Brunel International N.V.

Reference: pages 36, 60.

Governance of material topics

Brunel's operating model "empowers local entrepreneurship under global policies and guidelines," with business-critical decisions made by regional leaders, supported by central functions and the Global Leadership Team (GLT). Sustainability is treated as one of these business-critical areas.

The team responsible for Brunel's ESG strategy and policy implementation "reports directly to the CEO." The CFO and CEO combined are responsible for... the GHG emission reduction of Brunel. The Board of Directors and Supervisory Board are updated periodically on material environmental IROs, policy effectiveness, action plans and targets by the Corporate Finance and Control function (p.38).

Brunel's four-person independent Supervisory Board is involved in reviewing key decisions on material IROs; management of IROs is integral to the Board of Directors, GLT and Supervisory Board responsibilities, with no separate dedicated sustainability committee (p.38).

Reference: pages 38-39.

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

The Board of Directors and Supervisory Board are "updated periodically on material environmental IROs, policy effectiveness, action-plans and targets by the Brunel Corporate Finance and Control function." The Supervisory Board "is periodically informed of ESG developments so it can oversee the strategy, risk management process, and significant decisions based on the defined material impact, risks, and opportunities."

Where believed needed, "the Supervisory Board and/or Board of Directors request subject matter experts to brief them on external ESG developments, implications to the Brunel businesses, and Brunel's response." The Board of Directors is informed on ESG developments "during each audit committee meeting."

Reference: page 36.

Integration of sustainability-related performance in incentive schemes

Brunel states plainly: "Sustainability related performance is not integrated in incentive schemes."

The company has also "not defined specific CAPEX or OPEX budgets for programme execution": "As we do not own or control buildings or facilities, we do not have the option to change existing buildings ourselves. Other budgets relate mainly to minimal IT budgets and operating expenses to facilitate teams working on ESG programmes. Where investments or costs are believed to be necessary these will be financed out of existing CAPEX or OPEX budgets."

Reference: page 60.

Statement on due diligence

Brunel's due diligence approach is set out in its "global Code of Conduct and within our client acceptance process," which takes "financial, operational and association risks into consideration." The company states it "acknowledge[s] the importance of integrating an environmental and human rights due diligence process into our business operations," including "integrating and acting upon the assessment findings, monitoring progress, and communicating how these impacts are being managed."

The framework rests on the Human Rights and Modern Slavery, Code of Conduct and Environmental Procurement policies, which "provide the framework within each entity is expected to act." On the EU's Corporate Sustainability Due Diligence Directive (CSDDD), Brunel notes that during 2025 "the Omnibus regulation has been under discussion and clarity on CSDDD regulation and implications are currently not confirmed by the European Commission."

Reference: pages 37, 69.

Risk management and internal controls over sustainability reporting

The Corporate Finance and Control function is involved and responsible for controlling the ESG data collection and reporting processes. In 2025, "gap assessments were conducted against both existing and newly introduced ESG policies. Each region completed the gap assessments individually and results were combined into policy gap overviews. The gap assessment concluded that policies are in place."

On data quality: "Brunel engages with a third party ESG specialist to support in the annual data collection and validation process, ensuring accuracy and completeness," and ESG data is "verified internally before being provided to our external assurance provider for review."

Reference: pages 30, 48.

Strategy, business model and value chain

Brunel's business model is "centred around delivering specialised project and workforce solutions across various industries globally," built on a skilled workforce, technology infrastructure and strategic partnerships.

The value chain has three parts: 1. Upstream (Suppliers); 2. Own operations (Corporate, Recruitment & Contracting, Own workforce); 3. Downstream (Clients & Communities). Brunel states: "Own workforce placed at client sites are part of reporting under S1 own workforce and S2 workers in the value chain is not applicable." There were "no significant changes to the Brunel value chain in 2025."

Brunel distinguishes direct positions (employees and non-employees placed at clients, together "specialists") from indirect positions (own corporate staff).

Reference: pages 32-33.

Interests and views of stakeholders

As part of the 2025 DMA refinement, Brunel "expanded our stakeholder engagement to strengthen our process," engaging with "four external stakeholders, ranging from shareholders, a client and NGO, to capture diverse perspectives" on its most material impacts, risks and opportunities. Internal stakeholders across functions, regions and divisions were interviewed or sat on the DMA panel.

Brunel considers these interactions "sufficient to support continuous improvement of our assessment process and to ensure it reflects current stakeholder expectations," noting they "provided valuable new input while also reaffirming previous DMA outcomes."

Reference: pages 32-34.

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

The "2025 DMA refinement resulted in 20 material IROs across 8 sustainability matters" (p.32). "No additional material sustainability matters were identified compared to 2023," but the refinement "added material IROs related to Artificial Intelligence (AI) and integrating Health & Safety into KYC procedures," and placed "enhanced material focus on IROs related to... Workforce well-being and human rights."

The eight matters span three E1-linked topics (contribution to the energy transition through clients, exposure to traditional oil & gas clients, GHG emissions and energy consumption), three S1-linked topics (diversity/inclusion/belonging, workforce well-being and human rights, talent attraction/development/career) and two G1-linked topics (ethical business and compliance, data privacy and cybersecurity). "Currently, these IROs are not believed to have material impact on our financial position and performance" (p.34).

Reference: pages 30-33.

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

Brunel ran its "first double materiality assessment" in 2024 and a refinement in 2025, applying EFRAG guidance. The 2025 refinement covered: stakeholder engagement (internal interviews plus four external stakeholders), an update of the business review (market research, sector trends, peer benchmarking), topic prioritisation (DMA-panel scoring against impact- and financial-materiality parameters, against "a revised threshold"), and validation (CFO review, final validation by the DMA panel, approval by the CEO, communication to the Supervisory Board).

IRO consolidation: the register was "critically reviewed for clarity, precision, and relevance," re-written and re-assigned, then checked for duplication. Stated limitations include that IROs were scored gross, before mitigating factors, on a point-in-time basis, and that "secondary and tertiary impacts may not have been fully captured" (p.36-37).

Reference: page 61 (Appendix I: Reference Table).

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

Appendix I is Brunel's ESRS content index: "The below list includes the list of material disclosure requirements that Brunel reports on and the reference where this requirement is discussed in the sustainability statements." It lists BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P/A/M/T, E1-1 through E1-9 (E1-7 and E1-8 referenced "N/a"), S1-1 through S1-3, S1-5 through S1-9, S1-13, S1-14, S1-16, S1-17, and G1-1 through G1-4, each against a chapter reference.

No E2, E3, E4, E5, S2, S3 or S4 code appears anywhere in the index. A separate table, Appendix V (pp.89-94), marks specific E2-4, E3-1, E3-4, E4-2, E5-5, S2-1, S3-1, S3-4, S4-1 and S4-4 datapoints "Not material." A further list (p.64) names S1-11, S1-12 and S1-15 as datapoints that "might be phased in by our 2027 reporting cycle."

Reference: pages 81-83.

Transition plan for climate change mitigation

Brunel's 2023-baseline transition plan was "adopted and approved by management in 2024 and disclosed for the first time in our annual report for 2024," and "is approved by the Board of Directors and the Supervisory Board," with regular reviews for effectiveness and alignment.

Following a Scope 2 conversion-factor restatement, the 2030 target was revised "from 27% reduction in total GHG emissions to 25% compared to the 2023 baseline" (37,903 to 28,542 tCO2e market-based). Key levers quantified in the transition plan's bridge chart include lease-fleet electrification (~3,782 tCO2e reduction), renewable power sourcing (~1,011 tCO2e), green commuting (~591 tCO2e) and removing fossil fuels from buildings (~406 tCO2e), partly offset by a ~143 tCO2e rise from capital goods tied to green-electricity procurement.

Brunel is candid about the limits: "Brunel is not expected to achieve the objective of limiting global warming to 1.5°C in line with the Paris Agreement, nor the ambition of achieving climate neutrality by 2050 under the current approach," citing its "limited decarbonisation influence over our Scope 3 activities" (business travel and commuting). No separate CAPEX/OPEX budget has been set for the plan; costs are met from normal operating budgets.

Reference: page 80.

Identification of climate-related risks and scenario analysis

Back-filled from Appendix III: Environmental Disclosures (Climate Risk Analysis), where this content is disclosed in the FY2025 report (page 80). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Brunel "used selected IPCC scenarios, combining Representative Concentration Pathways (RCPs) to explore physical risks and Shared Socio-Economic Pathways (SSPs) to evaluate transition risks," naming SSP1-1.9 ("Most Optimistic," 1.5°C by 2050) as the Paris-aligned scenario and SSP5-8.5 ("Avoid at All Costs," 4.4°C by 2100) as the worst-case scenario.

Transition risks are tabulated by time horizon, value-chain segment and category (long-term reputation, policy and legal, technology and market risks tied to the conventional energy sector). Physical climate risks are assessed as not material: "Our offices are leased, and staff work flexibly, meaning that any local climate events would not disrupt business continuity." Brunel states the results "are subject to inherent uncertainty" and that it "will periodically review the scenarios we apply in our analyses and refine these as needed."

Reference: pages 80-81.

Resilience in relation to climate change

Back-filled from Appendix III: Environmental Disclosures ("Resilience of our business model"), where this content is disclosed in the FY2025 report (pages 80-81). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Brunel "concluded our first climate resilience analysis in 2024... In 2025, we updated and refined this analysis," following TCFD guidance over short/medium/long horizons defined as 0-5, 5-10 and 10-20 years - "a deviation from the default categories suggested in the ESRS delegated acts," made "to ensure consistency with our internal strategic planning cycles."

On resilience itself: "Our leased offices and limited fixed assets further reduce exposure, and we do not foresee any constraints in accessing capital due to climate change." Brunel expects rising demand for engineering solutions to climate-driven change to "reinforc[e] the relevance of our services," and says it has "diversified our service portfolio and strengthened our focus on low-carbon solutions." The company flags that it has "not extended the IPCC scenarios with other considerations" and has not factored in non-conventional-energy clients' dependence on the conventional-energy industry.

Reference: pages 81-82.

Policies related to climate change mitigation and adaptation

Brunel's climate policy sits in its Transition Plan, approved by the Board of Directors and Supervisory Board and built on a 2023 baseline calculated per GHG Protocol guidance. The plan sets targets to "transition 75% of office space to fossil-free operations by 2030" (55% achieved) and source "55% of electricity consumption... from renewable energy by 2030" (72% achieved), among others.

For emissions Brunel cannot control directly - it leases rather than owns its buildings - the policy is one of engagement rather than mandate: working with landlords on electric heating and LED retrofits, negotiating lease clauses that prioritise renewable-energy procurement, and engaging airlines on sustainable aviation fuel. The plan explicitly considers a just transition: "With relation to our own workforce, we do not foresee any material adverse impacts as a result of the ambitions of our current transition plan."

Reference: pages 36, 40, 82-83.

Actions and resources in relation to climate change policies

Climate action sits under Brunel's "Environmental (CO2) Reduction" ESG programme, one of five: "focus on reducing Brunel's carbon emissions through amongst others development of the electric car fleet, green electricity contracts and LED lighting."

Concrete 2025 action: Brunel "started the process of moving to fossil-free operations by moving German entities in the DACH region towards more environmentally friendly office facilities." Planned levers include converting the lease/rental fleet to 95% zero-emission vehicles by 2030, "scaling to 100% by 2040," converting 90% of lighting to LEDs by 2030 (55% done), and raising zero-emission flight kilometres to 2.5% of business air travel by 2030 (baseline 0) and zero-emission commuting to 50% by 2030. CAPEX/OPEX for these actions comes from normal operating budgets; Brunel states it has "not performed a separate budget exercise" for the transition plan.

Reference: pages 36, 41-42, 82.

Targets related to climate change mitigation and adaptation

Headline targets: 100% zero-emission vehicles by 2040 (95% of the lease/rental fleet by 2030) and 75% of office space fossil-free by 2030. The overarching GHG target, restated in 2025 after a Scope 2 conversion-factor correction, is a 25% reduction in total market-based GHG emissions by 2030 versus the 2023 baseline (37,903 to 28,542 tCO2e); by scope, Scope 1 targets a 31% reduction to 335 tCO2e, Scope 2 market-based a 7% reduction to 1,298 tCO2e, and Scope 3 a 2% reduction to 26,938 tCO2e.

Supporting targets: 55% renewable electricity by 2030 (72% achieved in 2025), 90% LED lighting by 2030 (55% achieved), 50% zero-emission commuting by 2030, and 2.5% zero-emission business-travel flight-km by 2030 (baseline 0). Brunel states plainly that under the current approach it is "not expected to achieve the objective of limiting global warming to 1.5°C... nor the ambition of achieving climate neutrality by 2050."

Reference: pages 40-41.

Energy consumption and mix

Total energy consumption fell from 19,880 MWh (2024) to 16,916 MWh (2025), down 15%. Fossil energy consumption fell 23% to 14,233 MWh, while total renewable energy consumption rose 79% to 2,683 MWh. The renewable share of total energy consumption rose from 8% to 16%, and the fossil share fell from 92% to 84%; 0% of consumption comes from nuclear sources.

By source, fuel from petroleum products fell 18% to 7,729 MWh and natural gas fell 32% to 2,141 MWh; purchased electricity/heat/steam/cooling from fossil sources fell 25% to 4,363 MWh. Self-generated/purchased renewable electricity rose from 1,500 to 2,683 MWh (+79%). Brunel describes its environmental metrics as relating "primarily... to its office operations, employee mobility, and energy consumption," with a "relatively limited" direct footprint as a service-based organisation.

Reference: pages 41-42.

Gross Scopes 1, 2, 3 and Total GHG emissions

Gross Scope 1: 4,523 (2023) to 3,079 (2024) to 2,473 tCO2e (2025), none from regulated emission trading schemes. Scope 2: gross location-based 2,394 tCO2e (2025); gross market-based 1,651 tCO2e (2025). Scope 3 (significant categories disclosed): capital goods 128 tCO2e, business travel 14,893 tCO2e, employee commuting 6,962 tCO2e, totalling 21,983 tCO2e gross indirect emissions in 2025.

Total GHG emissions (market-based): 26,107 tCO2e in 2025, down from 35,744 in 2024; intensity 21.43 tCO2e per net-revenue monetary unit. Brunel restated its 2023 and 2024 Scope 2 figures "following an incorrect application of conversion factors" (impact: -1,937 / -1,978 / -1,300 tCO2e market-based for 2023/2024/2025 respectively). Scope 3 is "80% of our total GHG emissions," driven mainly by business travel (notably specialist air travel) and commuting; a 2025 update to DEFRA flight-emission conversion factors cut reported air-travel emissions 35% on stable travel distance.

Reference: pages 80-81, 83.

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

Brunel finds physical climate risk not financially significant: "Our offices are leased, and staff work flexibly, meaning that any local climate events would not disrupt business continuity... the financial impact on Brunel is diversified across sectors, geographies, and clients." It also states it does "not foresee any constraints in accessing capital due to climate change."

On transition risk, the updated assessment finds "a risk of reputational damage and litigation exposure on the services side if Brunel would be associated negatively with the conventional energy sector," as that sector faces growing scrutiny "by capital providers, advocacy groups and by younger generations." Brunel expects this pressure to extend "to the conventional energy's supply chain" in the mid-to-long term. No single quantified financial-effect figure is given; the assessment remains qualitative.

Reference: pages 48-50.

Policies related to own workforce

Brunel's workforce policies rest on its Code of Conduct, DIB Policy, and Health and Safety Policy, aligned with "the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises."

Policies "explicitly prohibit forced labour, child labour, and modern slavery across all regions and all operations," and the Code of Conduct and DIB policies "explicitly prohibit discrimination on the grounds of racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, and social origin." Brunel states it does "not see forced labour and compulsory labour as a material risk for the business" given its focus on technical graduates and experienced professionals. A global Health & Safety council was established in 2025 to align standards across regions.

Reference: pages 50-51.

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

In the Netherlands, Brunel has a Works Council, a formal body of elected employee representatives consulting on company policy and personnel matters under the Works Council Act (WOR). In Germany, Brunel "respects and participates in collective bargaining agreements with trade unions"; in Australia, enterprise agreements under the Fair Work Act cover wages, conditions and dispute resolution.

There are "no agreements with employees for representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council." Broader engagement runs through the SpeakUp line and bi-annual performance reviews, plus employee surveys and regional DIB councils that identify local priorities.

Reference: pages 50-51.

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

Brunel operates the SpeakUp Line, a confidential channel "accessed anonymously, 24 hours a day, 365 days a year, in multiple languages," for harassment, discrimination or other workplace concerns, managed by "Brunel's legal counsel and the Board of Directors." The Whistleblower Policy provides guidance and "includes a strong non-retaliation commitment."

Brunel "commits to providing access to appropriate remediation support in the event of adverse human rights impacts that we have caused or contributed to," with remedies potentially including "restitution, compensation, rehabilitation, and guarantees of non-repetition," determined in consultation with affected stakeholders. Issue volume, response times and resolution outcomes are tracked, with oversight from the Board of Directors and Regional Leadership.

Reference: pages 52-53.

Targets related to own workforce

Brunel states plainly: "Brunel does not set output-oriented Group social targets. This is because Brunel does not drive social performance centrally." Instead, "each regional business is required to establish regional targets and action plans that align with both global policies and local priorities," with the Board of Directors ensuring regional plans fit the overall ESG strategy and the Global Leadership Team reviewing effectiveness.

Regions "are mandated to report their progress on a periodic basis." No Group-level numeric social target (e.g., turnover, engagement, diversity ratio) is disclosed at consolidated level beyond the metrics reported under S1-6 to S1-17.

Reference: pages 53-56.

Characteristics of the undertaking's employees

Total headcount fell from 10,074 (2024) to 9,443 (2025): 7,113 male, 2,315 female, 15 other (2025; both "other" and "not reported" were 0 in 2024). By contract type (2025 consolidated): 6,097 permanent, 2,154 temporary, 1,823 non-guaranteed-hours employees.

The largest country populations in 2025 include the Netherlands (1,475), Qatar (1,373), and the United States (475), among roughly 40 countries. Total leavers: 6,368 (69% of headcount) in 2025, versus 6,758 (67%) in 2024. Headcount reported for ESG purposes can differ from the financial report's FTE figures "due to definition differences."

Reference: page 57.

Characteristics of non-employee workers

Non-employees in Brunel's own workforce totalled 1,573 in 2025, down from 1,854 in 2024. By gender (2025): 231 female, 1,342 male, 0 other.

These are individuals in Brunel's own workforce who are not employees, reported alongside the employee headcount disclosed under S1-6.

Reference: pages 57-58.

Collective bargaining coverage and social dialogue

18% of Brunel's total employees were covered by collective bargaining agreements in 2025 (1,741 employees), down from 21% (2,101) in 2024.

By coverage band, most EEA countries with bargaining estimates (Albania, Czech Republic, Denmark, France, Greece, Netherlands, Norway, Poland, Romania, Spain, Switzerland, Italy, Sweden) sit in the 0-19% coverage band, with Austria, Belgium and Germany shown with workplace representation in higher bands. Non-EEA countries with over 50 employees (Australia, Brazil, Canada, China, India, and others) are also shown in the 0-19% band for collective-bargaining estimates.

Reference: page 59.

Diversity metrics

Female representation in senior management fell from 41% in 2024 to 38% in 2025, defined as the Executive Leadership Team (ELT), the Regional Leadership Team (RLT) and their direct reports. The Board of Directors has two positions, "both are held by male team members."

Age diversity (2025 headcount): 1,755 under 30, 5,706 aged 30-50, 1,982 over 50, of a total 9,443 (2024 comparatives: 1,959 / 5,958 / 2,157 of 10,074).

Reference: page 59.

Training and skills development metrics

Participation in performance and career development reviews fell from 2,130 employees (21%) in 2024 to 1,691 (18%) in 2025, of which 932 male employees (13% participation rate) and 759 female employees (33% participation rate). Brunel's policy is to "organise performance and career development reviews for indirect workforce and/or for direct workforce who have a long-term rather than a short-term employment relationship."

Brunel's separate phase-in list (p.64) flags "S1-13: Training hours" specifically as a datapoint that "might be phased in by our 2027 reporting cycle" - i.e., total training-hours figures are deferred even though review-participation metrics are reported this year.

Reference: pages 58-59.

Health and safety metrics

Brunel reports one work-related fatality in 2025 (a specialist in Kuwait; nil in 2024), against 37 total recordable injuries (21 in 2024) and a total recordable injury frequency (TRIR) of 1.48 (0.93 in 2024). Lost calendar days rose to 847 (409 in 2024).

HSE coverage was 98.5% for employees and 71% for non-employees in 2025 (99.9% / 83% in 2024), "slightly below 100% because at some locations a business other than Brunel is responsible for the HSE coverage," for example at Taylor Hopkinson's UK site and the newly acquired Brunel Equals location. Brunel's separate phase-in list (p.64) flags specific ill-health-case and lost-days sub-datapoints for later phase-in even though headline injury/fatality metrics are reported this year.

Reference: pages 59-60.

Compensation metrics (pay gap and total compensation)

The gender pay gap narrowed slightly, from 17.1% (2024) to 16.6% (2025). Brunel attributes this to workforce composition: "81% of our direct positions are male," and direct positions "are more likely to receive a higher compensation, irrespective of gender, than indirect positions," so "resolving this is not a matter of pay policy, but a matter of making careers in Science, Technology, Engineering and Math (STEM) more appealing to females."

The CEO pay ratio rose from 7.5 (2024) to 15.73 (2025), which Brunel explains by two factors: the 2024 median-employee figure was based on a partial-data estimate (2025's is calculated from all employee remuneration data, lowering the comparator), and 2025 CEO remuneration reflects a full year in the CEO role (the incumbent held the CFO role for 9 of 12 months in 2024).

Reference: page 60.

Incidents, complaints and severe human rights impacts

In 2025, Brunel recorded 0 work-related incidents of discrimination, 9 work-related complaints filed (down from 26 in 2024), and 0 fines as a result of work-related incidents. 0 of these complaints were reported to National Contact Points for OECD Multinational Enterprises.

No severe human-rights incident is disclosed for 2025 beyond the fatal workplace accident reported under S1-14. The complaints figures are tracked through the SpeakUp Line and HR grievance channels described under S1-3.

Reference: pages 84-85.

Business conduct policies and corporate culture

"At Brunel, our corporate culture emphasises ethics, proper behaviour, and a passion for people," with a zero-tolerance policy for improper conduct. The Code of Conduct "clearly defines the company's values and expectations, both collectively and individually." As a company listed on the Amsterdam Stock Exchange, Brunel follows "Dutch law and the Dutch Corporate Governance Code for good corporate governance."

Risk management is built into governance through the code of conduct, a whistleblower procedure, compliance training for new employees, refresher courses and on-the-job training. The Supervisory Board, Board of Directors, and senior leadership "regularly review feedback and metrics to ensure our culture aligns with business goals."

Reference: page 85.

Management of relationships with suppliers

"Brunel's activities related to its supply chain and its value chain related impacts on sustainability matters were not deemed material in the 2025 DMA update," as the vast majority of procured goods and services relate to direct/indirect staff (travel, office paper, IT, audit and consultancy services).

Even so, Brunel "encourages our businesses to incorporate social and environmental criteria into their supplier selection" through a Sustainable Procurement Policy, while stating "we do not execute further supplier engagements." On payment: "Brunel agrees and follows reasonable payment terms with all its suppliers. Payment terms of typically 30-60 days are agreed and adhered to," though this is "not formalised in a policy as we do not want to create policies for practices that are considered integrated into normal daily operations."

Reference: pages 60-61.

Prevention and detection of corruption and bribery

Anti-corruption and bribery training is mandatory for all new indirect employees at induction and periodically thereafter; the directly-placed workforce is out of scope, as Brunel does not believe it has "a role in the administrative processes for placement" that would create bribery exposure.

Brunel gives two training-coverage figures. A table reports 368 indirect employees trained in 2025 against 735 in 2024, out of a total indirect headcount of 1,394 (2025) / 1,476 (2024) - training coverage of 26% and 50% respectively (p.60). Separately, the surrounding narrative states 1,004 indirect employees completed the mandatory training in 2025; after removing those already trained in 2024 (to avoid double-counting) and leavers, and combining with 2024 completions, this "yields a training coverage of 79%," below 100% because "employees who have joined Brunel late in 2025 will complete their trainings in the beginning of 2026" (pp.60-61). The two figures appear to measure coverage on a different basis and are presented here as the report states them.

Reference: page 60.

Targets related to business conduct

Brunel is "committed to remaining free of anti-corruption and/or anti-bribery convictions. Due to the nature of the governance metrics there is limited opportunity to set further targets" (p.60).

This sits alongside the G1-3 training-coverage metrics (368 of 1,394 indirect employees trained in 2025, reported as 26% coverage on one basis and 79% on the cumulative basis described in the surrounding text) and the G1-4 result that Brunel recorded zero anti-corruption and anti-bribery convictions and zero fines in both 2024 and 2025 - the outcome the company frames itself as tracking against, rather than a forward numeric target.

Reference: pages 61, 84-85.

Incidents of corruption or bribery

Brunel's G1-4 KPI table reports zero anti-corruption and anti-bribery convictions and zero fines for violation of anti-corruption and anti-bribery laws, in both 2024 and 2025 (consolidated total).

The Whistleblower Policy provides the reporting process: "Reports go directly to legal or a compliance officer, who handle the matter with... non-retaliation policy." The Board of Directors and Whistleblower Officer "oversee investigations into reported or suspected incidents," carried out "independently and objectively," with outside legal counsel and investigators used "where considered appropriate and needed." The SpeakUp Line supports anonymous reporting by phone, website or app, directed initially to the Whistleblower Officer or line manager.