (283-294) and G1-1 to G1-6 (295-313). E3, E4 and S3 do not appear.

Appendix 9.6 (pages 453-459) lists EU-legislation datapoints with a materiality (Y/N) column, marking the E3-1 and E3-4, E4 IRO-1 and E4-2, and S3-1 and S3-4 datapoints "N" (pages 455-458).

Phase-ins elected (page 93). "Bnode has elected to apply the following phased-in provisions in line with ESRS 1 Appendix C": E1-9, E5-6 and "ESRS S1_S1-14 (Cases of work-related ill-health and on number of days lost... for non-employees)".

Incorporation by reference (page 93). Six datapoints: BP-1 5b(i), GOV-1 20(a) and 21(d), GOV-3 29(a), GOV-5 34 and IRO-2 56.

Reference: page 152

"Bnode has approved near and long-term science-based emissions reduction targets with the SBTi" (page 152), validated November 2025: Scope 1 & 2 -71.3% and Scope 3 -38.2% by 2035 against a 2024 baseline, -90.9% / -90.1% by 2050, with an internal 2030 milestone of -54% and -8%. "This transition plan was approved by Bnode's ESG Steering Committee in September 2025, and later validated by the Board" (page 153).

Six levers (pages 153-154): emission-free last-mile delivery (100% electric vans and 100% of parcels emission-free in Belgium by 2035); emission-free company cars; 100% green electricity by 2030; alternative-fuel trucks and double-deck trailers, with electric trucks "as of 2028-2030 when the technology is expected to be mature"; phasing out natural gas and heating oil; a Scope 3 programme.

Locked-in emissions (page 154). "Bnode does not have any significant potential locked-in emissions from key assets that might jeopardize achieving our 2035 GHG emission reduction target". The 10,383 delivery vans represented 27% of 2025 Scope 1 and 2 emissions and the 666 trucks 25%; "none have a leasing period extending beyond 2035"; "Our goal is to achieve a net-zero target by 2050 without forced decommissioning of locked-in assets."

Exclusions (pages 152-153). Outsourced air and maritime transport and fleet-production emissions are outside the 2035 target. Bnode "is not excluded under the EU PAB framework" (page 152).

Progress (page 156). "In 2025, we reduced our Scope 1 and 2 emissions by 10.8% compared to our 2024 baseline", with 2,818 charging stations (+418), 3,139 electric vans (+942), 54% emission-free company cars and 76% green electricity.

Reference: page 137

Back-filled from E1 ESRS 2 IRO-1 (pages 137-140) and E1 ESRS 2 SBM-3 Climate Risk Assessment (pages 144-146), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risks classified (page 144) explicitly into physical and transition, then tabulated as physical acute, physical chronic, transition risks and transition opportunities (pages 145-147).

Physical methodology (pages 137-139). A four-step "funnel-based approach": Step 1 exposure assessment of 346 buildings against all climate risks; Step 2 granular analysis of the 110 buildings exposed to floods; Step 3 vulnerability audits "Done for 5 strategic bpost NV/SA sites"; Step 4 adaptation plans. Nine hazards assessed "for two emissions scenarios (RCP2.6, RCP8.5) and three time periods (2030, 2050, and 2080/2100)" using WCRP CORDEX data plus WRI and JRC flood mapping. "Exposure of locations in the supply chain was not modelled explicitly."

High-emission scenario (page 139). "By considering the IPCC SSP5-8.5 scenario, Bnode modelled the potential impact of high emissions scenarios (> 4degC). For conservative reasons, this is the main scenario we have used."

Transition (pages 139-140). Two 2024 NGFS scenarios: Net-Zero 2050 (1.4degC) and NDC (2.3degC), with stated assumptions on carbon prices, technology, energy consumption and macro-economics; evaluated qualitatively via workshops and expert interviews, using the PESTEL framework (page 148).

Limitations. "As part of the DMA, Bnode did not perform climate scenario analysis" (page 137); "The outcome of the 2025 update of the Double Materiality Assessment... does not yet consider transition scenarios" (page 139). Also presented under ESRS 2 IRO-1 and E1 ESRS 2 SBM-3.

Reference: page 147

Back-filled from E1 ESRS 2 SBM-3 Resilience Analysis (pages 147-151), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Scope (page 147). "This assessment of physical risks encompassed all Bnode's global locations, though it did not include physical risks related to the value chain. For the evaluation of transition risks and opportunities, Bnode considered its own operations as well as the upstream and downstream value chain... conducted for the entire global scope of Bnode's business (all of Bpost, Paxon and Landmark Global)."

Date and horizons (page 148). Started in 2024, continued through 2025, "we expect to complete it over 2026 and 2027". "Short term = current and historical effects; Mid-term = 2030; Long-term = 2050."

Outcome (page 148). "Bnode's strategy and business model are resilient in relation to climate change. Although the Climate Risk Assessment is still underway, initial findings indicate that climate change is not expected to pose critical or fundamental threats to Bnode's future operations", physical risks being mitigable "thanks to the distributed nature of its operations" and insurance cover.

Results per risk (pages 149-151). Three tables give, per physical risk, transition risk and opportunity, the rating by scenario and horizon plus the resilience result and the adaptation action identified - for sorting centres, "risk is currently low to medium and can be reduced to low with a limited set of measures".

Capacity to adapt and uncertainty (page 151). "Bnode currently doesn't anticipate obstacles in its ability to adapt its strategy or business model... we do not see significant areas of uncertainties."

Reference: page 157

Climate policy sits in a single Environment Policy covering all material environmental sub-subtopics: for E1, "Decarbonize the e-commerce and third-party logistics supply chain" over Scope 1, 2 and 3 emissions and energy; for E2, air pollution (NOx); for E5, recyclable and reusable packaging (page 157).

Scope (page 157). "all employees within bpost NV/SA and its subsidiaries... as well as persons closely connected with Bnode's activities and operations who are not employees but to whom this Policy is communicated", including directors, temporary workers, trainees and contractors. "Exclusions apply to individuals or entities not explicitly communicated with this Policy." Suppliers are asked to adhere via the Supplier Code of Conduct.

Third-party standards (page 158). ESRS policy requirements and "A standard environmental policy process outlined by EcoVadis", with validation by the Group Sustainability Department Head, review by Group Compliance, ExCo validation, ESG Committee advice and Board validation.

Accountability (page 158). "Bnode's CEO, along with the Executive Committee, holds overall accountability for the environmental impact of Bnode. The environmental policy was validated by the Executive Committee and the Board in April 2025." Published online "in multiple local languages".

Gap worth noting: the main principles of conduct are not reproduced - they "can be found in the Environment policy on our website" (page 158). A version 2 including the new SBTi targets is due online in 2026.

Reference: page 159

Per-lever 2025 effect and investment (page 159): emission-free last-mile delivery -1.7 kt CO2e and EUR 32.6 million; green electricity -4 kt CO2e and EUR 1.5 million; phasing out natural gas and heating oil -0.5 kt CO2e and EUR 0.92 million.

Financing (page 160). "Bnode invested around 52 million euros in 2025 for the implementation of its climate transition plan... Taxonomy aligned Capex amounts to 34.9 million euros." The gap is explained by eligible-but-unaligned charging stations, solar panels and efficiency investments (EUR 9.35 million, lacking DNSH Appendix C documentation), electric cars and e-trucks (EUR 16 million, "for lack of evidence on the DNSH 'tire' criteria") and non-eligible double-deck trailers (EUR 0.9 million). "Climate Transition Plan-related investments were entirely funded from internal resources, with no use of sustainable finance instruments... There are no references to those investments in the notes from the financial statement."

Fleet and network (pages 160-163). 3,129 e-vans, "a 30% electrified last mile fleet", 1,300 combustion vans disposed of, 610 e-bike trailers, 21 Ecozones rising to 25 by Q1 2026. From October 2025 Brussels parcel and mail delivery is emission-free: "750 tons of CO2 saved per year; 12,830 kilometers driven per day by electric vehicles and bike trailers". Charging points reached 2,818 against a 2030 ambition above 4,500; Bboxes doubled to 2,500 with 162,500 locker doors.

Energy and trucks (pages 164-167). 90,000 m2 of solar panels group-wide, plus 86,500 m2 in Belgium by 2029; the CO2-neutral Charleroi mail centre; 37 double-deck trailers and "115 trucks on alternative fuel or Double Deck Trailers" by March 2026.

Scope 3 (pages 168-170). The Carbon Coach Project with Climact (eight SME suppliers, November 2025) and a Transport Centre of Excellence plan "to reduce emissions by 44% by 2035... and by at least 95% by 2050" for subcontracted road transport.

Reference: page 172

Targets were set "using 2024 as the baseline year" and "have been externally assured and validated by SBTi" in November 2025 (pages 172-173).

Targets and 2025 status, including Staci (page 173):

• Scope 1 & 2 market-based: -71.3% by 2035, -90.9% by 2050; baseline Scope 1 80,717 tCO2e, Scope 2 29,804 tCO2e, total 110,521 tCO2e; status -10.8%
• Scope 3: -38.2% by 2035, -90.1% by 2050; baseline 419,684 tCO2e; status 0%

Excluding Staci: -6.2% and -1.5% against baselines of 98,642 and 320,757 tCO2e.

Scope and coverage (page 172). Operational control. "Currently, there are no separate reduction targets for Scope 1 and Scope 2 emissions, nor for location-based emissions. The targets do not include GHG removals, carbon credits, or avoided emissions." All seven Kyoto gases where applicable. Scope 1 and 2 are "in line with a 1.5degC scenario" while Scope 3 is "in line with a <2degC scenario for our 2035 target and in line with a 1.5degC scenario for our 2050 target".

Method and assumptions (pages 172-173). Set under the SBTi framework after consultation including the CEO, CFO and ESG Steering Committee plus benchmarking by "a leading strategic consulting firm"; footnote 10 records "Bnode did not use a sectoral nor a cross-sectorial decarbonization pathway". Business growth is assumed "in line with its long term plan until 2030 and at the same speed as the GDP afterwards", with external experts confirming "there are currently no global large-scale solutions that would be available in time for urgent transcontinental transport".

Reference: page 174

Total energy consumption (page 174), MWh, 2025 with Staci / 2025 without / 2024 without:

• Crude oil and petroleum products 214,038 / 209,915 / 224,671
• Natural gas 113,009 / 96,912 / 93,381
• Purchased electricity, heat, steam and cooling from fossil sources 30,905 / 27,544 / 36,820
• Total fossil 357,953 / 334,372 / 354,872, a 73% share
• Nuclear 8,129 / 5,988 / 10,889 (2%)
• Renewable fuel 740; purchased renewable 114,158; self-generated non-fuel renewable 9,014
• Total renewable 123,912 / 108,805 / 104,763, a 25% share (24% excluding Staci, up from 22%)
• Total 489,993 / 449,165 / 470,525

Coal and other fossil sources are nil throughout. "In 2025, excluding Staci, our total energy consumption decreased by 5% compared with 2024... Key contributors included the electrification of our fleet, the rollout of Bbox parcel lockers in Belgium... the growth of self-generated renewable electricity and the closure of a limited number of buildings" (page 174).

Production (page 175). 14,839 MWh, entirely renewable, "a significant increase of around 30% compared with 2024" (11,399 MWh).

Intensity (page 176). 109.3 MWh per million euros of net revenue, down 7% from 117.5. "Bnode operates in sectors identified as having a high climate impact, as listed in NACE Section H: Transport and Storage... H49.4.1 (Freight Transport by Road) and H53 (Postal and Courier Activities)", so all net revenue is attributable to high-climate-impact sectors. Figures are net calorific value; building data comes from utility bills and fleet data from fuel receipts or card invoices.

Reference: page 177

Gross emissions, tCO2eq, 2024 with Staci (base year) / 2025 with Staci / change (pages 177-178):

• Scope 1 80,717 / 78,729 / -2%: stationary 21,875 / 22,324, mobile 58,128 / 55,838, fugitive 714 / 567
• Scope 2 location-based 43,509 / 44,679 / +3%; market-based 29,804 / 19,893 / -33%
• Scope 3 419,684 / 419,874 / 0%: purchased goods and services 125,544 (+7%), capital goods 25,579 (-8%), fuel and energy-related 25,860 (-9%), upstream transport and distribution 197,502 (-1%), waste 4,142 (-21%), business travel 2,018 (-18%), employee commuting 39,230 (-1%)
• Total market-based 530,205 / 518,496 / -2%; location-based 543,910 / 543,282

Milestone columns give 2035 and 2050 values of 31,682 and 10,088 tCO2e for Scope 1 & 2 and 204,939 and 37,462 tCO2e for Scope 3.

Intensity (page 184). Market-based per net revenue rose to 115.7 from 104.8 tCO2eq per million euros (+10%), "primarily as a result of the integration of Staci".

Method (pages 179-184). GHG Protocol standards, operational control, factors from DEFRA, AIB, IEA, eGRID, Government of Canada, IPCC AR5/AR6 and S&P. "23% of Scope 3 emissions were based on supplier or value-chain primary data" (page 182). Categories 8-15 are excluded with a reason per category (page 181). Green electricity contracts cover 36.6% of purchased electricity, Guarantees of Origin 19.2%, RECs 11.4%, PPAs nil.

FY2024 restatements (pages 92, 180). FLAG added (+1,812), fleet-leasing removed (-14,471) and building emissions moved to capital goods (9,107 tCO2e); "FLAG emissions for FY2024 have not been audited by EY".

Reference: page 185

A nil return. "At Bnode, we do not include GHG removals or carbon credits as a means of achieving our GHG emission reduction targets" (page 185).

This is consistent with the target disclosure: "The targets do not include GHG removals, carbon credits, or avoided emissions, focusing solely on direct reductions in Bnode's operational and value chain emissions" (page 172), and with the reporting boundary, where "GHG removals, carbon credits, and GHG allowances are excluded from the calculations" (page 180).

Residual emissions are addressed only at the far end of the trajectory: "Once we have achieved our long-term science-based target and reduced our emissions by more than 90%, we will address the small share of residual emissions that cannot be eliminated by investing in durable, permanent carbon removal solutions. In line with the Science Based Targets initiative (SBTi) Net-Zero Standard, these residual emissions will be neutralized through high-quality carbon removal and long-term storage approaches" (page 152). No removals, credits or neutralisation volumes are reported for 2025.

Reference: page 185

A nil return with a stated intention. "Currently, Bnode does not have any internal carbon pricing schemes in place. However, we plan to analyze the opportunity of implementing a carbon pricing system, a carbon budget, or a similar mechanism in the future to better link our projects, initiatives, and plans with our carbon emissions targets" (page 185).

No internal carbon price, no coverage of Scope 1, 2 or 3 emissions by a shadow price, and no use of carbon pricing in investment decisions are therefore reported. External carbon pricing is discussed instead: the EU Emissions Trading System 2 "from 2028 onward will directly affect the cost of fossil fuels used for our fleet and for heating our buildings" and is identified as one of the two most significant transition risks (pages 124, 146), and "Reducing our dependency on fossil fuels will also help limit the financial impact of carbon taxation (ETS2), expected to apply from 2028 onward" (page 126). Investment decisions are screened instead through a tool that reviews new strategic projects "through the lens of the identified material IROs", enriched in 2025 "to also consider the impact of our investments on our climate resilience and on our degree of alignment towards the EU taxonomy" (page 125).

Reference: page 185

Listed in the content index at page 185, where the disclosure is made by cross-reference: "In 2025, we deepened our analysis of identified physical and transition risks to assess their financial magnitude across the group in a qualitative way. For the 2025 results, please refer to section 6.2.1.1 E1 ESRS2 SBM-3 Climate Risk Assessment" (page 185).

Caveat on completeness. Bnode elected the ESRS 1 Appendix C phase-in for E1-9 (page 93), so the quantified monetary amounts the requirement asks for are not provided.

What is disclosed instead (pages 145-147). Qualitative financial magnitude ratings (Very low to High) per risk, per scenario (RCP 2.6 and RCP 8.5 for physical, Net-Zero 2050 and NDC for transition) and per horizon. "The largest financial risk stems from the damage to property, equipment and customer stock and from the operations of disruptions that could be caused by extreme weather events. This risk is currently limited but could become significant in the long term under a high emission scenario if no adaptation measures are in place" (page 145). "The two most significant transition risks are (1) Carbon Taxation which should be implemented in the EU as of 2028 with the ETS2 mechanism and (2) our dependance on subcontractors for decarbonization" (page 146).

Quantified elements elsewhere (pages 123, 140). Adaptation measures identified after the flood audits "could represent climate-adaptation investments of EUR 1.5-3.0 million over the 2026-2030 period"; and "no climate-related provisions or accelerated asset depreciation have been made".

Reference: page 186

Pollution is covered by the same Environment Policy as climate. "The Environmental Policy was developed following stakeholder consultations conducted during the DMA... including feedback from panelists such as Natuurpunt and Bpost's waste management supplier, Renewi" (page 186).

Content for air pollution in own operations (page 186):

1. Address identified adverse impacts on air quality - "Collect the necessary data to develop emission inventories for major pollutants associated with our activities, i.e. NOx" and "Quantify air pollution generated by our operations and products."
2. Implement reduction programmes through decarbonisation and fleet electrification - "All newly leased vehicles must be either an Electric Vehicle, or else equipped with a Euro 6 engine."

Stated boundaries (page 186). "The Environmental Policy focuses on air pollution, as it is the only pollution-related sub-topic identified as material. Consequently, it does not address water and soil pollution, substances of concern, substances of very high concern, or incident prevention, as these sub-topics have been assessed as not material to Bnode. However, Bnode will continue to monitor these areas through its regular DMA updates and ISO 14001 certification process."

"The Pollution section of the Environmental Policy does not refer to third-party standards." On emergency preparedness: "The company does not directly process pollutants... Therefore, the Environmental Policy on Air Pollution does not include specific measures for incident and emergency prevention".

Reference: page 187

"Since air pollution is almost exclusively generated by fuel combustion in our vehicles and buildings, it is closely correlated with CO2e emissions. The actions we take to reduce CO2e emissions also contribute to reducing air pollution" (page 187).

2025 actions for bpost NV/SA, the air pollution scope (page 187): 932 e-vans delivered, taking e-vans to 30% of the fleet with about 1,000 more expected in 2026; Ecozones "increasing from 14 in 2023 to 21 by the end of 2025 and 25 by the end of Q1 2026 and the ambition to reach 200 emission free zip codes by the end of 2026 (vs 107 at the end of 2025)"; 168 additional e-bike trailers taking the total to 610; and "100% of new company cars delivered in 2025 are electric".

Measured effect. "The actions listed above resulted in 4% reduction in bpost NV/SA's Scope 1 Fleet's CO2 emissions in 2025 compared to 2024."

Two pollution-specific actions with KPIs (page 187): Euro 6d engines for all new leases, target end-2026 - "100%, from Jan 2025, all new leasing thermic vehicles are euro 6d or better"; and end of life for leased diesel vans below Euro 6, target end-2026 - "99.7%. Number of leased vans with euro emission standard older than euro 6: 31 in 2025 vs 60 in 2024".

Resources. "allocated resources for the above action are not significant, hence no disclosure is required. The most significant allocated resources, contributing to mitigate air pollution, are linked to Climate Change and described in part E1-3".

Reference: page 188

"Although the core targets for addressing air pollution are covered under Climate Change (E1), bpost NV/SA has also set additional, specific targets related to air pollution within its own operations. All targets outlined below are voluntary" (page 188).

Targets, all scoped to bpost NV/SA (page 188):

• Share of vans electric: baseline 22% (2024), 2025 progress 30%, target 100% by 2030
• Share of new company cars fully electric: baseline 94.5%+, progress 100%, target 100% by 2030
• Share of all diesel vehicles Euro 6: baseline 98.5%, progress 98.3%, target 100% by 2026, policy goal "All diesel vehicles must have particle filter installed"

Rationale (page 188). "According to PNAS, electric vehicles do not emit NOx as they operate without combustion. Additionally, data from the European Environment Agency (EEA) Emission Factor Data Viewer confirms that the latest Euro emission standards are designed to significantly reduce NOx emissions." Targets were set by the ESG team with the bpost NV/SA fleet manager "based on the bpost NV/SA fleet renewal plan".

Stated boundaries (page 188). "Bnode's targets do not address water pollution, soil pollution, substances of concern, or substances of very high concern, as these have been assessed as not material to the company." And "as a service company, specific air pollutant load measurements are not applicable". "Targets and method are stable, same as in 2024", expressed in relative terms; the scope was narrowed from all entities to bpost NV/SA for consistency with the DMA.

Reference: page 189

The only pollutant reported is NOx, consistent with air pollution being the single material E2 sub-topic.

Scope (page 189). "The focus is on bpost NV/SA, which accounts for more than 95% of Scope 1 fleet emissions... The remaining 5% are split among various geographies including North America."

Results (page 190), metric tonnes: light and heavy-duty vehicles 38.5 against 72.6 in 2024, -47.0%; company cars 1.0 against 1.6, -38.3%; total 39.5 against 74.3, -46.8%.

Drivers (page 190). "In 2024, within this segment, 2,625 vehicles with older Euro emission standards... are responsible for 60% of NOx emissions. In 2025, such vehicles with older emission standards drop to 133 vehicles." For cars, "the share of EV out of total kilometres driven by company cars reaches 40% vs 21% in 2024".

Method (page 189). "NOx emissions = Kilometers driven per vehicle type x Emission factors", vehicle type defined by fuel, gross weight and Euro standard, factors "sourced from the European Environment Agency (EEA)". Kilometres come from odometer differences collected via telematics in FleetWave; where a Euro standard is missing, "To be conservative, the minimum Euro emission standard required for that year is applied".

Assurance caveat. "The measurement of the metric is not validated by an external body." No water, soil or microplastics amounts are reported, consistent with the materiality conclusion at page 186.

Reference: page 191

"The Bnode's Environment policy includes two dedicated paragraphs outlining main principles of conduct specific to Waste & Packaging... The three material sub-subtopics - resource inflow, resource outflow and waste management (cf. E5.IRO-1) - are addressed by the policy" (page 191).

Waste commitments (page 191): increasing sorted waste, including "minimising unsortable dual-component packaging sold in our retail network" and improving sorting infrastructure; reducing plastic waste, where "operational teams will prioritize bio plastic over non bio plastic"; enhancing recycling, "ensuring that no recyclable waste is sent to landfill"; and reducing waste intensity per unit of revenue.

Packaging commitments (page 192): reusable containers for internal flows - "bpost NV/SA, our largest entity by both revenue and FTEs, already use reusable packaging exclusively for all internal flows"; encouraging reusability; maximising recyclability - "We are committed to ensuring that most of our packaging is recyclable or reusable, currently at 94.3%. Our goal is to achieve 100% recyclable content in our cardboard and envelope packaging by 2030... we will progressively stop selling double-component packaging, aiming for zero by 2030"; increasing recycled content; and reducing packaging weight per shipped parcel.

Background, accountability and validation follow the Environment Policy described under E1-2 (pages 157-158).

Reference: page 193

Actions are tabulated with scope, KPI, time horizon, 2025 progress and resource type (page 194).

Waste. An audit by entity "to understand the sorting rate and the reasons for the lack of sorting", covering entities making up at least 90% of non-sorted waste with a focus on bpost NV/SA and Radial US: "It should start in 2026 following operational reorganization in 2025."

Packaging. RFP modification for circularity by end-2029 - "We are increasingly including requirement for a minimum of 80% recycled content into our cardboard RFP's"; a recyclable alternative to double-component bubble envelopes, end-2026, "Done. In the new framework agreement with our packaging supplier, an alternative to double-component is available"; and fit-for-purpose packaging at Paxon entities, ongoing with "Active Ants and tailored cardboard cut".

Combined. Reusable packaging evaluation by end-2027 - "End of work with Hipli but continued work with Re-Zip and starting a new reusable packaging solutions pilot with 2 sustainability minded retailers. (Juttu... and Torfs)".

Resourcing (page 194). "The action plan on Circularity does not require significant OPEX or CAPEX, neither currently, nor in coming three years."

2025 initiatives (pages 195-196). At bpost NV/SA, unsorted waste fell from 35% in 2024 to 20% by end-2025, with "expected annual cost savings of around EUR 200K". At Eurodislog, "Initially, 30 tons of waste were downgraded and only three tons valorized... In 2025, close to 100% valorization was achieved." Dynalogic Breda runs a circular styrofoam stream; Staci France turns cardboard waste into filler using an inclusive-work partner.

Reference: page 197

Targets are set per KPI with entity scope, 2025 value with and without Staci, baseline, target and year (page 198).

Packaging: recyclable or re-usable packaging - Retail 96.6% (baseline 86.3%, 2022), target 100% by 2030; Fulfilment 99.1%. Recycled materials sourced - Retail 83.9%, target 80% by 2030; Fulfilment 37.1%. Double-component (unsortable) packaging - Retail 3.4% against an 8.2% 2024 baseline, target 0% by 2030, "Target in line with PPWR (article 6, paragraphs 1 and 2)". Packaging intensity 314 gr per shipped parcel, a new KPI with target "TBD".

Waste (all entities): waste not sorted and not recycled 21.8% (17.4% excluding Staci) against a 21.7% baseline, target maximum 15% by 2030, "Target in line with Cooperation Agreement on Waste in Belgium"; plastic waste recycled, reused or recovered 99.4% against a 95% target; paper and cardboard 98.6% against 98%, both "strictly above PPWR minimum requirement"; waste intensity 14.5 gr per euro of revenue against 16.0, target "TBD".

Review (page 199). Bi-annual review by the ESG team and ESG Steering Committee, quarterly operational reviews and "At least yearly, Target and KPI Review".

Method (page 200). KPIs drawn from prior reporting, regulation (PPWR, the Belgian Cooperation Agreement), material activity-specific indicators and peer benchmarks; consultations "were held throughout 2024". Worst case applies where evidence is missing. Two of eight KPIs carry no quantified target, stated plainly.

Reference: page 201

Boundary (page 201). "This section of disclosure requirement E5-4 refers to packaging as our resource inflow. Products transiting through Bnode's facilities are held by Bnode's customers and are therefore not the responsibility of Bnode. Consequently, Bnode is only responsible for the packaging it purchases."

Metrics (page 201), 2025 Bnode / 2025 without Staci / 2024 without Staci:

• Paragraph 31(a) total weight of packaging: 33,897 / 20,962 / 17,873 metric tonnes
• 31(b) percentage of biological materials sustainably sourced with a certificate such as FSC or PEFC: 52.1% / 73.2% / not available based on new methodology
• 31(c) secondary reused or recycled components and materials: 18,853 / 12,587 / 11,269 tonnes, and 55.6% / 60.0% / not available

Certification and composition (page 202). "Sustainable sourcing is ensured through third-party certification schemes, primarily: Forest Stewardship Council (FSC) (97%)... Other certification (3%), such as PEFC". "Biological materials represents 81.7% of packaging mass... the majority of the materials used in the packaging are cardboard, paper and wooden pallet." Fulfilment accounts for 90% of packaging mass. "increase of total mass in 2025 vs 2024, i.e. 17%, is driven by better data capture for this second year of reporting."

Data quality (pages 202-203). "In 2025, 10.0% of packaging weight is estimated"; worst case applies where evidence is missing. Template fields were expanded in 2025, which "explain the appearance of performance decrease in 2025 vs 2024". "None of the metrics have been validated by an external body".

Reference: page 204

Boundary (page 204). "this report primarily focusses on the waste aspect of resource outflows since packaging is not modified in any way after inflows in Bnode's facilities, so its nature remains unchanged (e.g. packaging is folded only, with no material added or removed)", so packaging outflow characteristics "remain unchanged as the packaging only moves through Bnode's facilities".

Paragraph 36(c) (page 207). Rate of recyclable content in products and their packaging: 99.3% with Staci, 99.1% without, 99.4% in 2024.

Paragraph 37 metrics (page 207), 2025 with Staci / 2025 without / 2024 without, tonnes:

• Total waste generated 65,166 / 52,337 / 49,182
• Hazardous waste diverted from disposal 1,846 / 1,806 / 1,672 (recycling 1,744.8)
• Non-hazardous waste diverted 56,101 / 45,575 / 42,899, of which recycling 47,696 / 40,426 / 23,137, preparation for reuse 1,468, other recovery 6,938
• Hazardous directed to disposal 222 (incineration 63, landfill 153); non-hazardous directed to disposal 6,997 (incineration 287, landfill 6,710)
• Non-recycled waste 11,360 / 7,629 / 10,689, i.e. 21.8% / 17.4% / 21.7%

Commentary (pages 207-208). "78.2% of the waste is recycled and 88.9% is diverted from disposal"; excluding Staci the recycled rate "reached 82.6%, +4.4 points vs 2024". Caveats stated plainly: "6,863 metric tons or 10.5%, of the waste is still being landfilled or assumed as such due to current lack of evidence (worst case scenario approach)"; "The total percentage of estimated data is 12.6% of waste weight"; "None of the above metrics are validated by an external body".

Reference: page 204

Sources (page 204). "Waste is generated at Bnode through various processes, such as removing plastic film from pallets, cardboard used in shipping and distribution, electronic waste from faulty equipment." Most common types: mixed paper and board, average plastics, wood (typically pallets) and commercial and industrial residual waste.

Composition (page 205), 2025 with Staci / 2025 without / 2024 without, tonnes and share:

• Total 65,166 (100%) / 52,337 / 49,182
• Hazardous 2,068 (3.2%) / 1,959 / 1,778; non-hazardous 63,098 (96.8%)
• Paper and board 38,237 (58.7%); plastics 1,245 (1.9%); wood 2,734 (4.2%); commercial and industrial 13,010 (20.0%); WEEE 8,667 (13.3%); batteries 17; others 1,256

"98.8% of WEEE weight comes from entity Dynagroup whose core business includes installation and reparation of white goods, IT and Telecom equipment" (page 205). Hazardous waste is "mainly coming from activities from Dynagroup, such as batteries and other electronic waste. 84.5% of the hazardous waste gets recycled" (page 207).

Treatment differences (page 205). "each entity manages its waste differently, aligned with local legislation and practice... the degree of recycling varies significantly depending on the capabilities of the recycling companies... While some entities (e.g. Europe) have historically had a detailed data granularity given local legislation, others (e.g. US) still have a lower level of data maturity."

Targets (page 198). Waste not sorted and not recycled 21.8% against a maximum of 15% by 2030; plastic recovered 99.4% against 95%; paper and cardboard 98.6% against 98%; waste intensity down from 16.0 to 14.5 grams per euro.

Reference: page 226

Three policies are disclosed: the Code of Conduct, the Speak Up policy and the Diversity policy (page 226).

Framework (page 226). "As the group currently undergoes transformation, many policies still remain at the entity level in 2025." A policy framework "adopted and published... in February 2025" governs creation, validation and implementation and "is re-validated each year during the first quarter"; policies are validated by the relevant senior management forum and, where needed, the Board, with unions consulted locally.

Code of Conduct (page 227). Adopted by the Board on 7 November 2018, last updated 9 December 2022; covers employment relationships, commercial relationships, personal data, communication and sustainability; applies to all employees plus directors, consultants, temporary workers, trainees and contractors; "The Board of Directors is the most senior accountable body."

Speak Up policy (page 227). Covers employees, former employees, external workers, subcontractors and suppliers; "The compliance department is the most senior accountable body."

Diversity policy (page 228). "In 2024, our organization did not yet have a single, aggregated diversity policy at the group level... we took an important step forward in 2025 by developing the Bnode diversity policy. This policy is, currently under validation" and "should be published during 2026" (page 116). Staci France introduced its own in 2025; Radial North America applies local handbook guidelines.

Stated gap (page 226). "Bnode does not have an aggregated policy for workplace accident prevention at group level, due to strong differences in local legislation."

Reference: page 229

Group mechanisms (page 229). The My Voice survey runs twice a year - "In 2025, it reached a 44% participation rate and highlighted a strong score of 4.1 out of 5 on the 'appreciation' driver." Others: the Speak Up tool; "monthly individual well-being interviews" plus "a dedicated well-being team composed of experts in Diversity, Equity and Inclusion (DEI), absenteeism, and overall wellbeing"; target setting where "For topics with significant impact on employees, unions or workforce representatives are included in discussions"; and policy development, where "all policies impacting employees... require consultation with unions".

Entity mechanisms (pages 230-231). bpost NV/SA: performance reviews at least twice a year, a Leadership Model on the MIT 4-CAP framework, consultation committees meeting "monthly (or every two months as needed)", Employee Resource Groups (XandY, Pride2b, Young) and dialogue with the prevention committee on the green transition. A named outcome: "employee input has directly shaped decisions, including declaring vacant contractual positions and reinstating part-time work at 40% for medically challenged employees". Radial North America adds the Workstep survey; Staci France a digital idea box under its Quality of Work Life agreement.

Agreements (page 232). "Bnode does not have a Global Framework Agreement (GFA) at group level." bpost NV/SA negotiates "a company collective labor agreement with the trade unions" on a bi-annual basis.

Responsibility (page 234). Held by people managers, supported by HR Business Partners, well-being teams and Health & Safety teams; no single senior role is named.

Reference: page 234

Two group channels plus local mechanisms: "Speak Up, as a grievance mechanism that enables the workforce to submit concerns... [and] My Voice, that can help raise problems through its fulfillment two times a year" (pages 234-235). "Across the group, the formal reporting process is well known; however, most employees prefer to raise concerns informally by discussing them directly with their manager or HR representative."

Awareness (page 234). Channels are communicated "during the mandatory Code of Conduct training, which is required for all employees and has been followed by 98% of employees in 2025".

bpost NV/SA remediation (pages 235-236). Post-event risk analyses "triggered when signs of disruption or distress emerge", using "semi-structured individual interviews (lasting 1-1.5 hours) that explore the five well-being domains defined by the Well-being at Work Legislation (4 August 1996)". A worked example: "a risk analysis conducted in a retail cluster in Brussels revealed a lack of transparency in procedures, leading to corrective actions implemented nationwide". Support runs through "a network of 12 social assistants and 3 psychosocial prevention advisors serving all Belgian regions", with "a critical incident emergency number... available 24/7".

Effectiveness (page 237). Each site prepares an annual report on health and safety data, formal complaints and psychosocial risk analyses; "the Privacy and Compliance team provides quarterly compliance reports to the Executive Committee and the Board's Audit, Risk, and Compliance Committee".

Scope limit (page 238). "Reports concerning psychosocial risks at bpost NV/SA are excluded from the Speak Up tool, as they fall under Belgian wellbeing legislation".

Reference: page 239

Actions appear in three grouped sections, each headed "S1-4 Actions, S1-5 Targets and Metrics": workforce diversity and compensation (page 239), collective bargaining and human rights (page 252) and workplace health, integration and skills (page 259). The S1 IRO table maps actions to each material sub-sub-topic (page 225).

Diversity and inclusion (pages 239-242). The gender action plan covers "strengthening transparency and frequency of reporting to the Board", diversity training for recruiters and people managers, and "embedding balanced representation into key people processes (recruitment processes and succession planning)". Named initiatives: age-inclusive careers and a Young Talent Program at bpost NV/SA; at Radial North America "an expanded family planning and extended healthcare benefits program... related to in vitro fertilization (IVF), adoption, pregnancy, menopause", and a 401(k) participation drive for hourly workers; Employee Resource Groups at both entities; disability inclusion at Staci France, which reports "an employment rate of 4.2% for people with disabilities".

Health, safety and well-being (pages 261-263). "The Safety Games engaged over 10,000 employees at bpost NV/SA in 2025"; the Points mobile tool for route risks; ProcessMaster, "an AI powered safety software platform", at Radial North America with bi-annual corporate and monthly site audits; posture training producing "more than 500 ergonomic ambassadors"; a Mammobus at Staci France; Mental Move at Base Logistics, "reducing waiting times for mental health support from several weeks to just one week".

Skills (page 270). A Staci UK apprenticeship "supported by an investment of more than GBP 100,000", the Apple Express Learning Academy and the two-year Bpost Traineeship Program.

Resources (page 238). bpost NV/SA allocates "an active HR team, involvement of the entire management layer, and dedicated budgets"; Radial North America "approximately 50 HR professionals".

Reference: page 224

"In 2025, to address the key social impacts, risks and opportunities (IROs) identified through our double materiality assessment, we developed a focused set of 2030 social targets" (page 224).

The five group targets (page 224):

• "By 2030, we aim to reach 40% women in management positions", phased 40-40-20 for Management by end-2027, Group Leadership Team 2028, Group Top Management 2029, ExCo 2030 (page 239)
• "a target to reduce the lost time frequency rate (LTFR) by 30% by 2030", 2025 baseline (page 259)
• "an average of 32 hours of training per employee per year by 2030"
• "our ambition to retain 85% of new hires after one year"
• An entity-specific target "to reduce sickness-related absenteeism to 8.2% by 2031" at bpost NV/SA

On violence and harassment, "we maintain our existing commitment to zero tolerance".

Where no targets are set (page 224). "For the remaining disclosures - S1-8, S1-15, S1-16 - no specific quantitative targets have been set at this stage. While formal targets are not yet established for these topics, performance is regularly monitored... the ongoing focus is to strengthen key foundations such as policies, data quality, governance structures and reporting frameworks."

Setting and tracking (pages 224, 229). "Stakeholders, including HR leadership were closely involved in the target-setting process. Performance will be tracked two times a year by the ESG team as well as on entity-level." Targets "undergo a formal validation process, up to Board level", after which "Top-performing and lower-performing entities are identified and engaged in developing improvement plans".

Reference: page 239

"Bnode (including Staci) is a large logistics group with more than 33,532 internals employees worldwide, including 11,453 women, 21,857 men, 221 undisclosed and 1 other. About 76,81% of our employees are based in Belgium" (page 239).

By gender at 31 December (page 243), 2025 / 2025 without Staci / 2024: male 21,857 (65.18%) / 20,348 / 21,480; female 11,453 (34.16%) / 9,951 / 11,084; other 1; undisclosed 221 / 59 / 159; total 33,532 / 30,359 / 32,723. Belgium 25,755 / 25,643 / 26,628.

By contract type (page 243): permanent 30,963; temporary 2,569; non-guaranteed hours 282. "Approximately 92% of Bnode workforce (including Staci) is employed on full-time contracts, while temporary personnel... represent about 8%... below the Organization for Economic Co operation and Development (OECD) average of 16% (2022)."

By age (page 246): under 30 15.24%; 30 to 50 47.89%; over 50 36.87%.

Turnover (page 246): 6,545 leavers, 15.03% turnover and 84.97% retention (2024: 18.02%); new-hire turnover 19.45%, retention 80.55% (2024: 25.06%).

Methodology caveat (page 247). "Last year, the turnover rate was overestimated because some terminations of fixed term contracts were counted as turnover... Due to this methodological refinement, year-on-year comparisons with prior periods should be interpreted with caution." Figures are headcount at 31 December with no averaging; related metrics are cross-referenced to note 6.12 of the financial statements.

Reference: page 248

"A part of Bnode's workforce is made up of non-employees, including individuals employed by third-party contractors and self-employed professionals" (page 248).

Numbers (page 248): 9,616 non-employees (headcount) in 2025, 8,082 excluding Staci, against 9,533 in 2024.

Purpose and protections (page 248). "Bnode employs external workers primarily to manage for temporary absences (e.g. illness). This approach provides the necessary flexibility to meet short-term operational needs while maintaining stability in long-term employment. External workers (e.g. interim) are provided with social protections and benefits in line with local requirements, mainly via their interim agency with whom they have an employment contract, ensuring they are supported even during brief employment periods."

Methodology (page 248). "Our reporting on non-employees is based on end-of-year (EOY) figures... All figures reported are based on actual data, without reliance on estimates. The data is captured in headcount... collected directly from our workforce management systems." Only external workers active on 31 December 2025 are counted.

The boundary is set under S1-6: "individuals who do not have an employment relationship with Bnode and who provide services under a commercial or service contract are classified as external workers" (page 244).

Caveats: the total is not split between agency-supplied and self-employed workers, and non-employee ill-health and lost-day data is omitted under the S1-14 phase-in (pages 93, 264).

Reference: page 252

"We respect and value employees' rights to freedom of association and collective bargaining, as outlined in our Human Rights Policy and Code of Conduct... Collective bargaining agreements are negotiated at local level... Participation in unions or workers' councils is voluntary and protected from any kind of discrimination or retaliation" (page 252).

Coverage (pages 252-253):

• "in 2025, 76.88% of Bnode's employees (including Staci) were covered by collective bargaining agreements, compared with 80.39% when excluding Staci"
• "44.20% of Bnode's employees (including Staci) were represented by workers' representatives, and 42.96% when excluding Staci"
• "Within the European Economic Area (EEA), 88.83% of employees were covered... Outside of EEA, 1.31% of employees are covered"
• "In the EEA, 51.11% of employees (including Staci) were represented by workers' representatives"
• Belgium, the only country meeting the significant-employment threshold: 94.13% covered, placed in the 80-100% coverage band and the 40-59% workplace representation band

European works council (page 252). "There is no agreement with employees for representation by European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea (SCE) Works Council."

Data limitation (page 253). "Trade union membership data is not collected or processed due to GDPR restrictions. The assessment relies on existing HR flags and organizational records and does not involve employee surveys."

No quantitative target is set for S1-8 (page 224).

Reference: page 245

Gender diversity in management (page 245), 2025 with Staci / 2025 without / 2024:

• Top management headcount: male 356 / 314 / 274; female 157 / 144 / 126; undisclosed 2
• Top management share: male 69.13%; female 30.49% / 31.30% / 31.19%
• Management headcount: male 2,210 / 1,861 / 1,920; female 1,386 / 1,163 / 1,204; other 1; undisclosed 95
• Management share: male 59.86%; female 37.54% / 38.17% / 38.01%

Age distribution (page 246): under 30 15.24%; 30 to 50 47.89%; over 50 36.87%.

Target (page 239). "Management level: 40-40-20 by end of 2027; Group Leadership Team (GLT): 40-40-20 by 2028; Group Top Management (GTM): 40-40-20 by 2029; Executive Committee (ExCo): 40-40-20 by 2030." "Progress against these targets is monitored through bi-annual reporting on workforce composition, management representation and gender distribution" to the Board and ESG Steering Committee (page 240).

Definitions (page 245). GTM covers ExCo members, their senior-management direct reports (banding 3.1 at bpost NV/SA) and "selected operational leaders lower in the hierarchy who manage large operational units (for example, managers of sorting centers)"; GLT covers banding 3.2 and above plus banding 3.1 at N-2 or below. "the list of top management is a closed list defined and regularly maintained by HR."

No data on employees with disabilities is reported at group level.

Reference: page 267

Target (page 267). "In 2025, Bnode introduced a new group-level target: by 2030, the group aims to reach an average of 32 hours of training and development per year per internal employee", requiring "improved tracking and monitoring of training hours across Bnode".

Metrics (page 271), 2025 with Staci / 2025 without / 2024:

• Total training hours 818,612 / 786,066 / 888,667 (male 511,706; female 305,272)
• Average hours per employee 24.41 / 25.89 / 27.24; male 23.41, female 26.65
• Performance review participation 14,200 employees, 42.35% of the workforce (11,284 and 37.17% excluding Staci; 12,774 in 2024); male 31.88%, female 60.99%

"the main challenge relates to the completeness of data capture, rather than any real decrease in learning hours compared with 2024" (page 271); "Strengthening this reporting capability will be a key focus in 2026" (page 267).

Mandatory training (page 267). "In 2025, the Code of Conduct training was the only mandatory training applicable across the entire group... and includes strict prohibitions regarding child labor, forced labor and human trafficking." Diversity training "is mandatory for all recruiters". Entity-level requirements cover compliance, cybersecurity, first aid, forklift, electrical and dangerous-goods training (pages 267-268).

Incentive link (page 269). "a group wide KPI was introduced in 2025 for middle and senior management: eligibility for the full short term incentive requires completion of at least one leadership development initiative during the year. This initiative applies across Bnode, except for Paxon Europe, which is currently out of scope due to tooling limitations."

Reference: page 259

Metrics (page 260), 2025 with Staci / 2025 without / 2024:

• Employees covered by health and safety management systems 99.46% / 99.67% / 98.13%
• Fatalities 0 / 0 / 1
• Recordable work-related accidents 1,392 / 1,223 / 1,261; accident rate 29.17 / 28.53 / 27.0 per million hours
• Lost time frequency rate 19.03 / 19.34 / 17.07
• Days lost 29,754 / 28,264 / 27,625; severity rate 0.62 per 1,000 hours

"The types of work-related accidents reported in 2025 were mainly musculoskeletal disorders caused by manual handling. In Belgium, for our mail carriers, a significant number of accidents are linked to walking on streets or driving on the road."

Two data caveats stated plainly (pages 260-261). "we collected the status of 2025 accidents on Monday, February 9, 2026. At this date, 91 cases were still under review by the insurance provider." And "Based on this update, the 2024 LTFR for Bnode amounts to 19.33 (instead of the 17.07 initially reported)."

Target and systems (page 259). "By 2030, we aim to reduce our Lost Time Frequency Rate (LTFR) by 30% at group level", 2025 baseline. "Radial North America achieved its entity level LTFR target of 1, while bpost NV/SA closed the year close to meeting its target of 24." bpost NV/SA runs "the Safety Performance Barometer, which tracks 14 indicators... two lagging indicators - severity rate and frequency rate - and twelve leading indicators". My Voice wellbeing scored 3.6 out of 5 in October 2025 (page 261).

Phase-in (page 264). "Information on non-employees & ill-health are subject to the CSRD phase-in", so work-related ill-health cases and related days lost are not reported.

Reference: page 265

"In 2025, we begin reporting on S1-15, acknowledging that work-life balance is a key driver of diversity, equity, and inclusion, one of our material topics" (page 265).

Metrics (page 266), 2025 with Staci: employees entitled to take family-related leave - male 99.98%, female 99.84%, other 100%, undisclosed 100%, total 99.93%; entitled employees that took it - male 5.26%, female 9.67%, other 0.00%, undisclosed 7.69%, total 6.78%.

No comparative, and why (page 266). "In 2025 Bnode has chosen to start reporting on work-life balance metrics in the subsequent year, as per the ESRS phased-in provision. Therefore, prior year information in accordance with ESRS S1-15 is not disclosed."

Arrangements (page 265). "At bpost NV/SA, employees working in support functions are entitled to two to three days of teleworking per week... A formal teleworking policy is under development and is expected to be implemented in 2026." Radial North America offers remote work to non-distribution-centre staff. Staci France's Quality of Life and Working Conditions agreement includes "the possibility for employees to donate leave days to colleagues whose child or spouse is seriously ill... and the formal right to disconnect". At Base Logistics "overtime is rare, compensated, and limited to peak activity periods only", with the CEO promoting "a clear 'no unnecessary overtime' philosophy", though "these practices are not formalized through quantitative indicators".

Family-related leave is defined to include maternity, paternity, parental and carers' leave. No quantitative target is set for S1-15 (page 224).

Reference: page 249

Gender pay gap (page 250), 2025 / 2025 without Staci / 2024: unadjusted gender pay gap 0.02% / -2.66% / -0.64%.

Disaggregation is narrative: "the gender pay gap in our European operations was 5.82% in favor of women, in its North America operations, it was 33.77% in favor of men... in Bpost (former BeNe Last Mile) was 10.93% in favor of women, 19.56% in favor of men in Paxon and 25.15% in favor of men in Landmark Global" (page 250). "The gender pay gap at Bnode is primarily driven by the workforce structure and the distribution of employees across functions and hierarchical levels, rather than by differences in remuneration for equal work."

Total remuneration ratio (page 251). "82.05 in 2025 (81.47 excluding Staci), compared with 84.30 in 2024", the highest annual total remuneration over the median of all other employees.

Policy gap stated plainly (page 249). "Our Code of Conduct and Diversity Policies... promote non-discrimination and equal opportunity, thereby supporting equality in remuneration. They do not include any specific reference to equal pay for equal work."

Pay transparency preparation (page 249). 2025 analyses across bpost NV/SA ahead of the EU Pay Transparency Directive (EU) 2023/970 identified "elements of the remuneration policy that require publication, as well as adaptations needed in recruitment, internal mobility and annual salary review processes".

Method caveats (page 250). The gap is unadjusted, "without controlling for factors such as job role, seniority, education, or working time"; pre-retirement employees and those working under 40 hours are excluded; "gender classification for the purpose of this calculation is limited to men and women". No target is set (page 224).

Reference: page 254

"Bnode applies a zero-tolerance approach to any form of human rights infringement, including discrimination, harassment, violence, or retaliation" (page 254).

Via the Speak Up tool (page 256), 2025 / 2024: Bnode excluding Radial North America and Landmark US - discrimination 13 / 7, harassment 24 / 31, sexual harassment 9 / 9; Radial North America 4 / 9, 9 / 9, 1 / 1; Landmark US nil throughout.

Via bpost NV/SA internal procedures (page 257), 2025 / 2024: discrimination 6 / 18, harassment 192 / 224, sexual harassment 26 / 33. The harassment category covers "moral harassment, aggression by third parties, assault/theft on mail carriers, physical assault by a third party, serious aggression, serious verbal aggression, verbal aggression by third parties, and workplace violence", with the caveat that the third-party aggression figures "reflect only the cases in which our team intervened directly".

Other complaints (pages 257-258). Tabulated by category, including bpost NV/SA psychosocial and mental health complaints rising to 297 from 268, and management, culture and relationships to 563 from 416.

Financial effect (page 256). "In 2025, one work-related harassment case was addressed and resolved through bpost NV/SA's internal resolution process before any litigation was initiated. No court order was issued. The total compensation related to incidents and complaints amounted to EUR 42,201.36 gross."

Severe impacts (page 258). "There were no serious issues or incidents related to Human Rights involving our personnel during the reporting period. Therefore, there were no cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration... or the OECD Guidelines."

Comparability caveat (page 256). From June 2025 bpost NV/SA harassment and discrimination cases moved out of Speak Up scope to the Prevention Team.

Reference: page 275

Four policies address value chain workers: the Human Rights Policy, the Speak Up policy, the Subcontractor Policy and the Supplier Code of Conduct (page 275).

Human Rights Policy (pages 275-276). Built on the UDHR, ILO core instruments, the UN Global Compact and the UN Guiding Principles, covering seven topics including "Forced labor, human trafficking and modern slavery: Bnode prohibits the use of all forms of forced labor whatsoever" and "Child labor: Bnode does not use or accept child labor in any of its operations or facilities". The Board of Directors is accountable and the policy is public. "remedial actions for human rights violations include... reference of the matter to the appropriate enforcement authorities and/or termination of the commercial relationship with the supplier." "In 2025, Bnode did not register any legal action or complaint related to human rights incidents... that involved value chain workers."

Subcontractor Policy (page 277). Requires verification of transport permits, insurance, employment contracts and work permits for non-EU drivers, plus criminal record extracts from subcontractors and directors "to ensure no serious violations (e.g. human trafficking, illegal employment, or tax fraud)"; it prohibits onward subcontracting "unless explicitly approved by bpost NV/SA" and mandates "Daily and ad hoc controls". Scope limit: "This policy applies only to bpost NV/SA. We are currently in the process of extending it to all entities (the approval of a group-wide policy is expected in 2026)."

Supplier Code of Conduct (page 278). "The latest version... entered into force on 25 March 2025, and applies equally to all Bnode entities. It now includes a supplier self-assessment mechanism", splitting principles into "Minimum Requirements" and "Aspirations". It applies "to all tiers of suppliers" and requires key suppliers to "undergo an annual assessment by an independent organization, such as Ecovadis or equivalent".

Reference: page 279

The company states a limitation up front: "While we have controls in place to protect the human rights of value chain workers and ensure their safety and wellbeing, our engagement with value chain workers is currently limited and we do not yet have a general process for engaging with them" (page 279).

Where engagement occurs (page 279). "Onboarding stage: during the onboarding of bpost NV/SA's suppliers, workers' representatives are given the opportunity to provide feedback and raise concerns. Transport subcontractors additionally undergo a compliance screening. Relationship stage: regular checks and ad hoc audits are performed on our transport subcontractors... During these checks and audits, individual workers can express their feedback and concerns during direct interaction."

Effectiveness, two routes (pages 279-280). An annual EcoVadis screening of key suppliers scored 0-100 across Environment, Social & Human Rights, Ethics and Responsible Purchasing, with bands "45 and over" (good), "Between 25 and 44" (partial) and "Less than 25" (insufficient). Escalation is specified: below 45 "general improvements"; 44 to 25 "a mitigation plan and monitor progress toward reaching the sector average within 24 months"; 0 to 24 "on-site audits... with a reassessment within 12 months. If the supplier's actions to improve prove inadequate, the ESG Steering Committee may decide to delist the supplier". For transport subcontractors, "a permanent control plan that includes regular on-site controls, ad hoc controls, and ad hoc on-site audits... monitored monthly".

Both routes are presented as proxies: "A lack of infringements can be seen as an indication that the engagement... is sufficient."

Responsibility (page 280). "We have no one senior role with the operational responsibility for ensuring engagement with value chain workers... The operational responsibility is spread over various roles within the organization."

Reference: page 280

"Persons working for a subcontractor or supplier of Bnode can report concerns and possible negative impacts as outlined in our Speak Up Policy. Except for Radial NA and Landmark Global NA, where specific reporting channels apply, workers in our value chain can report concerns through multiple channels, including our Speak Up tool, telephone hotline and by registered letter to their local entity reporting manager" (page 280).

Timelines (page 280). "The Bnode Compliance department will acknowledge receipt within 7 days via the Speak Up Tool. Monitoring is done by our Compliance department or local entity reporting manager, which informs on the outcome of the investigation of the report within 3 months from the acknowledgement of receipt. The Bnode Compliance department also monitors to assess whether any provided remedy is appropriate and effective."

Protection (page 280). "Our Speak Up Policy ensures confidentiality as well as protection from retaliation. This includes protection from disciplinary measures, changes in working conditions, dismissal, and other forms of retaliation."

Direct contact as a channel (page 277). "Our daily controls and ad hoc controls, which put us in direct contact with the workers of our subcontractors, offer the possibility for the workers to engage with our employees and our controllers."

Work in progress (page 280). "Recognizing that certain workers in our value chain may be particularly vulnerable to negative impacts or marginalized... we are actively working to enhance our understanding of their perspectives. These efforts aim to ensure that our grievance mechanisms are inclusive, effective, and responsive."

No figures are given for reports received from value chain workers, and no evidence is presented on their awareness of or trust in the channels.

Reference: page 281

"As shown in the table in section S2 SBM-3, Bnode did not identify any financial risks or opportunities related to workers in the value chain. We did, however, identify material impacts linked to equal treatment and working conditions" (page 281).

Three actions with expected outcome, scope and horizon (page 281): the updated Supplier Code of Conduct with binding requirements - "All new suppliers will adhere to the binding requirements", short term, "the updated policy came into force in 2025. Implementation ongoing"; EcoVadis monitoring - "Exclusion of poor performing suppliers", upstream, "Underway"; and a Third-Party Risk Management Framework - "Prevention of negative impacts on workers in the supply chain", upstream, medium term.

Supplier Code of Conduct (page 281). It "ensures that suppliers comply with comprehensive health and safety requirements while encouraging continuous improvements in areas such as gender equality, diversity, equal pay, and measures against workplace violence and harassment. Non-compliance... shall be deemed a breach of the contractual obligations of the supplier and may therefore lead to further steps or even lead to termination of the contract."

Third-Party Risk Management Framework (page 282). Based on a compliance maturity assessment "with a particular focus on Compliance, Health & Safety, and Social Responsibility", implemented "for bpost NV/SA, followed by a phased implementation across the rest of the group", introducing "supplier categorization, defining clear risk taxonomies and setting specific risk appetite parameters", initially "a qualitative and risk-informed approach to risk appetite". "So far, no cases requiring remedy have been identified."

Incidents (page 274). "Bnode did not experience any incidents involving value chain workers in 2024 and 2025." No monetary resources allocated to these actions are disclosed.

Reference: page 282

A negative answer, stated plainly with the reason. "Bnode is currently undertaking a comprehensive revision of its procurement strategy, and has, therefore, not yet established a formal process for setting targets specifically related to the material impacts affecting workers in our value chain" (page 282). The S2 IRO table records "N/A" under both METRICS and TARGETS for all five material sub-sub-topics (page 274).

What is tracked instead (page 282). "we already track the effectiveness of our policies and actions by using the following tools: Supplier Compliance Rates: Measured through contractual adherence; Sustainability Performance Scores: Assessed via third-party tools like EcoVadis; Incident Reports and Corrective Actions: Tracked through supplier reporting mechanisms."

Intentions (page 282). "As part of our effort to develop a target-setting process, we will consider how best to incorporate direct engagement with value chain workers, their legitimate representatives, and/or credible proxies in the next years... The base year for measuring progress will be established after the rollout of our Supplier Code of Conduct that was introduced in 2025."

Quantified supplier metrics sit under G1-2 rather than S2-5, scoped to bpost NV/SA: 75 key suppliers gave consent to the Supplier Code of Conduct in 2025 (56% of key suppliers) against 57 in 2024, and 68 were screened through EcoVadis (50%) against 65 (page 305).

No target, target year, baseline or milestone is disclosed for value chain workers, and the company does not present a proxy as one.

Reference: page 286

Two policies are disclosed: the Group Privacy Policy and the Data Classification Policy (page 286).

Group Privacy Policy (page 286). "the Group Privacy Policy was adopted in alignment with the General Data Protection Regulation (GDPR)... and approved by the Executive Committee on 10 December 2025." Scope caveat: "The Group Privacy Policy will apply from 2026 to all Bnode entities." Governance "is embedded within the Enterprise Risk Management framework and follows the 'three-lines-of-defence' model", with oversight by the Digital Compliance Office, Data Protection Office and Privacy Network, assurance from Corporate Audit, and "ultimate oversight by the Board of Directors and its Audit, Risk and Compliance Committee".

Data Classification Policy (page 287). Based on the Confidentiality, Integrity and Availability triad, managed by the CISO Office, with retention periods: contractual data up to 10 years; parcel delivery preferences 36 months, or 13 months if linked to a parcel; requests and complaints 12 months; camera footage 30 days; call recordings up to 6 months.

Consumer rights (page 288). Access, rectification and erasure, restriction, portability, objection, withdrawal of consent and complaint to the supervisory authority.

Non-discrimination and access (pages 287-288). Under the 7th Management Contract, Article 40 Social Responsibility Charter, "The mandate explicitly states that 'Bpost is there for all citizens', strictly prohibiting discrimination of any kind." The universal postal service obligation ensures nationwide availability at affordable prices, delivery of mail up to 2 kg and single parcels up to 10 kg at least five days a week, and a dense access-point network, overseen by the BIPT.

Human rights (page 288). "no cases of non-compliance with the UN Guiding Principles... involving consumers or end-users have been reported within our downstream value chain".

Reference: page 289

"Bnode engages with consumers and end-users through regular customer satisfaction surveys and feedback collection through social media, websites, and customer service interactions. The objective is to ensure that the perspectives of consumers and end-users are integrated into Bnode's decision-making processes and service offering" (page 289).

Customer satisfaction survey (page 289). "We continuously measure customer satisfaction at bpost NV/SA through telephone surveys, consolidating data monthly, quarterly and annually. With over 15 years of historical data, we can reliably compare and explain trends. The survey includes 2,400 residential customers and 2,400 business customers annually... Satisfaction is measured on a 7-point scale... Results are frequently reported to the Management Team and annually to the BIPT, which oversees performance and provides recommendations." The 2025 score for bpost NV/SA was 86.0%, up from 85.0% (page 4).

Reputation survey (page 290). "A third-party organization conducts ongoing quarterly surveys with a representative sample of 5,200 individuals across Belgian society", covering perceptions of environmental footprint, societal influence, care for employees, equal opportunities, economic contribution, ethics and supply chain transparency.

How engagement informs decisions (page 290). Engagement occurs "at various stages, such as product development, service delivery, and post-service evaluation"; "The communication and commercial departments are responsible for ensuring that engagement results are integrated"; effectiveness is assessed "through follow-up surveys, feedback analysis, and performance metrics like the Net Promoter Score (NPS)".

Stated gap (page 290). "it does not have specific mechanisms to gain insight into the perspectives of consumers and end-users who may be particularly vulnerable to impacts and/or marginalized."

Reference: page 290

"Bnode has established a robust data protection and privacy governance model to prevent, mitigate, and remediate material negative impacts related to Digital Compliance. This includes the Data Protection Office (DPO) and the Digital Compliance Office, which ensure compliance with GDPR... Subsidiaries appoint their own DPOs or Privacy Ambassadors" (page 290). All subsidiaries belong to a Privacy Network intended to harmonise governance, improve compliance and risk management, provide centralised support and "Disseminate documentation regarding AI and emerging technologies".

Access reviews (page 291). "An example of actions taken by the Chief Information Security Officer (CISO) Office includes the review of access to over 100+ business applications of Bnode. The default review frequency is yearly, except for sensitive applications."

Data breach process (page 291). "In the event of a data breach, Bnode has a dedicated process involving the Digital Compliance Office, the DPO Office, and the CISO. This process includes four key phases" - detection and preliminary assessment, initial assessment, detailed assessment and response, and reporting, review and improvement - each with "clearly defined roles and responsibilities". "Risky data breaches are analysed using an external tool to evaluate risks for data subjects."

Channels (pages 289, 291). A web form or post for data-subject requests, evaluated by the Compliance department against GDPR criteria; in Belgium also "the bpost NV/SA customer care online reporting form... or by directly contacting a company representative. Reports may also be submitted by phone or in person at a Post Office, Post Point, or Parcel Point."

Awareness, inferred rather than measured (page 291). "Given the significant volume of requests received every year, we believe our consumers and end-users are well aware of these channels and trust them" - no volume figure is given.

Reference: page 292

Incidents disclosed (page 292). "In 2025, Bnode faced two data security incidents. We promptly initiated an investigation and took steps to contain and remediate the issue. Where required by applicable law, notifications were made to relevant parties. Bnode has since implemented additional measures to further strengthen its security controls."

Actions on negative impacts (pages 292-293), each with outcome "Improve data security" and status "Underway": the Data Leakage Program with an external provider covering domain protection, "Dark Web Monitoring: Detecting and addressing targeted attacks discussed on Dark Web forums", account takeover prevention and data breach prevention; Cyber Incident Management, where "Regular ICT Incident Response exercises, known as Incident Specific Simulation Exercises, are conducted to test and validate cyber incident use cases, playbooks, and automated remediation scripts"; and an Information Security Questionnaire "To comply with the EU NIS-2 Directive, DORA, etc., particularly the requirements concerning Supply Chain Risk".

Actions on positive impacts (pages 293-294). Parcel locker expansion - "Doubled its Bbox network, going from 1,250 to 2,500 parcel lockers across Belgium... Launched the Bbox boutique", bringing pickup points above 4,000. A current account network with Nickel promoting "financial inclusion, especially for those who do not have access to digital means", tracked on "the number of accounts opened". And ensuring non-discrimination under the USO, overseen by the BIPT.

Stated gap (page 294). "Although bpost NV/SA does not currently have a formalized evaluation process in place, we have determined... that our practices do not cause or contribute to any material negative impacts on consumers or end users related to discrimination. Therefore, no corrective action or remediation is required." "there were no reported cases of severe human rights violations specifically related to our consumers and end-users".

Reference: page 294

A negative answer, stated plainly. "Bnode does not yet have measurable time-bound outcome-oriented targets related to consumers and end-users, nor a standardized process to systematically track the effectiveness of our policies and actions related to our impacts on them. We will consider setting them in the future, following the completion of further in-depth analyses. We remain committed to enhancing our reporting framework and providing meaningful insights as we progress" (page 294).

The S4 IRO table is consistent: for both material sub-sub-topics - privacy, and non-discrimination and equal access to products and services - the METRICS and TARGETS columns both read "N/A" (page 285).

What is measured in the absence of ESRS targets. Quality-of-service targets arise from the management contracts rather than the DMA: "Under its agreements with the Belgian government - namely the 2nd Management Contract relating to universal postal service obligations (USO) and the 7th Management Contract... we also have several quality-of-service targets, including targets related to the quality of delivery, opening hours, waiting time and customer satisfaction" (page 288). Customer satisfaction at bpost NV/SA reached 86.0% in 2025 against 85.0% in 2024 (page 4), reported "annually to the BIPT" (page 289), and engagement effectiveness is assessed via follow-up surveys, feedback analysis and the Net Promoter Score (page 290). For the Nickel partnership, effectiveness "can be tracked and assessed on the basis of the number of accounts opened" (page 294), though no figure is given.

No target, baseline, target year or milestone is disclosed, and the company does not present a proxy as one.

Reference: page 296

Policy framework (page 296). "in 2025, the Bnode's Legal, Compliance & Enterprise Risk Management departments created a Policy Governance Framework, also known as the 'Policy of Policies'", covering the policy lifecycle, validation process and "the introduction of the Group Compliance Policy Gatekeeper function".

Five policies (pages 297-299). The Code of Conduct (general provisions, employment relationships, commercial relationships including conflict of interest, corruption, gifts, money laundering and fair competition, personal data, communication and sustainability), accountable to the Board; the Speak Up Policy, "launched across Bnode in April 2023 and updated in 2025", via the Convercent webform, hotline or registered mail, applying to all subsidiaries "except Radial NA and Landmark Global NA where specific reporting channels apply"; the Bid Compliance Policy, which "strictly prohibits conflicts of interest, bribery, and other unethical practices"; the Public Affairs Policy; and the Policy on Contacts with Competitors.

Whistleblower mechanism (page 301). The Speak Up Program "is supported by robust policies that align with Directive (EU) 2019/1937"; the team "is deliberately kept small" and selected "based on their independence, absence of conflicts of interest, and expertise in fraud detection, ethics, and compliance matters".

FACE Program (page 300). The Compliance Maturity Assessment evaluates "compliance practices across all companies and jurisdictions where Bnode operates"; "most of ex-Staci Group entities have been assessed. The exercise is under finalisation, which is expected during Q1 2026". "the Board of Directors has identified eleven domains that require attention, with an initial focus on Third-Party Compliance (TPC), Business Continuity, Bribery and Corruption and Cybersecurity".

Training (page 302). "For two consecutive years (2024 and 2025), this comprehensive training initiative achieved a completion rate of 98% across all Bnode employees", with a 75% pass mark and video modules "For colleagues without a Bnode email address".

Gaps acknowledged (pages 301-302). A dedicated ABAC policy is only "in the final validation phase... scheduled to come into effect in early 2026", and "To date, no standalone risk assessment has been conducted to rank functions based on an elevated risk profile."

Reference: page 303

Risk management (page 303). "we leverage EcoVadis as our primary risk management tool... Through EcoVadis, we conduct high-level risk assessments across procurement categories to identify potential risks, such as environmental impacts, human rights violations, and ethical concerns."

Policies (page 304). The Subcontractor Policy "establishes strict onboarding, documentation, audit and daily/ad hoc control requirements to ensure transport subcontractors comply with legal, labor and ethical standards, preventing exploitation and illegal subcontracting"; the Supplier Code of Conduct "is embedded into contracts and procurement decisions, enabling monitoring, corrective actions and, where necessary, contract termination".

Standardised minimum RFP requirements (page 304): adherence to the Supplier Code of Conduct; "ongoing performance monitoring post-tender, completing an annual sustainability assessment via EcoVadis (or equivalent)"; and "Suppliers are expected to calculate and report on their annual carbon footprint, set a CO2 reduction target, and develop a strategy to achieve this target."

KPIs, scoped to bpost NV/SA (page 305), 2024 / 2025:

• Key suppliers giving consent to the Supplier Code of Conduct: 57 / 75, "56% of total key suppliers"
• Key suppliers screened through EcoVadis: 65 / 68, "50% of total key suppliers"
• Spend with key suppliers holding SBTi Scope 1 and 2 validated targets: EUR 204,972,197.96 / EUR 234,241,150, "39% of total key supplier spend"

"Key suppliers are defined as the top 80% spend suppliers of bpost NV/SA." A prior-year correction is disclosed: "in 2024 this figure was incorrectly reported as 3,045 due to a factual error."

Assurance caveat (page 305). "No external assurance is performed on these specific indicators other than the limited assurance provided for the overall sustainability statement by our external auditor." No SME-specific or vulnerable-supplier considerations are quantified.

Reference: page 309

"Over the past years, we have established a clear and comprehensive compliance framework designed to prevent, detect, and address corruption-related risks. This framework includes our Code of Conduct and Supplier Code of Conduct, the Speak Up Policy, as well as targeted training initiatives" (page 309).

New ABAC policy (page 309). "a dedicated Anti-Bribery and Anti-Corruption (ABAC) Policy, which was approved by the Executive Committee (ExCo) in December 2025 and is scheduled for implementation in 2026. This Policy will complement the existing provisions of the Code of Conduct and establish clearer rules regarding the behaviors to avoid."

Channels and investigator independence (pages 309-310). The Speak Up team is "composed of a diverse set of profiles, including a private detective, a fraud expert, AML & Transport experts, and an ethics manager". "On top of the Speak Up tool, bribery and corruption can also be reported through Integrity Management's CaseIQ tool (formerly named i-Sight)." "investigations related to corruption and bribery are conducted independently from the chain of management involved in the matter. The Compliance Director reports directly to the Executive Committee, Audit, Risk & Compliance Committee, and the Board of Directors on compliance risks, including ethics and fraud, on a quarterly basis... [and] has a direct reporting line to the Chair of the Audit, Risk & Compliance Committee."

Training (pages 310-311). Delivered within the Code of Conduct programme, covering "recognizing and avoiding conflicts of interest, prohibiting any form of corruption (including bribery, kickbacks, and fraud), and distinguishing between acceptable and unacceptable gifts and favours". "In 2025, 98% of Bnode employees, including those in administrative, management, and supervisory roles, completed the Code of Conduct training which includes the section on ABAC." Completion is tracked via Traliant, EdApp and Scandata, carries a 75% pass mark, is reviewed by Internal Audit and "is reported quarterly to the Compliance Director".

Functions at risk (page 310). Sales, Public Affairs and Public Procurement "are required to complete the full training... in the same way as all other employees", with dedicated ABAC training only from 2026. No separate ABAC completion rate is given.

Reference: page 295

No business conduct targets were set; effectiveness is tracked instead, which is the alternative limb of MDR-T. The G1 IRO table records "N/A" in the TARGETS column for all five material sub-sub-topics - corporate culture, prevention and detection of corruption, protection of whistleblowers, management of relationships with suppliers including payment practices, and political engagement and lobbying - and "N/A" under METRICS for three of them (pages 295-296).

How effectiveness is tracked instead:

• Code of Conduct training completion, the principal indicator: "For two consecutive years (2024 and 2025), this comprehensive training initiative achieved a completion rate of 98%" (page 302), tracked via Traliant, EdApp and Scandata, "reported quarterly to the Compliance Director" and reviewed by Internal Audit "as part of their audit engagements" (pages 310-311)
• Incident review: "Twice a year, all incidents are reviewed, categorized, and compiled into a report by the Compliance team. This report undergoes quality checks before submission to the Audit, Risk & Compliance Committee" (page 311), with zero fines and zero convictions in 2025
• Compliance Maturity Assessment under the FACE Program, with eleven Board-identified domains and finalisation "expected during Q1 2026" (page 300)
• Supplier KPIs: key suppliers consenting to the Supplier Code of Conduct 75 against 57, screened through EcoVadis 68 against 65, and spend with SBTi-validated key suppliers EUR 234.2 million against EUR 205.0 million (page 305)
• Litigation tracking: an annual Material Legal Risk report reviewed by the Compliance Director and Chief Legal Officer and "submitted annually to the Audit, Risk & Compliance Committee" (pages 310-311)

G1-3 is a standalone targets disclosure requirement only from the 2025/2026 ESRS; this statement was prepared with reference to the 2023 ESRS, under which business conduct targets fell within MDR-T.

Reference: page 311

A nil return with the verification trail. "In 2025, Bnode faced no convictions or fines for violations of anti-corruption or anti-bribery laws. Additionally, no breaches of our anti-corruption or anti-bribery procedures or standards were identified, highlighting the effectiveness of our compliance measures" (page 311).

Metrics (page 311), 2025 data across Bnode: amount of fines for violation of anti-corruption and anti-bribery laws 0; number of convictions 0. "As no breaches were detected, no actions needed to be taken to address breaches in procedures and standards."

Verification (pages 310-311). "This information is verified through the Legal Department's litigation tracking system and annual Material Legal Risk (MLR) report, which is reviewed by the Compliance Director and Chief Legal Officer (CLO). The report is submitted annually to the Audit, Risk & Compliance Committee", which also reviews "a centralized litigation report... [including] material legal risks from all Bnode entities globally". Reports are registered in Convercent and CaseIQ, and "For Radial NA, incidents are tracked in Syntrio". The Legal Department uses "a dedicated tool called Avonca to track ongoing and/or anticipated fines and litigations", and "material fines and penalties are cross-referenced with Upper Management contacts across subsidiaries... so that no ABAC-related convictions or fines are omitted".

Assurance caveat (page 311). "These figures have only been calculated and validated internally; they have not been validated by an external or third-party."

The G1 SBM-3 section adds that although the supplier relationship and political engagement impacts were classified as "actual", "no specific instances of malpractice related to these topics were identified in 2024 and 2025" (page 295).

Reference: page 312

Oversight (page 312). "Oversight of the Bnode's political influence and lobbying activities is the responsibility of our Government & Public Affairs Director under the direct supervision of our CEO." The Public Affairs Policy "came into force on January 1st, 2025", founded on "compliance with laws and regulations, integrity, transparency, and professionalism", and focused primarily on Belgian and EU public authorities.

Political contributions (page 312). "Bnode does not make any financial or in-kind political contributions, either directly or indirectly, in any country or geographical area." The metric table confirms a total monetary value of 0 for 2025.

Lobbying topics (page 312). "At the European level, Bnode's lobbying activities are primarily carried out through its contributions to PostEurop, a trade association representing national postal operators across Europe", covering "universal service, transport, e-commerce, human resources, environmental concerns, and customs regulations". Nationally, positions concern "taxation, sector specific regulation, management contract, general conditions related to labour law".

Registers (page 313). "Bnode is registered in the Belgian federal parliament lobby register... Additionally, Bnode is registered in the EU Transparency Register under Number 448148139186-23."

Revolving door (page 313). "Three members of management held a position in public administration during the two years preceding their current appointment: Delphine Van Bladel... served in the Cabinet of Karine Lalieux until October 31, 2024; Catherine Wijnants... until August 31, 2023; Finke Jacobs... until August 31, 2023."

The underlying material impact is the ownership structure: "The Belgian State's triple role as shareholder, client, and supervisory authority creates a potential conflict of interest" (page 296). No lobbying expenditure figure is given.

Reference: page 306

Scope limit stated up front (page 306). "Bnode does not operate under a centralized payment policy. Each entity within the group retains full autonomy in determining its own payment processes, procedures, and terms. Consequently, this analysis is limited to a representative sample of our entities, covering around 75% of our activities (by revenue). The business groups included are the following: bpost NV/SA, Freight4U, Active Ants, Radial EU, Radial NA."

Average payment time in calendar days (page 307), 2024 / 2025: bpost NV/SA 38.4 / 36; Freight4U 50.2 / 54; Active Ants not available / 26; Radial EU 20.9 / 21; Radial NA 34.69 / 35.41.

Standard terms (page 307). "In 2025, bpost NV/SA applied a standard payment term of 50 calendar days. No distinction is made between SMEs and larger suppliers." Freight4U, Active Ants and Radial EU apply 30 days; at Radial NA "the preferred term is 45 days from the invoice date (NT45), actual payment terms vary by vendor or contract and may range from immediate payment (NT00) to 60 days (NT60)".

Payments aligned with standard terms (page 308), 2024 / 2025: bpost NV/SA 90.05% / 87.6%; Freight4U 18.61% / 34.4%; Active Ants / 68.9%; Radial EU 82.22% / 87.9%; Radial NA 85.20% / 89.32%.

Legal proceedings (page 308). "Bnode has no outstanding legal proceedings related to late payments."

SMEs (page 307). "Bnode does not differentiate between SMEs and larger companies and, therefore, does not have a policy dedicated specifically to preventing late payments to SMEs", though it "fully complies with... the EU Late Payment Directive".

Assurance caveat (page 308). "all metrics reported in this section have not been subject to validation by an external body but have been assessed through consultations with our internal Finance and Legal teams".