Cairo Communication S.p.A.

Reference: pages 53-56.

The Board has 10 directors (4 executive, 6 non-executive; 3 of the non-executive members independent), 40% women. The Board "has assessed that all its members possess professional expertise in the Group's industries, products, and geographic areas," and in March 2025 ran an "induction session ... open to all independent directors and statutory auditors to explain the changes introduced by the Corporate Sustainability Reporting Directive (CSRD)."

Sustainability oversight sits with the Board-level Control, Risk and Sustainability Committee, which "reviews and approves in advance the process aimed at identifying and evaluating the material risks, impacts, and opportunities" and receives updates from the Risk, Compliance, Internal Audit & Sustainability function at least twice a year. Internal Sustainability Committees also operate in Italy and Spain (Comité de Sostenibilidad).

Reference: page 56.

"At least once a year, the Control, Risk and Sustainability Committee informs and updates the Board of Directors on the material impacts, risks, and opportunities, as well as on the progress of the actions included in the Sustainability Plan." The administrative, management and supervisory bodies "take these impacts, risks, and opportunities into account in performing their activities and making decisions."

Monitoring, management and control of IROs runs through the Board via the Control, Risk and Sustainability Committee, supported by the Internal Audit, Risk, Compliance & Sustainability function. The full list of material IROs addressed by the Board is set out in the Annexes.

Reference: page 56.

Remuneration policy is approved by the Board on the proposal of the Remuneration and Appointments Committee and applies to Board members and Key Management Personnel. Variable pay is tied to "operating, financial, and/or strategic objectives, including sustainability ones," aligned to the Sustainability Plan.

"The portion of variable remuneration that depends on sustainability-related targets as envisaged in the 2025-2026 Sustainability Plan, for 2025, ranges between 5% and 10% (5% in 2024)." The Group states it "has not currently adopted" a medium/long-term incentive (LTI) plan.

Reference: pages 57-58.

The Group maps its due diligence practices in tabular form against ESRS 1 AR 15's five elements, cross-referencing them to specific chapters: (a) embedding into governance/strategy -> GOV-1, GOV-2, SBM-1, SBM-2, IRO-1; (b) involvement of affected parties -> the S1/S2/S3/S4 stakeholder-engagement sections; (c) identification and assessment of negative impacts -> SBM-3, IRO-1; (d) taking measures -> the Actions/Resources sections of E1, E3, E4, E5, S1, S2, S4; (e) monitoring effectiveness -> the Targets sections of the same chapters.

Underlying policies are the Model 231 organizational, management and control model, the Sustainability Policy and the Code of Ethics; the "Process of Implementation of the Consolidated Sustainability Reporting" procedure is described under GOV-5.

Reference: pages 58-60.

The Group runs an Internal Control System for the Consolidated Sustainability Reporting ("SCIRS"), paired with the Internal Control System on Financial Reporting as "integrated and synergistic" parts of the broader Internal Control and Risk Management System (SCIGR). SCIRS proceeds through Scoping (based on the Double Materiality results), Documentation, Execution, Testing, and certification collection, overseen by the Financial Reporting Manager.

"Following the results of the scoping activities conducted in 2025, subsequent documentation and testing activities focused on the disclosure under ESRS S1 on Own Workforce (in 2024, the activity focused on ESRS E1, concerning Climate Change)." External consultants supported the SCIIF verification work; a data system in use since 2022 tracks access, entries and changes.

Reference: pages 60-64.

Cairo Communication Group operates as a magazine and book publisher (Cairo Editore), TV publisher and network operator (La7, Cairo Network), multimedia advertising agency (Cairo Communication, CairoRCS Media), and, through RCS MediaGroup, publisher of dailies and magazines in Italy and Spain plus organizer of major sporting events (e.g. Giro d'Italia). At 31 December 2025 the Group had 3,819 employees (2,705 Italy, 1,083 Spain, 31 other countries).

The business model is described across four value chains: circulation (paper mills, printers, national distributors m-dis and Boyacà), television (in-house and outsourced production, Cairo Network as terrestrial network operator), advertising (CAIRORCS Media, Unidad Editorial's internal structure), and organization of sporting events. The Board approved a three-year 2024-2026 Sustainability Plan; its actions were re-evaluated between January-February 2026 and reconfirmed.

Reference: pages 64-66.

Stakeholder categories are mapped with engagement methods: Human Resources (employees, journalists, trade unions - Code of Ethics dissemination, training, Focus Groups, Surveys, negotiations with Editorial Committees/Trade Union Representatives); Shareholders/Market/Lenders (financial reports, Shareholders' Meeting, roadshows); Institutions; Business Partners (supplier portal, workshops); Public/Retail/Business Customers; Environment/Community and territory.

For 2025 the Group "conducted a stakeholder mapping exercise" feeding the Double Materiality update, including surveys of employees, readers, consumers, key raw-material suppliers and a number of financial institutions "to assess ESG impacts based on their perception of the Group." The Board receives at least two reports a year from the Control, Risk and Sustainability Committee on stakeholder engagement.

Reference: page 66.

The full material-IRO table (description, value-chain location, time horizon) sits in the Annexes. "While a specific analysis of the resilience of the Group's strategy and business model with regard to impacts, risks, and opportunities has not yet been carried out," though risk-management-context analyses exist; for climate, see IRO-1 under E1.

Regarding future financial effects of material risks and opportunities, "the Group takes advantage of the transitional provisions set forth in the regulations"; on current effects, "there were no material financial effects on the Group's financial position arising from material risks and opportunities." "In line with 2024, no material Impacts, Risks and Opportunities were identified resulting in the need to identify entity specific indicators."

Reference: pages 67-68.

The 2025 Double Materiality process followed "EFRAG IG 1 - Materiality Assessment" (May 2024) in four steps: (1) understanding the context; (2) identifying IROs from ESRS 1 Appendix A plus peer benchmarking; (3) assessing impact materiality (Management plus stakeholder engagement) and financial materiality (meetings with Risk Owners); (4) processing results. Roughly thirty to forty managers in Italy and Spain were interviewed, jointly with RCS's Internal Audit Department for the RCS Group.

"Based on the analysis of activities carried out at the Group's production sites, ... the Group's own activities are not expected to generate significant effects in terms of pollutant volumes, water consumption, or biodiversity deterioration," and "the related IROs on these topics were deemed immaterial to the Group's operations. However, biodiversity- and water-related impacts were material only in the value chain." Versus 2024, several IROs were reformulated/aggregated or excluded (detailed in the Annexes), and ESRS E3 - Water and marine resources newly became material via the upstream paper supply chain.

Reference: pages 74, 153-157.

The ESRS content index cross-references each applicable Disclosure Requirement to its reporting section, covering ESRS 2 (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1/IRO-2), E1 (through E1-7), E3 (IRO-1, E3-1 to E3-3), E4 (E4-1 to E4-4), E5 (E5-1 to E5-5), S1 (S1-1 to S1-6, S1-8 to S1-10, S1-14, S1-16, S1-17), S2, S3, S4 (all five DRs each) and G1 (G1-1 to G1-4, G1-6). ESRS E2 - Pollution is absent from the index, consistent with IRO-1's finding of no material own-operations or value-chain pollution impact.

A separate table (BP-2) lists the specific Disclosure Requirements and datapoints for which the Group applies the ESRS 1 Appendix C phase-in provisions for 2025, including E1-9, E3-5, E4-6, E5-6 and several S1 datapoints (S1-7, S1-11, S1-12, S1-13, parts of S1-14, S1-15).

Reference: page 80.

"The Group does not currently have a transition plan for climate change mitigation." It annually quantifies and monitors Scope 1, Scope 2 and Scope 3 emissions, "has gradually integrated information related to the value chain" for Scope 3, and states: "Next year, prep activities for a possible preparation of a Transition Plan will be assessed."

Material climate IROs are: two current negative impacts (value-chain emissions from third-party activities; direct/indirect GHG emissions at Group sites), one current negative impact on energy (non-renewable/renewable consumption), a transition risk (regulatory, technological, market, reputational) and a physical risk (acute/chronic hazards, notably for sporting-event locations). In 2025 the Group "reviewed the scenario analysis prepared in the prior year" and "confirms the validity of the scenario analysis developed in 2024."

Back-filled from ESRS 2 IRO-1 (pages 81-83), where this content is disclosed in the FY2025 report under "ESRS E1 - Climate Change". This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The 2024 scenario analysis (confirmed valid for 2025, no material changes found) applied the TCFD framework. Physical risks used IPCC scenarios: optimistic "RCP 4.5" and pessimistic "RCP 8.5" ("Business-as-usual"/"No mitigation"). Transition risks used IEA scenarios: optimistic "Current Policies" (warming ~3C) and pessimistic "Net Zero 2050" (1.5C-aligned, strict policies/innovation). Steps: mapping sites, identifying TCFD risk categories, scoring exposure (high/medium/low) by climate scenario over the long term, interviewing corporate contacts on mitigation, and geographic risk mapping.

Material risks identified: physical - heat stress, water stress, heat waves, subsidence; transition - replacement of products/services with low-emission options and market uncertainty. No global-average-temperature projection per scenario or assumptions/dependencies breakdown is given, and scope is limited to the Group's locations and sites (no explicit value-chain scope statement).

Back-filled from ESRS 2 SBM-3 (page 66) and ESRS E1 IRO-1 (pages 80-81), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group states plainly that a dedicated resilience analysis has not been performed: "While a specific analysis of the resilience of the Group's strategy and business model with regard to impacts, risks, and opportunities has not yet been carried out, it should be noted that analyses have been conducted within the broader context of risk management," with the climate-specific strand addressed under E1 IRO-1.

For climate specifically, the 2025 review of the 2024 scenario analysis "did not identify any significant changes in the operational, regulatory, or strategic environment, nor any material changes in the risks and opportunities identified," and also "covered the identification and assessment of the mitigation actions implemented by the Group ... including: preventive measures to limit the impact of physical risks, energy efficiency measures, and monitoring systems." No quantified capacity-to-adjust analysis (financial flexibility, asset redeployment) is provided.

Reference: page 83.

The Group describes an "ongoing improvement" process on environmental matters (technology, energy/resource management) spanning work organization, procurement, workspace management and technology. It states plainly that its general policies do not speak directly to climate: "The Code of Ethics and the Sustainability Policy, while addressing environmental topics, do not specifically contain aspects of mitigation, adaptation, energy efficiency, and the spread of renewable energies." Procedures cover production processes as well as office/personal-services management. See MDR-P Policies for scope and responsibilities.

Reference: pages 83-84.

Three workstreams for 2025-2026: Energy efficiency - consumption monitoring at Milan Via Rizzoli (from December 2024), Transition 5.0 upgrades at La7 TV studios (photovoltaic system, new air conditioning, UPS replacement, Building Management system). Reducing emissions - work begun on an SBTi-aligned target pathway, and an LCA project started for Corriere della Sera. Renewable energy - partial GO-backed renewable purchase for the Italian companies' sites, and "100% energy from renewable sources with Guarantee of Origin (GO) for Unidad Editorial's headquarters in Spain."

"The impact of the measures ... can be assessed in future years." "The implementation of the above actions did not involve significant operating or capital expenditure."

Reference: page 84.

"To date, no quantitative targets have been set in the environmental and climate field." The Group notes it "may consider including such targets (possibly also Science-Based) in the next Plan." Effectiveness is instead overseen through the materiality-analysis process and "a system for monitoring the progress of the planned activities of the 2024-2026 Sustainability Plan," using qualitative and quantitative indicators on energy consumption, CO2 emissions and sustainable supply-chain management.

Reference: pages 85-87.

2025 total energy consumption: 52,212.3 MWh (2024: 52,611.4 MWh restated, -0.8%). Fossil sources: 31,033.7 MWh, 59.4% of the total (down from 80.5% in 2024). Renewable sources: 21,178.5 MWh, 40.6% of the total (up from 19.5%), driven mainly by a higher share of electricity purchased with Guarantees of Origin. No nuclear-source consumption. "GO cancellation certificates for consumption... were not yet available at the date of preparation," so the renewable share is estimated from contractual agreements. 2024 fossil/total figures were restated for a refined estimation methodology (natural gas, electricity at minor offices) and updated fuel-conversion factors for the company fleet.

High-climate-impact-sector entities are separately identified: RCS Produzioni Milano, RCS Produzioni Padova, RCS Produzioni S.p.A. (sector C - Manufacturing) and My Beauty Box S.r.l. (sector G - Retail).

Reference: pages 88-90.

2025 (tCO2e, 2024 restated in brackets): Scope 1 1,906.2 (1,943.9, -1.9%); Scope 2 location-based 10,981.8 (15,306.7, -28.3%), market-based 7,708.3 (13,386.7, -42.4%); Scope 3 169,639.7 (178,041.4, -4.7%; Purchased goods and services 127,897.1 is the largest category); Total location-based 182,527.6 (195,292.0, -6.5%); Total market-based 179,254.2 (193,371.9, -7.3%). GHG intensity per net revenue: 182.6 location-based, 179.3 market-based (net revenue Euro 999.5 million).

Scope 1 factors come from UK Government GHG Conversion Factors 2025; Scope 2 uses AIB European Residual Mixes (Residual mix for market-based, Supplier mix for location-based). 2024 figures for Scope 1, 2 and several Scope 3 categories were restated following a methodology update tied to the E1-5 change.

Reference: pages 91-92.

The Group does not report GHG removals, but RCS "purchases certified carbon avoidance credits to specifically offset GHG emissions from some of the major events it organizes." Four events achieved "Carbon Neutral" certification in 2025: Milano Marathon (~233 t CO2, credits funding micro-credit stove/solar-lamp projects in India), Festival Pianeta 2030 (~169.7 t CO2, biodiversity-protection credits in Sierra Leone), Cook Fest (~142 t CO2, bamboo-reforestation credits in Nicaragua) and Premio Cairo 2025 (~16.7 t CO2, climate/environmental credits in India via LifeGate).

Reference: page 93.

"To date, the Group does not have a dedicated policy for managing its impacts related to water and marine resources." Consistent with the Sustainability Policy, it "is committed to monitoring its activities with high environmental impact, with particular focus on production activities and the supply chain." The material IRO is a current negative impact - "Water withdrawal affecting resource availability arising from upstream value chain activities in the paper production process" - sited entirely in the upstream paper supply chain, not the Group's own operations; IRO-1 found no material water risks or opportunities and no consultation with affected communities on water.

Reference: page 93.

"To date, the Group has not implemented specific actions or initiatives to manage the negative impact related to water withdrawal" itself; instead it relies on its paper and printing suppliers, who "demonstrate their ongoing commitment to the environment through certifications of eco-friendly production processes, such as ISO 14001 certification, EMAS ... and 'Ecolabel' certifications" and publish water-stress risk analyses. "These analyses show that most suppliers operate in low/medium water stress areas, except for a few suppliers that also operate in Italy, Belgium and Spain, where almost all water resources withdrawn are in areas with medium/high water stress conditions," and those suppliers "stated that they aim to reduce water resource consumption and increase water recycling."

Reference: pages 93-94.

"The Group currently has no defined targets for water management," but commits to "continue to monitor the analyses carried out by major raw material and printing suppliers and, whenever possible, request specific information on their water footprint, in order to assess suitable ways for the Group to contribute to the responsible management of water consumption."

Reference: page 94.

"To date, the Group has not conducted a structured resilience analysis regarding its strategy and business model in relation to physical, transitional, and systemic risks related to biodiversity and ecosystems. This is partly due to the fact that no material risk factors have been identified in relation to these cases." The single material IRO is a potential negative impact - "changes in biodiversity and natural ecosystems and/or severe degradation related to raw material production processes, especially paper" - tied to the Group's paper supply and deforestation risk in biodiversity-sensitive areas, sited in the upstream value chain. No land degradation, desertification, soil sealing or threatened-species impact was identified, and no biodiversity risks or opportunities were found material.

Reference: page 95.

"To date, the Group does not have a formalized policy in place regarding the management of its impacts and dependencies related to biodiversity and ecosystems." Consistent with the Sustainability Policy, it "is committed to monitoring its activities with high environmental impact, with particular focus on production activities and the supply chain."

Reference: page 95.

The main lever is certified paper sourcing: suppliers hold ISO 14001, EMAS and Ecolabel certifications and are "active in global reforestation programs." Unidad Editorial became "the first Spanish daily newspaper publishing group nationwide to earn the PEFC ... seal for its print publications" in 2023; in September 2025 Cairo Editore and RCS MediaGroup completed the process to extend PEFC-logo use to their weekly/monthly/bimonthly/quarterly magazines. The Group also used biodiversity-offset carbon credits (see E1-7) but "did not conduct analyses to integrate local knowledge on the nature of biodiversity-related actions" in 2025. "The implementation of the above actions did not involve significant operating or capital expenditure."

Reference: pages 95-96.

"The Group does not have measurable quantitative targets in place related to Biodiversity Protection," but monitors action implementation via paper-procurement checks and periodic verification of printers against the PEFC-certified-company register; the 2025-2026 Sustainability Plan target is to maintain PEFC certification in Italy and Spain and "minimize the effect that the Group's activities may have on deforestation due to paper sourcing." "No ecological thresholds were applied in setting the target," and it is not based on the post-2020 global biodiversity framework or the EU Biodiversity Strategy 2030.

Reference: page 96.

The Sustainability Policy "does not directly address the gradual phase-out of virgin resources ... or the sustainable sourcing and use of renewable resources," though it and the Code of Ethics reference a guideline "to promote environmentally-responsible purchasing policies, including a focus on waste reduction." The main raw material is paper (purchased centrally in Italy and Spain from certified eco-friendly suppliers using "mainly recycled-based paper and pulp"); the other is printing ink. Waste from production sites goes "to specialized and authorized companies for recovery or disposal," with disposal method set by the EWC waste code; paper is the most significant waste stream, declining with lower print volumes and page counts.

Reference: pages 96-97.

Beyond PEFC-certified paper (see E4-3), the MediaGreen Project (started 2022 in the Group's main Italian locations) targets office paper-waste reduction. "The production cycle of paper raw material itself serves as a virtuous example of the circular economy: unsold copies returned to the publisher are recovered through sale to specialized pulpers," who reuse the paper in production. Unidad Editorial's 2023 "Reciclos" project recycles cans/bottles via a compactor at its San Luis site with an employee bonus incentive, continuing through 2025; a similar "bottle to bottle" PET-recycling initiative runs at La7 in Italy. "The implementation of the above actions did not involve significant operating or capital expenditure."

Reference: page 97.

"The Group does not have measurable quantitative targets in place related to resource use and circular economy," but monitors 2024-2026 Sustainability Plan policies and actions such as maintaining PEFC certification and "gradually increasing electricity from renewable sources," aligned with the Sustainability Policy's aim to optimize energy and natural-resource use and promote waste reduction.

Reference: page 98.

2025 material inflows (t): Paper - Offices 44.2 (2024: 44.3), of which 0.3% from a certified sustainable supply chain and 0.3% secondary materials; Paper - Production sites 71,157.5 (2024: 76,268.5), of which 0.1% certified-sustainable and 8.3% secondary materials; Ink 601.0 (2024: 614.1), all classified as technical materials; Plates 190.1. Paper is purchased centrally for the Group's own and third-party production sites in Italy and Spain.

Reference: pages 99-100.

At production sites, "hazardous waste includes mainly ink sludge and chemical materials for plate development," while "paper production waste is recovered and managed within the pulping process"; data come from the Waste Identification Form. At locations/offices, Italian waste data cover the main sites (Milan Via Rizzoli and Via Solferino, Rome Via Campania and Via Novaro/Durazzo) under direct management; where primary data are unavailable, waste is estimated using a per-square-metre generation index. Spanish office waste (San Luis) is classified at source by waste-management-company certification; Spanish distributor-managed waste paper is excluded from the figures.

Reference: pages 99-100.

"39. Total amount of hazardous waste" was 105.9 t in 2025 versus 98.9 t in 2024, an increase of approximately 7%, "due mainly to the reclassification of waste from chemical solutions used in the printing process at the RCS Produzioni S.p.A. production site, as well as to the reorganization of space at the San Luis building, which led to the disposal of obsolete equipment, and an incident involving the diesel fuel tank of the generator sets, which rendered the stored fuel unusable and required its full transfer to an authorized operator." The disclosure also breaks out non-hazardous waste and recovery routes (preparation for re-use, recycling, other recovery) by waste type.

Reference: pages 102-104.

Personnel policy sits in the Sustainability Policy and Code of Ethics, which "aim to guarantee its employees and associates respect for human dignity" and non-discrimination on race, religion, politics, nationality, gender, sexual orientation or health status. Human-rights commitments reference the UN International Charter on Human Rights, UN Guiding Principles on Business and Human Rights, ILO conventions and OECD Guidelines. In 2025 RCS Group Italy "approved the Gender Equality Policy," completing a framework that includes the Diversity & Inclusion Charter of Values, a gender-representation policy for panels, and the Workplace Harassment Prevention and Management Model (adopted 2024); a Gender Equality Steering Committee was appointed to monitor it.

Reference: page 104.

Engagement channels include training sessions, the corporate intranet, cross-functional working groups, and "Focus Groups, Surveys, discussions and negotiations with the Editorial Committees and the Trade Union Representatives." Human Resources functions in Italy and Spain hold operational responsibility. Dialogue with social partners runs through works councils "with at least ten meetings per year," with trade unions playing "a rather significant role" given the need to resolve operational issues quickly.

Reference: page 104.

Grievance handling applies national labour law and collective agreements, with the Code of Ethics providing communication channels via intranet/website governed by the Whistleblowing Procedure (shared by Cairo Group and RCS Group, described under G1-1); RCS integrated it with the Workplace Harassment Prevention and Management Model. Regular meetings with managers, workers and union representatives serve as "formal occasions for collecting information and various kinds of reports." The report notes that in the reporting year "no such [potential negative] impacts occurred," so remediation processes were not triggered.

Reference: pages 105-109.

Actions span productivity/skills investment, health and safety (an ISO 45001-aligned accident-management system, Prevention and Protection Services structured across five risk macro-areas - office, publishing, printing, events, TV studios), and privacy (a GDPR-based programme with DPIAs, training and Privacy Committees in Italy and Spain, established in Spain in 2025). Under the 2025-2026 Sustainability Plan, 12 named initiatives ran in 2025, including Unidad Editorial's "Planes de igualdad," RCS's 2025/2026 Welfare Plans, La7's welfare-bonus conversion agreement, and training programmes: an ESG e-learning course reaching 152 people in Cairo Group and 1,107 at RCS, a women's-empowerment programme (140 hours, ~20 participants) and a harassment-prevention e-learning course (432 participants, 324 hours). "The implementation of the above actions did not involve significant operating or capital expenditure."

Reference: page 109.

"The Group has always aimed to reduce occupational accidents to the point of eliminating them entirely," relying on investigating accident causes for corrective action. "While the Group does not have measurable quantitative targets in place," it commits to sustained focus on diversity and skills development per the 2025-2026 Sustainability Plan, through ongoing monitoring, awareness/training initiatives on Diversity & Inclusion, and needs-tailored training programmes.

Reference: pages 60-61, 110-111.

At 31 December 2025 the Group had 3,819 employees (2024: 3,810): 2,705 in Italy (1,610 executives/managers/white collars, 939 publication editors/journalists, 156 blue collars), 1,083 in Spain (622/461/31), and 31 in other countries. Italy breaks down by gender as 1,201 women and 1,504 men (2024: 1,205/1,482). "Since there have been no changes in the Group structure or in the activities carried out, the figures in the tables below are broadly in line with those of the prior year."

Reference: page 112.

"60. a) Percentage of its total employees covered by collective bargaining agreements" was 99.2% in both 2025 (3,789 of 3,819 employees) and 2024. "63. a) Coverage of social dialogue" (workers' representatives) was 98.5% in 2025 versus 98.0% in 2024 (restated). A 2024 figure was restated: the Group-wide covered-employee count "amounting to 3,700 ... has therefore been restated to 3,780" after a methodology update for Unidad Editorial S.A. data. Non-EEA operations (Mexico, Dubai) are excluded as below the 50-employee regulatory threshold; granular country-band breakdowns (60.b/60.c, 63.a) are itemized under the BP-2 phase-in table.

Reference: pages 113-114.

Senior/top management (first and second levels below governing bodies of the parent companies): 120 people in 2025 (2024: 122) - 30 women (25.0%) and 90 men (75.0%), up from 29 women (23.8%) in 2024. "Top Management" is defined as the first and second levels below the governing and supervisory bodies of Cairo Communication S.p.A., RCS MediaGroup S.p.A. and Unidad Editorial S.A. An age-group breakdown of the workforce is also disclosed.

Reference: page 114.

"Employees of the Group receive adequate pay. Adequate pay is defined according to collective agreements, where applicable. In countries where collective agreements are not applicable, the term 'adequate pay' refers to the prevailing 'minimum wage' established by local regulations, where applicable, or alternatively, based on benchmarks proposed by the Wage Indicator Foundation."

Reference: page 114.

"88. a) Percentage of people in its own workforce who are covered by the undertaking's health and safety management system based on legal requirements and/or recognized standards or guidelines" was 100.0% in both 2025 and 2024. "88. b) Number of fatalities" was zero in both years. "88. c) Number of recordable workplace accidents" fell to 9 in 2025 from 15 in 2024, against 6,101,340.7 hours worked (2024: 6,097,191.7), giving a recordable-accident rate of 1.5 (2024: 2.5). Granular datapoints under paragraph 88(d)/(e) are itemized in the BP-2 phase-in table.

Reference: page 114.

"97. a) Female-male pay gap" narrowed to 15.2% in 2025 from 16.8% in 2024 (average gross hourly pay: women Euro 27.0/26.8, men Euro 31.9/32.3, 2025/2024). The "annual total pay ratio" - highest-paid individual's total annual pay versus the median of all other employees - was 70.1 in 2025, down from 73.4 in 2024.

Reference: page 114.

"During the reporting period, within the Group's Italian companies, no serious human rights incidents were reported to the Supervisory Bodies or Human Resources Departments, nor were any complaints related to episodes of discrimination (including harassment) submitted. For Unidad Editorial, investigations conducted in 2025 did not identify any discrimination or harassment."

Reference: page 116.

The Sustainability Policy "applies to Group companies, employees, agents and contractors, suppliers, and other business partners." The Group "opposes all forms of exploitation, including child labour, as well as any form of psychological or physical abuse or coercion against its workers and those employed along the value chain," per the Code of Ethics and Sustainability Policy. Under the 2025-2026 Sustainability Plan's "Developing a sustainable supply chain" strand, the Group "will assess implementing a Supplier Code of Conduct and the Policy on the Safeguarding and Protection of Human Rights ... also for Cairo Group companies." No instances of non-compliance with the UN Guiding Principles, ILO Declaration or OECD Guidelines involving value-chain workers were reported.

Reference: page 116.

"Although the RCS Group does not have a dedicated engagement process, it indirectly considers workers in the value chain through the supplier qualification process managed centrally within the Supplier Portal," where suppliers must accept the Code of Ethics and Model 231; strategic-supply contracts require compliance with Decree 231/01 and the Group's ethical principles.

Reference: page 116.

The shared Whistleblowing procedure (Cairo Group and RCS Group, described under G1-1) covers value-chain-worker concerns. On supplier-privacy risk, "the Group has in place stringent rules and policies, complemented with a corporate culture that needs to be aligned with the latest regulations that have extended and consolidated the protection of data subjects' rights."

Reference: pages 116-118.

Contractual standards require suppliers to comply with health/safety regulations, certify contribution payments (DURC), meet economic/technical requirements, and accept the Code of Ethics/Model 231 (or Spanish ethical standards). RCS's Italian companies adopted the Policy on the Safeguarding and Protection of Human Rights, with "a dedicated process to identify specific actions to respond to negative impacts concerning workers along the value chain"; a Supplier Code of Conduct is under development for adoption next year. "In 2025, no severe Human Rights issues and incidents related to the upstream and downstream value chain of the Group were reported." "The implementation of the above actions did not involve significant operating or capital expenditure."

Reference: page 118.

"To date, the Group does not have measurable targets in place related to material impacts concerning value chain workers," but monitors action effectiveness under the 2025-2026 Sustainability Plan's "Developing a sustainable supply chain" objective. "Currently, there is no direct employee involvement in the value chain to set objectives, define a monitoring system, and establish improvement actions."

Reference: pages 119-120.

Per the Sustainability Policy, the Group "is committed to generating a positive impact on people's lives and community development," with attention to quality information, culture, sport, non-profit support (especially in emergencies), women, disabilities, schooling, digital development and youth professional development. No cases of non-compliance with the UN Guiding Principles, ILO Declaration or OECD Guidelines involving affected communities were reported in own operations or the value chain, and "no material negative impacts on affected communities were reported."

Reference: page 120.

Engagement values include "defense and freedom of ideas," support for sports/social activities, attention to women's topics, and promotion of technological-progress initiatives. Community support is triggered by "any emergency situations," including fundraising events; "There is no dedicated function for the involvement of affected communities."

Reference: page 120.

"No material negative impacts on affected communities were found in the Double Materiality process." Concern-raising runs through the shared Whistleblowing Procedure (Cairo Group and RCS Group), described under G1-1.

Reference: pages 120-121.

Initiatives generating the material positive impact include Corriere della Sera's "Buone Notizie" third-sector magazine and Milano Civil Week; Fondazione Candido Cannavò (solidarity, prison work, disability support via sport); the Milano Marathon Charity Program relay fundraiser; and, in Spain, Unidad Editorial's collaboration with "Comité de Emergencia" providing media space to raise funds for Myanmar earthquake victims (April 2025). "No incidents, complaints and severe human rights impacts were reported in relation to the affected communities." "The implementation of the above actions did not involve significant operating or capital expenditure."

Reference: page 121.

"While the Group does not have measurable quantitative targets related to the affected communities, it has defined a qualitative target in its 2025-2026 Sustainability Plan," aimed at continuing to promote sustainability values via events and publishing initiatives responsive to community needs.

Reference: pages 123-124.

The Sustainability Policy commits the Group to being "an authoritative, innovative, and relevant source of cultural stimulation," building relationships on "integrity, trust, and transparency." Journalists follow the Charter of Journalist Duties and the Code of Ethics, with special protections for minors' data (2006 Treviso Charter in Italy, Ley Organica 1/1996 in Spain). Privacy compliance runs under GDPR, Italian Legislative Decree 196/2003 (as amended) and Spain's LOPDGDD. No non-compliance with the UN Guiding Principles, ILO Declaration or OECD Guidelines involving consumers/end-users was reported during the year.

Reference: pages 124-129.

Engagement runs through surveys (e.g. Corriere Milano/ViviMilano readership research, a Gazzetta dello Sport fantasy-football survey) and external institutions for comparability over time. An AI-assisted content-tagging project measuring ESG content on corriere.it found "an increase of approximately 25% in ESG content published versus last year, reaching approximately 6,900 articles (approximately 5,500 articles in 2024)." Numerous sustainability-themed editorial initiatives and events ran across Green/sustainability (Pianeta 2030, L'Economia del Futuro), Diversity & Inclusion (Il Tempo delle Donne, Top Leaders LGBTI Spain), information/culture, and sport/health/nutrition strands in Italy and Spain. "There is no dedicated function for consumer and end-user engagement processes."

Reference: page 129.

The shared Whistleblowing Procedure (Cairo Group/RCS Group, described under G1-1) applies. CAIRORCS Media in 2025 ran market-research studies for advertising clients: two "market scenario and communication diagnostics" studies, seven "brand lift" analyses, three event-linked studies, roughly 30 Digital Branded Content effectiveness studies, and ongoing customer-care research for small/SME advertisers via the CAIRORCS Store portal. "There are dedicated reporting channels for subscribers and readers of Group titles."

Reference: pages 130-134.

On misleading-content risk, the Group applies Italy's Self-Regulatory Code of Commercial Communication / Spain's Codigo de Conducta Publicitaria plus sector-specific rules (Legislative Decree 145/2007, Consumer Code); ads are pre-assessed for lawfulness and editorial-line compatibility. On privacy, the Group runs Privacy Committees in Italy and Spain, a DPO, a Privacy Office, Data Processors under GDPR Art. 28, and a formalized data-breach process, plus IT-security measures (dual-layer access protection, next-gen WAFs rolled out fully in 2025, disaster-recovery replication across data centres). "To date, there is no formalized process in place to identify the actions needed in response to a negative impact on consumers and/or end-users, but the topics are nonetheless being overseen as described." "No incidents, complaints and severe human rights impacts were reported in relation to consumers and end-users."

Reference: page 134.

"While the Group does not have measurable quantitative targets in place, it continues to monitor the effectiveness of policies and activities adopted related to impacts, risks and opportunities," overseen through its existing rules, procedures and organizational structures, aiming to sustain its role in information/culture/entertainment "while respecting the principles of freedom, fairness, and pluralism."

Reference: pages 135-138.

Cairo Communication S.p.A. runs an Internal Control and Risk Management System; RCS MediaGroup determines its own governance independently. Model 231 (adopted 2008, last updated 2023) has general and offence-specific sections (corruption, corporate/tax crimes, health-and-safety violations, environmental crimes), backed by a Code of Ethics and a Supervisory Body per Group company reporting to the Board. "The Group has not identified any functions particularly exposed to the risk of corruption or bribery but considers the risk to be widespread across the organization." A new IT whistleblowing channel (aligned to Legislative Decree 24/2023) handles written/oral, including anonymous, reports, managed by a Committee of the Head of Internal Audit and Head of Legal and Corporate Affairs.

Reference: pages 138-140.

Key dependencies are printing outsourcing (Italy/Spain), Spanish distribution, and raw materials (paper, inks, plates). RCS joined the Italian Global Compact Network's "Sustainable Procurement" Working Table. "Suppliers are selected based on economic criteria that currently do not specifically take into consideration preset social or environmental aspects," though paper and add-on-goods suppliers face added ESG assessments; non-EU add-on suppliers must accept "Ethic Principles" covering child/forced labour, discrimination and safety. In 2025 RCS integrated ESG questions into its centralized supplier-portal questionnaire to assign an internal ESG score, with a 2026 roll-out planned. "It is worth noting that the Group does not have a formalized policy to avoid payment delays."

Reference: pages 140-142.

"The rejection of corruption and bribery in the management of own operations is the cornerstone of the decisions that steer the activity of the Group," implemented through Model 231's internal controls. Anti-corruption training in 2025 covered 1,510 at-risk employees in Italy (up from 152 in 2024), including 76 managers and 1,433 other staff, via a ~1-hour online course on Legislative Decree 231/01 topics (predicate offences, at-risk areas, control protocols, reporting system, penalties). RCS Spain's biennial "Ley Organica" training is next due in 2026. RCS operates specific anti-corruption procedures (gifts/donations, conflicts of interest, PA relations, whistleblowing).

Reference: pages 140-142 (part of MDR-T/GDR-T disclosures; no stated quantitative target).

The Group has not set a quantitative business-conduct target, but tracks the effectiveness of its anti-corruption programme through periodic monitoring: anti-corruption training coverage rose sharply in 2025 to "1,510 employees considered at risk, including 76 managers and 1,433 other employees" (up from 152 in 2024), delivered via an updated Legislative Decree 231/01 course; the Supervisory Body conducts "audits that may be both regular and one-off" of Model 231 compliance and reports to the Board, the Control, Risk and Sustainability Committee and the Board of Statutory Auditors; and G1-4 confirms the year's incident outcome ("no confirmed incidents of corruption or bribery in 2025"). This training-and-audit monitoring stands in for a stated target under MDR-T's second limb.

Reference: page 142.

"There were no confirmed incidents of corruption or bribery in 2025." This nil return follows a year in which the Group extended its Legislative Decree 231/01 anti-corruption training to 1,510 at-risk employees in Italy (up from 152 in 2024) and continued Supervisory Body audits of Model 231 compliance (see G1-1, G1-3). No legal proceedings, sanctions or convictions for corruption or bribery involving the Group or its employees are otherwise disclosed in the statement.

Reference: page 142.

Contractual payment terms of within 60 days cover "approximately 62% of invoices by value and approximately 85% in terms of the number of invoices," and within-90-day terms cover "approximately 92% of the Group's invoices payable considered." Average invoice payment days were "approximately 81 days (approximately 83 days in 2024)." Distributed publishers and the sales network (agents/brokers) are excluded, as their payment involves advances and, for paper publishing, returns valuation. "There are no legal proceedings currently pending due to late payments."