Capgemini

The role of the administrative, management and supervisory bodies

Board composition

At December 31, 2024, the Capgemini SE Board of Directors has 14 members, including:

• 12 members elected by Shareholders' Meeting
• 2 members appointed in accordance with the employee representation system
• 82% of its members are independent
• 43% have international profiles
• 45% are women
• Average age: 59 years
• Average length of office: 5 years

Directors are appointed for a period of four years.

Gender balance: 45% women / 55% men (excluding Directors representing employees and employee shareholders as per French law)

Internationalization: 43%

Independence: 82% independent Directors (excluding Directors representing employees and employee shareholders)

Governance structure

The Company's current governance structure separates the duties of Chairman of the Board of Directors, exercised by Mr. Paul Hermelin, and Chief Executive Officer, exercised by Mr. Aiman Ezzat.

Following the Shareholders' Meeting of May 19, 2022, the Board of Directors decided to continue this separated governance structure. Mr. Paul Hermelin was reappointed as Chairman of the Board of Directors and Mr. Aiman Ezzat was reappointed as Chief Executive Officer.

The Board of Directors also decided to retain the position of Lead Independent Director for as long as the duties of the Chairman of the Board are assumed by a director who is not independent as defined by the AFEP-MEDEF Code. Mr. Frédéric Oudéa was confirmed in his duties as Lead Independent Director by the Board of Directors' meeting of May 19, 2022.

Board committees with sustainability oversight

The Board has four specialized committees:

Strategy & CSR Committee

• Chairman: Paul Hermelin
• Members: 5 (50% independent)
• Meetings in 2024: 6
• Attendance rate: 83%

The Strategy & CSR Committee assists the Board in defining the Group's strategic orientations and reviews the Group's CSR strategy, including climate and environmental issues.

Audit & Risk Committee

• Chairman: Xavier Musca
• Members: 4 (100% independent)
• Meetings in 2024: 7
• Attendance rate: 100%

Ethics & Governance Committee

• Chairman: Frédéric Oudéa (Lead Independent Director)
• Members: 4 (100% independent)
• Meetings in 2024: 5
• Attendance rate: 100%

Compensation Committee

• Chairman: Patrick Pouyanné
• Members: 5 (100% independent)
• Meetings in 2024: 3
• Attendance rate: 87%

Sustainability-related expertise and experience

The Board of Directors considers that Directors demonstrating CSR expertise, including expertise relating to climate change issues, are:

• Ms. Clarken
• Ms. Fearn
• Ms. Ferraro
• Ms. Herbert-Jones
• Ms. Moscoso del Prado
• Messrs. Ezzat, Hermelin, Oudéa, Musca, Pouyanné and Sievers

Experience and expertise of directors (excluding the CEO):

*Including expertise on climate change

Frequency of Board and Committee meetings

In 2024:

• Board of Directors: 7 meetings with 95% attendance rate
• 4 executive sessions (meetings of the Board convened in the absence of Executive Corporate Officers)
• Strategy & CSR Committee: 6 meetings with 83% attendance
• Audit & Risk Committee: 7 meetings with 100% attendance
• Ethics & Governance Committee: 5 meetings with 100% attendance
• Compensation Committee: 3 meetings with 87% attendance

Specific roles assigned

Executive Management:

• Chairman of the Board of Directors: Paul Hermelin (non-executive since May 2020)
• Chief Executive Officer: Aiman Ezzat (sole Executive Corporate Officer since May 20, 2020)
• Lead Independent Director: Frédéric Oudéa (also Chairman of the Ethics & Governance Committee)

Role and duties of the Chairman of the Board of Directors:

The Chairman of the Board of Directors chairs meetings of the Board of Directors. He prepares, organizes and leads the work of the Board of Directors and sets the agenda of meetings. He oversees the proper operation of the Company's bodies and the correct implementation of Board decisions. He ensures that Directors are able to carry out their duties and have all information necessary for this purpose.

The Chairman of the Board of Directors chairs and leads the Strategy & CSR Committee.

Duties of the Lead Independent Director:

• Consulted by the Chairman on the proposed Board meeting schedule and draft agenda
• Can propose items on the agenda at his own initiative or at the request of Directors
• Can bring together Board members in "executive sessions" in the absence of Executive Corporate Officers
• Leads the assessment of the composition and performance of the Board and its committees
• Steers the search for and selection of new Directors
• Chairs meetings to assess performance/compensation of the Chairman and Chief Executive Officer
• Holds regular discussions with Directors
• Conducts specific reviews to verify the absence of conflicts of interest
• May communicate with shareholders on governance and compensation issues
• Reports on his actions to the Annual Shareholders' Meeting

Powers of the Chief Executive Officer:

The Chief Executive Officer must seek and obtain prior approval from the Board of Directors for any decision which is of major strategic importance or which is liable to have a material impact on the financial position or commitments of the Company or its principal subsidiaries.

Board composition objectives for 2022-2026

During its meeting on February 14, 2022, the Board of Directors decided to renew the following objectives for its composition for the period 2022-2026:

1. International diversification to reflect changes in Capgemini's geographic spread and businesses
2. Diversity of profiles and expertise
3. Staggered renewal of terms of office
4. Maintenance of a measured number of Directors enabling coherence and collective decision-making

Independence arrangements

Independence criteria:

The Board applies the definition of independence from the AFEP-MEDEF Code. A director is independent when he/she has no relationship with the Company, the Group or its Management, that is likely to impair his/her judgment.

The following criteria are examined:

1. Not an employee/Corporate officer in the previous 5 years
2. No cross directorships
3. No material business relationships
4. No family ties with a corporate officer
5. Not the auditor in the last 5 years
6. Has not been a director for more than 12 years

Independence review:

Based on the report of the Ethics & Governance Committee, the Board of Directors examined the personal situation of each member during its meeting of February 17, 2025.

Result: 9 of 11 members (82%) are independent (excluding Directors representing employees and employee shareholders): Megan Clarken, Ulrica Fearn, Maria Ferraro, Siân Herbert-Jones, Belen Moscoso del Prado, Xavier Musca, Frédéric Oudéa, Patrick Pouyanné and Kurt Sievers.

Conflict of interest prevention:

The Board of Directors' Charter requires Directors to notify the Chairman of the Ethics & Governance Committee or the Board of any one-off conflict of interests or potential conflict of interests and to refrain from attending deliberations and voting on the related decision. Any director who has a permanent conflict of interest is required to resign from the Board.

An appraisal procedure assesses any conflicts of interest from business relations. A statement of business flows between Capgemini Group and entities that are suppliers/clients with Directors in common is prepared annually and communicated to the Lead Independent Director. Each year Directors issue a statement regarding the existence or absence of any conflicts of interest.

Diversity policy for the Board

The Board of Directors regularly assesses its composition and ensures the best possible balance with regards to international development and diversity, changes in its shareholding base, and the various challenges facing Capgemini, including sustainability issues.

Results at December 31, 2024:

• International diversification: 43% (6 out of 14 Directors)
• Gender diversity: 45% women (excluding Directors representing employees and employee shareholders)
• Diversity of profiles and expertise: Maintained through renewals in 2024

Nationality breakdown:

• 8 French
• 1 United Kingdom
• 1 Spain
• 1 Canada
• 1 Germany
• 1 Sweden
• 1 New Zealand

Tenure breakdown:

• 4 Directors: 7 years and more
• 5 Directors: 3 to 6 years
• 5 Directors: 0 to 2 years

Assessment of the Board

The Board of Directors' Charter states that the Board conducts an assessment of its composition and performance once a year. This assessment is led by the Lead Independent Director.

During the last Board assessments, the Directors expressed their full satisfaction with the creation of the position of Lead Independent Director, the role and activities enabling the balance desired by the Board to be achieved, in line with best governance practices.

Integration of sustainability-related performance in incentive schemes

Roles covered

Sustainability-related performance is integrated into the compensation of:

• Chief Executive Officer (CEO): Variable compensation and performance shares include sustainability KPIs
• Top management: Performance shares tied to sustainability objectives
• Vice-President population: Sustainability KPIs integrated in variable compensation scheme either through country specific sustainability targets or through a multiplier impacting the variable compensation

The Compensation Committee ensures the CEO implements a non-discrimination and diversity policy in the Group governing bodies (including targets).

Specific sustainability KPIs tied to remuneration

CEO Annual Variable Compensation (2024)

CSR indicators representing 20% of overall variable compensation and 50% of CEO's personal objectives:

• Gender diversity: Improvement in gender mix in executive leadership positions
• Sustainability objectives: Related to sustainability offerings and talent development

CEO Performance Shares (Long-term Incentive)

20% of the CEO's performance shares are tied to Group long-term diversity and sustainable development objectives, with each objective equally weighted:

1. Diversity objective (2024 grant): Target increase in percentage of women in Executive leadership positions to 31% by end of 2026

2. Sustainable development objective: Reduction of operational GHG emissions (excluding commuting) by 75% by end of 2026 compared to 2019

Top Management (Performance Shares since 2018)

Since 2018, sustainability criteria have been included in performance shares plans approved annually, with long-term targets aligned to the ESG Policy:

• Gender diversity: Improvement in gender mix in executive leaders' population
• GHG emissions reduction: Reduction in GHG emissions per employee by end of 2026 versus 2019 reference year for operational emissions (commuting excluded)

Weighting (% of STI/LTI tied to sustainability)

Percentage of variable remuneration dependent on sustainability-related targets:

• 2023: 20.0%
• 2024: 20.0%

Performance period and target structure

• CEO annual variable compensation: Annual assessment of objectives set by Board of Directors
• Performance shares (CEO and top management): Typically 3-year performance period (e.g., 2024 grants measured by end of 2026)
• Targets set in resolutions submitted to shareholders for approval annually

Link to short-term incentive (STI) and long-term incentive (LTI)

• STI: CEO annual variable compensation includes 20% sustainability-related objectives
• LTI: CEO and top management performance shares include 20% sustainability-related conditions
• Vice-President variable compensation: Sustainability KPIs integrated through country-specific targets or multipliers

Performance measurement

The Board of Directors monitors the integration of sustainability-related performance in CEO and top management compensation through:

• Annual review by Compensation Committee of CEO objectives including Diversity, Sustainability-related offerings, and Talent (for 2024)
• Progress reviewed following year by Compensation Committee for Board recommendation
• Performance shares criteria approved by Board of Directors and submitted to shareholder vote
• Employee variable compensation criteria approved by Group Executive Board and ultimately by CEO

Governance and approval process

• Compensation Committee: Makes proposals to Board regarding fixed and variable compensation of executive corporate officers, including long-term incentive instruments
• Board of Directors: Sets sustainability-related objectives of CEO annually and approves performance share plans
• Shareholders: Vote on performance shares resolutions and director compensation
• Performance shares criteria submitted annually to shareholder approval

Payout disclosure

No specific disclosure of actual payout amounts against sustainability KPIs in the reporting period was provided in the excerpts. Progress in relation to CEO objectives is reviewed the following year by the Compensation Committee for recommendation to the Board of Directors.

Strategy, business model and value chain

Description of products/services and key markets

Capgemini is a global business and technology transformation partner, helping organizations to accelerate their dual transition to a digital and sustainable world, while creating tangible impact for enterprises and society. It is a responsible and diverse group of 340,000 team members in more than 50 countries.

With its strong over 55-year heritage, Capgemini is trusted by its clients to unlock the value of technology to address the entire breadth of their business needs. It delivers end-to-end services and solutions leveraging strengths from strategy and design to engineering, all fueled by its market leading capabilities in AI, generative AI, cloud and data, combined with its deep industry expertise and partner ecosystem. The Group reported 2024 global revenues of €22.1 billion.

Portfolio of Services

Capgemini is active in the business and technology services market, as well as in the engineering, research & development (ER&D) services market. Together, those markets are estimated to be worth $1.8 trillion and are both growing at strong single digit growth rates.

The portfolio of services is designed to bring value propositions to clients, including transformation, solutions and operations delivering tangible business and operational outcomes. The Group leverages its mastery of ever-changing technologies, as well as its deep understanding of industries and clients' most pressing business challenges to develop packaged offers by industry and for C-suite executives.

Key offerings include:

• Customer First: Transforming the experience that clients deliver to their customers, including the value of their products and services, and the quality of each customer interaction.

• Intelligent Industry: Digitally transforming the client value chain, from the design and development of intelligent products and services to intelligent supply chain, extending to the smart manufacturing of products and intelligent service operations.

• Enterprise Management: Transforming the processes, teams, solutions and operations in order to run enterprises with greater agility and operational efficiency and therefore offer a seamless, personalized experience to employees.

Two enablers:

• Cybersecurity: Cybersecurity is at the heart of all offerings. The Group helps IT and security teams enhance corporate security by identifying and assessing risks and vulnerabilities, developing risk mitigation plans, and implementing processes, security architectures, and resources for cyberattack detection and response.

• Sustainability: All offerings incorporate sustainability at the core. Capgemini works with clients' management teams to tackle the climate emergency and accelerate their journey toward carbon neutrality. Together with operations managers, the mission is to decarbonize value chains, from production to distribution.

Sector Expertise

The Group cultivates expertise across seven major sectors:

1. Consumer Goods, Retail and Distribution: Working with consumer products companies, retailers and distributors to create a transformative digital vision and roadmap.

2. Energy & Utilities: Guiding energy and utilities companies as they master market shifts and technology-triggered trends in the energy transition.

3. Financial Services (Banking, Capital Markets & Insurance): Steering the digital and operational transformation of leading financial institutions.

4. Manufacturing: Supporting manufacturing companies (e.g., automotive, aerospace and defense) to innovate faster, get closer to customers, and achieve operational efficiency.

5. Public Sector: Working with public sector organizations to deliver outcomes through digital transformation and citizen-led innovation.

6. Telecommunications, Media & Technology: Bringing innovation, creativity, and domain expertise to solve telecom clients' most pressing challenges.

7. Services: Accompanying the digital transformation of the services industry (hospitality, travel and transport, engineering and construction, and professional services).

Significant groups of products/services

No specific breakdown of revenue by product/service group is disclosed in the excerpts.

Significant markets / geographies

Distribution of employees (headcount) by geographical areas (2024):

The Group operates in more than 50 countries. The bulk of its revenues are generated in Europe and North America. India alone accounts for around 50% of the Group's total headcount.

Sustainability-related goals embedded in the business model

Capgemini's business model is centered around providing opportunities from the worldwide Consulting, IT Professional Services and Digital Engineering markets with the relevant expertise to help clients transform at scale, transitioning towards a digital and sustainable economy.

ESG ambition embedded into strategy:

As a core pillar of the strategic vision and value creation model, Environmental, Social and Governance (ESG) is deeply embedded in the strategy and organization. The Group is committed to:

• Helping clients achieve their net-zero objectives, while simultaneously reducing own environmental impacts
• Collaborating with stakeholders to create positive impacts across the value chain
• Adopting policies that safeguard the long-term interests of Capgemini and its stakeholders
• Embedding sustainability in business offerings

Purpose: "Unleashing human energy through technology for an inclusive and sustainable future"

Sustainable offerings strategy:

Built on the following pillars:

1. Addressing clients' sustainability challenges: Enhanced value proposition with ESG-focused offerings and tailored solutions for climate tech innovators. Services encompass sustainability strategy, sustainable products, operations, technology, and ESG reporting.

2. Transforming delivery model: Sustainability is embedded in operations through mandatory training for employees and systematic measurement of project-related carbon footprints. The Sustainability Campus equips all employees with knowledge and tools needed to contribute effectively to sustainability goals.

3. Sustainability Accelerator: Launched in 2021 to position the Group to lead in sustainability services while creating long-term value for clients and the planet.

ESG Policy priorities (2025-2030):

The Group's ESG Policy represents a comprehensive approach to addressing environmental, social, and governance challenges. Following the 2024 stakeholders' consultation and double materiality assessment, the ESG Policy was updated with renewed priorities and targets for 2025-2030, including:

• New priority on 'enhance awareness and foster the adoption of ethical AI practices' with associated 2030 target
• Addressing challenges relating to non-employees (new policy to be adopted in 2025)
• Continuing implementation of roadmap on circular economy
• Business opportunity from offers to help clients achieve their sustainability commitments as a priority in its own right

Environmental commitments:

• Focus on ensuring the most sustainable buildings, operating them with optimum energy efficiency, and transitioning rapidly to renewable electricity
• Committed to reducing both business travel and commuting emissions per employee by 55% by 2030, compared to 2019
• Committed to acting beyond the value chain to help limit atmospheric greenhouse gas concentration
• Target: 98% of electricity came from renewable sources in 2024, with commitment to 100% renewable by 2025
• Member of RE100
• Net zero business by 2040

Social commitments:

• Capgemini is a people-oriented business that tackles challenges by leveraging the expertise, creativity, and commitment of all people
• Belief that everyone joining Capgemini is a talent in the making
• Offering individualized learning paths, appropriate guidance, and coaching
• Fostering a positive and healthy work environment
• Building an inclusive culture where every form of diverse talent thrives
• 42.7% women among new recruits
• 4,344 people with disability
• 29% proportion of women in executive leadership positions
• 25.73 million hours of training
• 7.7/10 employee engagement score
• 8.5% employee share ownership

Governance commitments:

• Establishing trusting but demanding relationships with all stakeholders
• Communicating regularly with all stakeholders
• Requiring suppliers to conduct business with highest environmental and social standards
• Avoiding all forms of corruption, bribery, extortion or embezzlement, and unfair business practices
• Commitment to protecting privacy of clients, employees and partners
• Recognized as One of the World's Most Ethical Companies® by the Ethisphere Institute for the twelfth year running in 2024

Description of the upstream and downstream value chain

Upstream entities:

1. Business partners

   • Alliances, suppliers, other partners
   • Teams (workers) of suppliers and partners
   • Market leaders, professional or industry organizations, standardization bodies
   • Strategic partnerships with high-profile technology companies and innovative startups
   • Majority of client engagements delivered in collaboration with one or multiple partners
   • Global ecosystem of partners including: Adobe, AWS, Aveva, C3.ai, Dassault Systèmes, DELL, Duck Creek, Google, Guidewire, IBM/Redhat, Intel, Liquid AI, Majesco, Microsoft, Mistral AI, Nvidia, OpenText, Oracle, Pega, PTC, Qualcomm, Salesforce, SAP, Schneider Electric, ServiceNow, Siemens, Sweep, Tenemos, UiPath, Unity, Verizon, VMware

2. Financial community

   • Shareholders
   • Banks, financial analysts, rating agencies, ESG indexes
   • Credit rating: BBB+/stable outlook by Standard & Poor's
   • Total equity of €11.8bn
   • €1,961 million organic free cash flow generation

Entities included in consolidation scope:

• Capgemini organization with 341,118 employees
• Employees, non-employee workers
• Local and international works councils
• Talent pool, families, alumni

Downstream entities:

1. Clients

   • Existing clients
   • Teams (workers) of the clients the Group interacts with
   • Potential clients
   • Clients' ecosystems
   • Global "Voice of the Client" program covering priority clients

2. End users

   • Users of solutions
   • Consumers of clients

Interaction with Public authorities and Civil society:

• Local authorities, regulators, legislators, EU
• International organizations (OECD, etc.)
• Local communities, academics, thought leaders, think tanks
• Citizens, NGOs, media
• Long-standing relationship through Digital Inclusion Programs
• Capgemini Research Institute interacts with global network of experts, universities, major academic institutions, startups and partners

• 1,000 social impact projects

• 7.5 million citizens have benefited from digital inclusion initiatives since 2018

Key inputs and outputs

Key inputs:

1. Human Capital

   • 341,118 talented employees in more than 50 countries
   • Broad diversity of profiles and expertise
   • Seven core values
   • Bold entrepreneurial spirit
   • Ethical culture as a guide
   • Dynamic evolving skills pipeline
   • Tailored world-class learnings
   • Inclusive and flexible work environment
   • 99% of employees have access to flexible work policy

2. Industrial Resources

   • Recognized industrial and technology know-how
   • Management of complex projects
   • 8 security operations centers
   • 73 delivery centers
   • Global Quality Management System
   • Global Cybersecurity Governance and Management System

3. Intellectual Capital

   • Continuous investment in R&D
   • Multi-award-winning Capgemini Research Institute
   • TechnoVision report
   • Strategic partnerships with technology and business leaders
   • Alliances with universities, schools, research centers, startups and recognized experts
   • Internationally recognized brand
   • 22 Applied Innovation Exchanges (AIE) worldwide
   • Capgemini Ventures for co-creating with startups

4. Financial Resources

   • Strong balance sheet with total equity of €11.8bn
   • €1,961 million organic free cash flow generation
   • €3,382 million in purchase of goods and services with suppliers

Key outputs:

1. Enhanced capabilities

   • Strategy & Transformation
   • Applications & Technology
   • Engineering
   • Operations

2. For Employees

   • 29% proportion of women in executive leadership positions
   • 25.73 million hours of training
   • 7.7/10 employee engagement score
   • 8.5% employee share ownership

3. For Business and technology partners

   • €3,382 million in purchase of goods and services
   • Majority of sales made alongside partners

4. For Society and public authorities

   • €681 million income tax expense

   • 1,000 social impact projects

   • Net zero business by 2040
   • Contribution to 11 out of 17 UN Sustainable Development Goals
   • 7.5 million citizens benefited from digital inclusion initiatives since 2018

5. For Shareholders and investors

   • Earnings per share of €9.82 (up 1.2% on 2023)
   • €1,552 million returned to shareholders (€580 million dividend, €972 million share buyback)
   • 13.3% operating margin

Value added sharing:

• 67.7% Employees
• 18.4% Public Authorities
• 9.8% The Group (Enterprise)
• 3.1% Shareholders
• 1.0% Creditors

Total value added: €18.7 billion

Interests and views of stakeholders

Identified key stakeholder groups

Capgemini identifies the following key stakeholder groups:

Affected stakeholders and users of the sustainability statement:

• Affected stakeholders: Individuals or groups whose interest are or might be affected by the Company or across its value chain
• Users of the sustainability statement: Primarily, financial stakeholders such as investors, secondarily other users such as NGOs, trade unions, business partners, academics

Specific stakeholder categories consulted:

• Clients and partners
• Market players
• Suppliers and sub-contractors
• Employees (including employee representatives through the International Works Council)
• Investors
• Local communities
• Non-governmental organizations (NGOs)
• ESG rating agencies
• Government authorities
• Experts in human rights, AI safety, technology and the environment

How the company engages with each group

Stakeholder consultation in 2024:

The project team consulted more than 30 internal and external stakeholders directly affected by Capgemini's activities and/or who can influence the business during the double materiality assessment.

Stakeholder engagement channels by group:

Frequency of engagement:

• IWC: quarterly meetings (4 times per year)
• IWC Bureau: monthly meetings
• Voice of the Client: annual
• Pulse surveys: regular (throughout the year)
• Stakeholder consultation for materiality: conducted in 2024 (previous consultations in 2018, 2020, and 2021)

Key concerns / views raised by stakeholders during the reporting period

Emerging concerns identified during 2024 stakeholder consultation:

1. Unethical use of Artificial Intelligence (AI) and technology in general: Identified as an emerging concern requiring particular attention

2. Non-employees: Specific challenges relating to non-employees working for Capgemini

3. Indirect impact on the environment of IT hardware purchases: Concerns related to circularity and environmental impact of hardware procurement

4. Human rights in the supply chain: Concerns about non-employees and the indirect impact through the value chain

Client perspectives (from Voice of the Client program):

• Annual ranking of top sustainability challenges
• Verbatim feedback on areas clients consider most pressing
• Findings presented annually to the Board of Directors to inform strategic implementation

How views are integrated into strategy and business model

Integration into ESG Policy and strategy:

The outcome of the 2024 stakeholders' consultation and Double materiality assessment were taken into consideration by the Group to update its ESG Policy at the end of 2024 with renewed priorities and targets for 2025-2030.

Specific actions taken in response to stakeholder concerns:

1. Ethical AI: In response to concerns about unethical use of AI:

   • Included in ESG Policy a new priority: "enhance awareness and foster the adoption of ethical AI practices"
   • Associated 2030 target established
   • Further described in Section 4.10 "S4 – End-users" and sub-Section 4.10.6 "Ethical use of technology (including AI)"

2. Non-employees: Will adopt in 2025 a new policy to address specific challenges relating to non-employees (see Section 4.7.1.2b "Non-employees working for Capgemini")

3. Circular economy and IT hardware: Continued implementing roadmap on circular economy (see Section 4.4 "E5 – Circular economy and resources"). Indirect impact of IT hardware purchases was already being addressed but has accelerated in 2024

4. Client sustainability commitments: The business opportunity resulting from offers to help clients achieve their sustainability commitments became a priority in the revised ESG Policy, with an associated target (see Section 4.3.4 "Helping clients achieve their sustainability objectives")

5. Human rights in supply chain: Efforts as part of due diligence plan will address topics such as ethical use of technology and AI, impact of value chain on circularity, and human rights in supply chain (see Section 4.8 "Value chain workers")

How policies address stakeholder material issues:

The company provided a table (referenced but not fully reproduced in excerpts) summarizing how various policies address stakeholder material issues across different stakeholder groups:

Policies addressing stakeholder concerns include:

• ESG Policy
• Anti-corruption Policy
• Code of Business Ethics
• Code of Ethics for AI
• Competition Laws Policy
• Conflict of Interest Policy
• Data Protection Policy
• Diversity and Inclusion Policy
• Employee Relations Policy
• Environmental Policies
• Health & Safety Policy
• Human Rights Policy
• Supplier Standards of Conduct

Integration into governance:

• Stakeholders' views taken into account regularly as part of ongoing dialogue described in Section 4.1.2.1
• Views expressed during 2024 general consultation used to identify the Group's material sustainability matters and update the Group's duty of care risk map
• Results of stakeholder consultation inform strategy and business model decisions
• "Capgemini strives to be a valued member of the communities in which it operates. Hence, we have policies in place to ensure we continue to operate our business safely, ethically, respecting human rights and aligned with the highest environmental and business conduct standards."

Distinction between affected stakeholders and users of sustainability information

Capgemini explicitly differentiates between:

Affected stakeholders: Individuals or groups whose interest are or might be affected by the Company or across its value chain. This includes:

• Employees
• Suppliers and sub-contractors
• Communities
• End-users/customers

Users of the sustainability statement: Primarily, financial stakeholders such as investors; secondarily other users such as NGOs, trade unions, business partners, academics.

The company states that "ESRS differentiates several types of stakeholders to be considered" and has structured its stakeholder consultation and engagement accordingly to capture both perspectives in the double materiality assessment conducted in 2024.

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

Overview of material sustainability matters

Following the double materiality assessment update, Capgemini's 25 material impacts, risks and opportunities can be aggregated into 15 macro sustainability matters as summarized below.

The most material sustainability matters (from both impact and financial perspectives):

• Climate change mitigation (1)
• Consumption of resources and indirect impacts on the supply chain (3)
• Digital inclusion and socio-economic development (9)
• Human rights in the supply chain (8)
• Diverse and inclusive environment (5)
• Social dialogue and collective bargaining (7)
• Ethical use of technology and AI (12)
• Cybersecurity (10)
• Data privacy (11)
• Helping clients achieve their sustainability objectives (2)
• Health and safety (6)
• Talent attraction, retention and development (4)
• Corruption and bribery (13)
• Trade controls (14)
• Anti-competitive practices (15)

Full list of material impacts, risks and opportunities

Material risks as per CSRD and their linkage to Group critical risks

Out of the 25 material impacts, risks and opportunities, 8 correspond to material risks for the Group in accordance with the Financial materiality or Outside-in vision.

Interaction with strategy and business model

As a global business and technology transformation partner, Capgemini helps organizations to accelerate their dual transition to a digital and sustainable world, while creating tangible impact for enterprises and society.

Committed to a digital and sustainable transition

Digital and sustainability transformation are intertwined and the need for a dual transition to a digital and sustainable economy has changed the game across industries. To turn these challenges into business opportunities, Capgemini mobilizes its industry expertise, leadership in data protection and cybersecurity, and mastery of new technological levers, with AI at the forefront, to create value and maximize impact for clients.

The portfolio of offers and strategy around sustainable offerings through industry-specific solutions is designed to bring value propositions to clients, helping them achieve their sustainability objectives. This in turn will fuel the resilience of Capgemini's business model through increased opportunities as clients' transition journeys accelerate.

As a responsible business, Capgemini is determined to play a leadership role in ensuring technology creates a sustainable future and drives internal change across operations and supply chain to minimize total GHG emission impacts and increase circularity. The diverse and agile nature of the business, serving a wide range of sectors with a varied portfolio of services, gives protection from the most disruptive transitional impacts of climate change. The business model is considered strong and resilient to respond to climate risks and opportunities across the whole value chain.

For all

Capgemini believes everyone joining Capgemini is a talent in the making. Through offering individualized learning paths, appropriate guidance, and coaching, as well as fostering a positive and healthy work environment, Capgemini builds an inclusive culture where every form of diverse talent thrives.

Technologies, whilst unlocking new opportunities for growth and enabling transformative advancements in sustainability, can also bring unintended social and ethical challenges. Capgemini's approach to the ethical use of technologies, including AI, as well as its Cybersecurity and Data Protection programs aim at creating a trusted environment while fostering innovation.

Capgemini also aims at driving impactful digital inclusion initiatives to equip underprivileged individuals with the skills they need to thrive in a digital world.

Material sustainability matters with greatest impact on business model and strategy

The sustainability matters assessed as material for Capgemini which can have the greatest impact on the business model and strategy are:

• Helping clients achieve their sustainability objectives
• Cybersecurity and data privacy
• Talent attraction, retention and development
• Unethical use of technology and AI
• Climate change mitigation

The maturity of the policies put in place by the Group to address these and the results obtained to date position Capgemini for long-term resilience.

Time horizons

Capgemini uses the following time horizons as defined in the ESRS:

• Short-term time horizon: the reporting period in financial statements (< 1 year)
• Medium-term time horizon: from the end of the short-term reporting period up to 5 years (2-5 years)
• Long-term time horizon: more than 5 years (> 5 years)

Each material IRO was assessed taking into account these time horizons.

ESG Policy 2025-2030: 9 priorities & 14 objectives

The Group aligned its updated ESG policy for 2025-2030 with the outcomes of the double materiality assessment conducted in 2024.

Environment: Protecting the planet

• Priority A: Act on climate change and become a net zero business, by 2040

  • Objective 1: Reduce our Scope 1, 2 and 3 emissions by 90%, by 2040
  • Objective 2: Scale up our investment in climate and nature solutions at a level commensurate with our total GHG emissions

• Priority B: Lead to a sustainable economy, by helping our clients achieve their sustainability commitments

  • Objective 3: Increase bookings (value) delivering sustainability benefits to our clients

Social: Shaping a future with protection & respect for all

• Priority C: Invest in our talents through an empowering experience

  • Objective 4: Reach and maintain 70 learning hours per employee per year
  • Objective 5: Upskill our talents on a yearly defined strategic topic
  • Objective 6: Maintain our employees' belonging index above 80

• Priority D: Maintain high ethical standards at all times

  • Objective 7: Keep over 80% of the employees with a positive perception of our Values, culture, and ethical behaviors in the Group
  • Objective 8: Enhance awareness and foster the adoption of Ethical AI practices

• Priority E: Enhance inclusion in our activities

  • Objective 9: Maintain 40% of women in our teams and reach 35% of women in executive leadership positions, by 2030

• Priority F: Support digital inclusion in our communities

  • Objective 10: Support 10 m beneficiaries in underserved communities through our digital inclusion programs, by 2030

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

Overview

In 2024, the Group updated its double materiality assessment in order to be compliant with the framework of the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) standards. The Group used its 2021 double materiality matrix, its 2021 ESG risk mapping, and 2023 Group Risk Map as the starting point for the 2024 double materiality assessment, while restructuring the analysis to meet the requirements of the CSRD and cross-referencing the results with the ESRS Standards.

In the CSRD framework, the double materiality assessment is a fundamental prerequisite for identifying and assessing sustainability matters, qualified as "Impacts, Risks, and Opportunities" (or "IROs").

Impact materiality ("Inside-Out" vision) focuses on impacts, positive or negative, actual or potential, on the population or the environment linked to the Group's own activities and its value chain including its services and its business relationships.

Financial materiality ("Outside-in" vision) focuses on sustainability issues that have a significant influence or can reasonably be expected to have a significant influence on the Group's business and financial performance (results, cash flow, market position, access to financing etc.): i.e., risks or opportunities.

The double materiality assessment considers sustainability matters that are either material from one perspective only (impact or financial) or both perspectives at the same time (impact and financial).

More than 30 internal and external stakeholders directly affected by Capgemini's activities and/or who can influence the business were consulted as part of this assessment.

Step-by-step methodology

To conduct the double materiality assessment, Capgemini mobilized an ad hoc Steering Committee, combining three key functions: Group Compliance, Group Risk and Insurance, and Group ESG. The Steering Committee has been supported by an external consultancy firm specialized in sustainable transformation and business risks services.

The project was designed in alignment with the "Materiality Assessment Implementation Guidance" published by EFRAG in May 2024, and comprised the following three phases:

Phase 1 – Identification of a potential IROs universe

Objective: Precisely understand Capgemini's context through a document review and corporate workshops, to set up a universe of pre-qualified IROs before assessment.

Own operations

The analysis covered the Group's consolidated scope, whose activities face similar risks and opportunities and generate relatively homogeneous impacts. The most relevant or at-risk geographical zones were identified on a case-by-case basis and when relevant, considering items taken from the analyzed documentation or as a result of comments raised by the interviewed stakeholders. Selected stakeholders were consulted to cover both at-risk and significant regions such as India, Brazil and the US.

Upstream and downstream value chain

The ESRS require companies to identify and assess IROs across their entire value chain, both upstream and downstream, linked to their services and business relationships beyond the scope of financial consolidation and beyond tier 1. Relevant matters can occur in connection with the processes at any stage of the value chain, contributing to the Company's operations or services.

From an impact perspective, impacts must identify negatively or positively affected stakeholders (suppliers, communities, clients, users, etc.). From a financial perspective, risks and opportunities must identify dependencies on resources affected by identified impacts (natural, social, cultural) or business relationships which have or may have significant financial effects.

The Group has considered its upstream and downstream value chain (beyond tier 1) with a focus on the products and services used by and also provided by the Group, which are considered to have a heightened risk of adverse impacts and/or financial effects. Important links in the value chain were identified for each IRO on a case-by-case basis and when relevant.

Upstream value chain

The assessment focused on purchasing categories such as travel providers, cloud services, AI providers, or third-party data centers for environmental impacts, especially indirect GHG emissions. Other impactful purchasing categories (up to the extractive phase) such as IT hardware and office furniture and machinery were also taken into account.

For upstream potential human rights violations and the impact on communities, the assessment focused on purchasing categories such as IT hardware and extraction of metals or core-business sub-contractors.

Downstream value chain

For the downstream value chain, the assessment focused on the following:

• direct Capgemini clients, affected by or involved in business conduct matters and other topics such as cybersecurity, or accounting for indirect GHG emissions related to the use of Capgemini's solutions and services;
• clients and end-users beyond Capgemini's clients (BtoBtoB or BtoBtoC) regarding, in particular, data privacy, technology safety and ethical use of AI by clients on these populations;
• communities (positively) affected by Capgemini, in terms of economic and social rights and development, access to technology; and
• market players and competitors of Capgemini which can be affected by business conduct matters indirectly.

Documentation review

To identify potential impacts, risks, and opportunities, the project team reviewed more than 40 internal documents, including the 2023 Universal Registration Document, the 2023 Group Risk Map, and the 2021 Group ESG Risk map, as well as specific studies such as the impact assessment conducted in 2023 on biodiversity, carbon emissions and socio-economic footprint. The project team also considered complementary external documents such as the sectoral SASB standard "software and IT services," the Water Watch index and the Food and Agriculture Organization.

Scenario analysis

To meet regulatory expectations, each IRO was assessed on a "gross" or "inherent" basis, which differs from pre-existing "net" scores in the Group Risk Map and previous Group ESG Risk Map, leading in some cases to higher severity scores or magnitude of financial effects scores.

Under ESRS, three time horizons, which are by default short (< 1 year), medium (2-5 years) and long term (> 5 years), must also be considered. The Group decided to use the pre-defined time horizons from ESRS 1 in its assessment.

Phase 2 – Stakeholders' consultation

Objective: Select a representative group of key stakeholders and sustainability statement users, and update the qualification of IROs and their assessment with their vision.

The latest consultation was conducted in 2024 and enabled the Group to i) identify the material sustainability matters, and ii) update the Group's duty of care risk map.

More than 30 internal and external stakeholders directly affected by Capgemini's activities and/or who can influence the business were consulted as part of this assessment involving representatives from all five stakeholders categories in the Group value chain.

Phase 3 – Assessment of material IROs and consolidation

Objective: Apply a scoring methodology to determine which IROs are material and aggregate the results into macro sustainability matters.

Scoring criteria

Assessment of risks and opportunities

1. Severity/Magnitude of financial effects

The severity/magnitude of financial effects has been evaluated on a scale of 1 to 4, where 1 means Minor and 4 means Major.

The scales used to evaluate the financial effects of risks were identical to those of the Group Risk Map (financial ranges are expressed in impact on the Group's operating margin). Financial ranges are also based on qualitative analysis, similar to Group Risk Management methodology: impact on strategic objectives, reputation, people, and compliance related impacts.

A specific scale was established to estimate the magnitude of financial effects for opportunities based on estimated or anticipated revenues.

2. Likelihood

The likelihood criteria also use a scale of 1 to 4, 1 being Unlikely, 4 being Almost Certain, and are based on the same scale as the one used for the different risk mappings within Capgemini.

Likelihood was also scored considering a qualitative assessment including known record or past cases for the Group or the sector; anticipated changes in regulation, technology or resources, as well as anticipated changes in stakeholders' expectations and scrutiny.

The likelihood of each risk and opportunity was evaluated in the short, medium, and long term, to determine the probability of a scenario happening over time. The three scores were averaged to calculate the final likelihood assessment on a scale of 1 to 4.

The final materiality of each risk and opportunity was assessed in line with the level of risk appetite used for the Group Risk mapping.

Assessment of impacts

The regulatory framework requires the assessment of two criteria:

• the severity of the impact, which is itself a combination of three criteria:
  • scale: How serious/beneficial the impact is for the environment or people?
  • scope: How widespread the negative/positive impacts are, e.g., geographical scope, number of people?
  • irremediability: Whether and to what extent the negative impacts could be remediated, i.e., restoring the environment or affected people to their prior state.
• the likelihood of the impact.

The Group defined severity criteria ranging from a scale of 1 to 4, 1 being Low, 4 being Major. The scale for likelihood of impacts is the same as the one used to assess risks and opportunities.

Focus on "actual" and "potential" impacts

As stated by the ESRS, it is important to identify whether the impact is actual or potential:

• if the impact is potential, the likelihood is assessed;
• if the impact is actual, the likelihood is not assessed, as it is not relevant.

Focus on "positive impacts"

In case an impact is considered as "positive," the "irremediability" criteria is not assessed, as it is not relevant.

Focus on negative impacts related to Human Rights

As stated by the ESRS, severity takes precedence over likelihood when assessing potential impacts on Human Rights. Consequently, for the impacts related to "other work-related rights" (notably child labor and forced labor) combined with fundamental freedoms ("collective bargaining", "social dialogue", "freedom of association"), potential negative impacts on the value chain were scored using only the severity criteria, and the likelihood was not assessed.

Assessment of each "potential impact"

The assessment of the potential impact is a combination of the following rules:

• severity: average of the two or three criteria assessed (scale, scope, irremediability); and
• likelihood: average of the three time horizon scores.

The final materiality of potential impacts was assessed in line with the level of risk appetite used for the Group Risk mapping.

Assessment of each "actual impact"

The assessment of the actual impact is only based on severity, made up of the average of the two or three criteria assessed (scale, scope, irremediability).

The final materiality of actual impacts was assessed in line with the level of risk appetite used for the Group Risk mapping.

Threshold for materiality

The final materiality of each risk, opportunity and impact was assessed in line with the level of risk appetite used for the Group Risk mapping.

Consolidated results

The assessment of each IRO was determined on the basis of:

• an analysis of the documentation at the start of the project (relevant and objective internal documentation, statistics, external sources, international benchmarks, etc.); and
• consultations of stakeholders (6 pre-consultations with Capgemini's top management conducted in phase 1, and 30 internal and external consultations conducted in phase 2).

The assessment was performed by the Steering Committee, to ensure the consistency of the assessment with the Group Risk Map as well as the relevance and the homogeneity of the assessments between the different topics.

The final results were validated by the Chief Executive Officer and members of the Executive Committee in charge of relevant risks, opportunities and impacts, and presented to the Audit and Risk Committee of the Board of Directors of Capgemini SE at its meeting on October 22, 2024. The 2024 Sustainability Statement, including the results of the double materiality assessment, was approved by the Board of Directors on February 17, 2025.

Frequency / when last reviewed

The double materiality assessment was updated in 2024. Prior to the 2024 consultation, Capgemini's stakeholders had been consulted in relation to previous materiality assessments conducted in 2018 and 2021, and the 2021 duty of care risk map.

Use of value chain mapping in the process

The Group has considered its upstream and downstream value chain (beyond tier 1) with a focus on the products and services used by and also provided by the Group, which are considered to have a heightened risk of adverse impacts and/or financial effects. Important links in the value chain were identified for each IRO on a case-by-case basis and when relevant, considering items taken from the analyzed documentation or as a result of comments raised by the interviewed stakeholders.

The assessment focused on purchasing categories such as travel providers, cloud services, AI providers, third-party data centers, IT hardware, office furniture and machinery, and core-business sub-contractors for upstream value chain.

For downstream value chain, the assessment included direct Capgemini clients, end-users beyond Capgemini's clients, communities affected by Capgemini, and market players and competitors.

Main changes in the methodology compared to the previous reporting period

In the context of this standardized exercise, several methodological components are new for Capgemini compared to the 2021 ESG risk mapping exercise and the 2021 double materiality assessment:

• the assessment was designed by considering the mandatory ESRS topics, automatically generating more precise and disaggregated matters than previously;
• certain sustainability matters previously communicated in the Universal Registration Document were excluded from the assessment (return to shareholders, profitable and sustainable growth etc.), as they were related to a business perspective only without links to ESG matters or ESRS topics;
• the upstream and downstream value chain was integrated with a broader perspective, involving direct and indirect relationships (including potential scenarios arising from industry steps located beyond tier 1);
• the definition of IROs and the scoring methodology introduce the mandatory consideration of a "long-term" perspective (> 5 years);
• the scoring methodology used for all IROs was conducted through a "gross" assessment, which differs from pre-existing "net" scores in the Group Risk Map and previous ESG risk maps;
• the scoring criteria used for the impact assessment were modified compared to the previous Group ESG risk mapping in order to match the regulatory framework.

Relationships with control procedures, risk management and overall management processes

The various owners of the Group's critical risks and contributors to other Group risks relevant to the double materiality assessment were also interviewed as part of the identification of the relevant IROs.

In terms of methodology, the scales used to evaluate the financial effects of sustainability risks were identical to those of the Group risk map and based on qualitative analysis, similar to the Group risk management methodology. The likelihood criteria were also similar to the one used for the different risk mappings within Capgemini. The final materiality of each risk and opportunity was assessed in line with the level of risk appetite used for the Group risk mapping.

The Group also leveraged the double materiality assessment and stakeholders' consultation conducted as part of the materiality assessment when updating its specific risk map under the French law on Duty of Care, ensuring alignment on the identification and assessment of impacts.

The final results of the double materiality assessment were presented to the Compliance Committee, validated by the Chief Executive Officer and members of the Executive Committee in charge of relevant risks, opportunities and impacts, and presented to the Audit and Risk Committee of the Board of Directors of Capgemini SE at its meeting on October 22, 2024.

Transition plan for climate change mitigation

Scope of the transition plan

Capgemini's transition plan covers the entire Capgemini Group on a consolidated basis, consistent with the scope of the financial statements. The plan addresses emissions across:

• Own operations: All owned and leased offices and data centers globally
• Upstream value chain: Business travel, employee commuting, working from home, and all purchasing categories (notably IT services, hardware, and facility management)
• Geographic coverage: Global operations across 38 countries certified under ISO 14001, covering over 340,000 employees (98% of the Group based on headcount)
• Value chain segments: The plan covers Scope 1, 2, and Scope 3 emissions including:
  • Scope 1 & 2: 14% of baseline emissions
  • Scope 3: 86% of baseline emissions, with purchased goods & services (27%), business travel (30%), and employee commuting (27%) as the largest sources

Target year(s) for net zero / carbon neutral

Net Zero Target: 2040

Interim carbon neutral targets:

• Carbon neutral for own operations no later than 2025
• Carbon neutral across supply chain by 2030

GHG emission reduction targets

Baseline year: 2019 (1.13 million tons CO2e total)

Long-term target (2040):

• 90% absolute reduction across all Scope 1, 2, and 3 emissions
• Final target: ~113,000 tons CO2e (reduction of 1.02 million tonnes)

Near-term targets (2030) vs 2019 baseline:

Supporting targets:

• 100% renewable electricity by 2025
• 100% electric vehicle fleet by 2030

2024 Performance vs 2019 baseline:

Alignment with 1.5°C / SBTi validation status

SBTi Validation: Yes - validated in 2022

• Targets validated by Science Based Targets initiative (SBTi) as aligned with Corporate Net-Zero Standard
• Alignment with 1.5°C trajectory and Paris Agreement goals
• Near-term 2030 targets cover 98% of Scope 1, 2, and 3 GHG emissions
• Long-term 2040 targets cover 100% of all reported Scope 1, 2, and 3 GHG emissions
• Capgemini was "one of the first companies to have its net zero targets validated by the SBTi" in 2022
• Climate scenario used: IPCC SSP1 – RCP1.9/2.6 (limiting warming to 1.5°C by 2100)

Key decarbonization levers and pillars

Capgemini's 10-point sustainability roadmap includes:

1. Energy (Scope 1 & 2)

A. Energy Efficiency

• Energy Command Center (ECC) deployed: 29% reduction in energy consumption across Indian offices (25 GWh saved in 2024 vs 2019)
• ISO 50001 energy management certification in 33% of sites (27% of energy used)
• HVAC system upgrades and regular maintenance protocols
• Green Lease Framework updated in 2024 with sustainability criteria

B. Renewable Energy

• 98% renewable electricity achieved in 2024 (up from 28% in 2019)
• On-site solar: 14% of electricity in India from solar arrays
• Power Purchase Agreements and high-quality renewable certificates
• Battery Energy Storage Solutions deployed across India
• 100% renewable electricity in owned/leased data centers

C. Alternative Fuels

• Dual feeder electricity supply at Indian campuses
• Bio-Compressed Natural Gas deployment planned for India offices

D. F-Gas Reduction

• 17% reduction in fluorinated gas emissions since 2019
• HVAC upgrades to lower GWP refrigerants
• Enhanced maintenance and leak detection protocols

2. Sustainable IT

G. Sustainable IT initiatives

• Energy management software deployed on Group laptops
• Decommissioned 75,000+ IP phones since 2021
• 10% reduction in IT equipment needed in 2024 vs 2023
• Data center consolidation and cloud migration
• Application portfolio modernization and legacy retirement

E. Extending Product Lifetime

• Laptop refurbishment program: ~7,000 laptops refurbished by end-2024 (target: 10,000 by end-2025)
• Avoided ~1,000 tonnes CO2e through refurbishment
• Furniture cataloging and reuse programs

3. Travel & Smart Delivery

H. EV Fleet Transition

• 26% pure EVs, 71% including plug-in hybrids (2024)
• 2,600+ EV charge points installed globally
• Target: 100% EV fleet by 2030 (EV100 commitment)

I. Virtual Collaboration

• 1,200 meeting rooms upgraded with collaboration technology (2024)
• Hybrid working infrastructure investments
• Advanced AV technologies to reduce travel needs

L. Business Travel

• Updated Group Travel Policy with sustainability priorities
• Mandatory train travel for journeys <3 hours by rail
• Monthly carbon dashboards and travel tracking
• 51% reduction in business travel emissions vs 2019

J. Sustainable Mobility & WFH

• Country-specific mobility packages
• Public transport subsidies and cycling support
• Company bus service in India (transitioning to bio-CNG)
• Hybrid working policies maintaining reduced commuting
• 19% reduction in total commuting emissions vs 2019 (including WFH impact)

4. Supply Chain

F. Supplier Engagement

• Supply Chain ESG Pledge launched end-2023
• Requirements: disclose annual GHG emissions, set SBTi-validated targets, share transition plans
• CDP Supply Chain member
• 35% of spend covered by suppliers committed to ESG pledge
• Supplier workshops and collaboration events

K. Education

• Sustainability Campus launched 2022
• Three-level training: Awareness, Role-Specific, Expertise Development
• Partnerships with University of Exeter, Stanford, ESSEC
• Mandatory sustainability awareness training (2024)

CapEx / investment commitments

Committed investments 2025-2027: Approximately €16 million (Capex and Opex)

Major investment areas:

• India (majority of investment): Energy efficiency in buildings, renewable energy generation, transportation initiatives
• On-site solar solutions and Battery Energy Storage Solutions
• EV charging infrastructure (2,600+ charge points installed)
• Energy Command Center deployment
• Office upgrades and green lease implementations

EU Taxonomy alignment:

• 2024 Taxonomy-eligible CapEx: 53% of total consolidated CapEx (€405 million)
• 2024 Taxonomy-aligned CapEx: 7% of total consolidated CapEx (€51 million)
• Total consolidated CapEx 2024: €765 million

Locked-in emissions and stranded assets

Assessment: Locked-in emissions concept assessed as not relevant to Capgemini

Rationale:

• Majority of offices are leased on relatively short-term agreements
• Most data center infrastructure is third-party managed
• No significant GHG-intensive infrastructure owned
• No physical products manufactured
• Conclusion: "Locked-in emissions do not pose any significant risks to the achievement of our climate transition pathway"

Stranded assets: The assessment revealed "there are no assets or business activities that are incompatible, or need significant effort to be compatible, with a transition to a low carbon economy, given the nature of assets and business activities inherent to the Company"

Use of carbon credits / removals

Strategy: Dual approach of emissions reduction + carbon contribution

Commitment:

• Retire carbon credits on a ton-for-ton basis against residual operational emissions from 2025
• Include supply chain emissions from 2030
• Target: Scale to match operational emissions by 2025, include supply chain by 2030

2024 Performance:

• 314,312 carbon credits retired (up from 236,191 in 2023)
• Equates to 72% of remaining operational emissions
• 62,916 tCO2e from removal projects
• 251,396 tCO2e from avoidance/reduction projects

Quality standards:

• All credits from CCP-eligible programs (VCS, Gold Standard, CAR)
• Alignment with IC-VCM Core Carbon Principles
• Due diligence on additionality, permanence, quantification, co-benefits

Major contracted projects:

Additional commitments:

• First Movers Coalition: 50,000 tons or $25M carbon dioxide removals by 2030 (39,500 tons contracted to date)
• 1 trillion trees campaign (1t.org): 20 million trees by 2030

2024 Projects (11 total):

• Mexican forest management (IFM) projects
• Cookstove projects (Kenya, Ghana)
• Avoided deforestation (Brazilian Amazon)
• Agroforestry and afforestation (China, various)
• Mangrove restoration (Delta Blue Carbon)

Investment principles:

• Seek nature-based and climate tech solutions
• Focus on high-quality credits with co-benefits (SDGs, biodiversity, social)
• Balanced portfolio: development projects, existing projects, funds
• Support projects in Capgemini operating countries where possible
• Transparent, aligned with best practice
• Fair scale relative to emissions

Nature & Climate Solutions approach:

• Recognized need for carbon removal alongside decarbonization
• Portfolio includes both nature-based solutions and technology (DAC)
• Focus on durable, scalable solutions
• All projects deliver wider environmental and social co-benefits

Policies related to climate change mitigation and adaptation

Capgemini has disclosed several policies that relate to climate change mitigation and adaptation as part of its environmental sustainability framework.

Group Environmental Policy

• Scope: Global commitment covering all operations and employees
• Key content/principles:
  • Continual improvement of environmental performance against Group objectives and targets (science-based targets where feasible)
  • Working with clients to help them reduce their environmental impacts
  • Training employees on the impacts of their work on the environment
  • Regular consultation with key stakeholders on environmental issues
  • Ensuring environmental program is responsive to stakeholder feedback
• Governance: Ultimate accountability for implementation sits with the Group CEO. Multiple stakeholders and committees are considered in formulation and setting, particularly representatives from key internal functions (Real Estate, Procurement, Group IT, HR and Sustainability) as well as Country Sustainability leads for larger entities. Significant decisions go to the CEO for final approval.
• Public availability: Published on the company website for external stakeholders and made available internally on noticeboards
• Monitoring: The environmental program is monitored through the Net Zero Board, which provides executive level governance and is responsible for monitoring climate risks and reviewing, debating, and approving the climate transition plan, as well as other sustainability plans, policies and practices. Underpinned by two key management systems: global Environmental Management System and carbon accounting system.

Sub-policies supporting the Group Environmental Policy

The Group Environmental Policy is supported by targeted sub-policies and strategies specific to each element of the company's 10-point plan:

1. Energy Policy

• Scope: All sites from which Capgemini operates
• Key content/principles:
  • Ensuring buildings are the most sustainable
  • Operating with optimum efficiency
  • Rapidly transitioning to 100% renewable electricity by 2025
  • Supporting reducing energy consumption where practical and cost-effective whilst maintaining a comfortable and productive working environment
• Implementation: Covers ISO 50001 across seven countries and commitment to RE100. Buildings meet LEED, IGBC and BREEAM certifications.
• Future strategy: Prioritizes achieving highest sustainability standards for buildings, optimizing operational efficiency, and completing transition to 100% renewable electricity

2. Sustainable IT Policy

• Scope: Covers Scope 1, 2 and 3 emissions across operations and value chain
• Key content/principles: Sustainable IT transformation roadmap focusing on four key areas:
  • Reducing IT energy consumption and use-phase emissions from IT equipment
  • Reducing embedded carbon footprint of purchased IT equipment and services, and progressively adopting circularity practices
  • Investing in sustainable IT tools and talent for monitoring, governance, and reduction of footprint
  • Enabling enterprise-wide digital collaboration
• Specific commitments:
  • Cloud-first policy for building and operating IT solutions and services
  • Internal policy ensuring AI is not deployed without qualified use cases, with review and approval by Group IT management
  • Setting up dedicated GenAI Board to approve use cases
  • Mandatory employee training on Generative AI, including sustainable and responsible use
  • Engagement with leading hyper-scaler providers that are leaders in sustainability practices

3. Travel & Smart Delivery Policy

• Scope: Global business with over 340,000 people across more than 50 countries
• Key content/principles: Three key parts:
  • Travel policy with clear sustainability guidelines and requirements
  • Requirement that employees take train instead of plane for all journeys reachable by rail in less than three hours
  • Encourages rail travel for journeys of four hours or less
• Governance: Annual travel targets cascaded to each country by the Net Zero Board. Progress monitored monthly through carbon dashboards.
• Implementation: New set of travel dashboards across global sustainability network enabling better tracking of travel emissions and granular analysis. Enhanced best practice guidelines for Group events, including policies on travel modes.
• Future actions: Publishing comprehensive guidance to support decarbonization of annual events. Enhancing management information dashboards and carbon accounting processes. Assessing viability of leveraging sustainable aviation fuel (SAF).

4. Supply Chain Policy / Supply Chain ESG Pledge

• Scope: Supply chain operations, particularly addressing purchased goods and services emissions (41% of carbon emissions in 2024)
• Key content/principles: Launched at end of 2023 to strengthen supplier engagement and support achievement of carbon reduction goals. Requires suppliers to:
  • Disclose annual GHG emissions
  • Set science-based targets validated by SBTi
  • Share climate transition and low-carbon product strategies
• Links to international standards: Member of CDP supply chain program. Recognized by CDP and earned spot on 2023 Supplier Engagement Leaderboard.
• Monitoring: Throughout 2024, fostered collaboration through supplier events and leadership discussions. Actively supports suppliers in calculating emissions and building climate change capabilities. 184 suppliers responded to CDP request in 2024, with 49% having set science-based targets and 56% having a climate transition plan aligned with 1.5°C.
• Future actions: Continue to develop systems capabilities to analyze carbon data. Develop organizational capability by deepening understanding of carbon calculation methodologies. Increase weighting of environmental assessment criteria within RFP processes with suppliers.

Climate Transition Plan

• Scope: Entire value chain (Scope 1, 2, and 3 emissions)
• Key content/principles:
  • Commitment to become net zero by 2040
  • Target to reduce total Scope 1, 2, and 3 greenhouse gas emissions by 90% by 2040 compared to 2019 baseline
  • Structured around several key phases: 2021-2024 (first phase) and 2025-2028 (next phase)
  • Developed with reference to framework by United Kingdom Transition Plan Taskforce (TPT)
• Links to international standards: Aligned with Paris Agreement and global efforts to limit global temperature rise to 1.5°C. Puts company on trajectory in line with 2030 science-based targets.
• Governance: Net Zero Board provides executive level governance with responsibility for monitoring climate risks and reviewing, debating, and approving the climate transition plan.
• Monitoring: Progress tracked through two key management systems: global Environmental Management System and carbon accounting system. Regular monitoring of progress against targets with intention to iterate plan based on lessons learned.

Additional Policy Commitments

• First Movers Coalition for carbon removal: Commitment to contract at least 50,000 tons or $25m of durable and scalable carbon dioxide removals by end of 2030 (joined in 2023)
• EV100 commitment: Transitioning entire 12,000-vehicle fleet to hybrid and electric vehicles by 2030
• RE100 commitment: Transition to 100% renewable electricity by 2025

Links to International Standards and Frameworks

Capgemini's environmental and climate policies align with:

• Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS)
• Paris Agreement
• Science Based Targets initiative (SBTi)
• UN Global Compact (UNGC)
• Taskforce on Climate-related Financial Disclosures (TCFD)
• Greenhouse Gas Protocol Corporate Reporting and Accounting Standard
• ISO certifications: ISO 9001:2015, ISO/IEC 20000-1, ISO 27001:2022, ISO 14001 (Environmental Management Systems), ISO 45001, ISO 50001 (Energy Management Systems)
• CDP Supply Chain Program
• EV100
• RE100
• First Movers Coalition

Actions and resources in relation to climate change policies

Capgemini's environmental strategy is delivered through a 10-point sustainability roadmap addressing decarbonization across Scopes 1, 2, and 3, nature-based solutions, and global leadership.

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1. Decarbonizing Own Operations (Scope 1 & 2 emissions, Scope 3 energy emissions)

A – Energy Efficiency

Action: Transition to renewable electricity and deployment of energy efficiency measures

• Scope: Own operations
• Time horizon: Ongoing; 100% renewable electricity target by 2025; 2040 Scope 1 and 2 net zero target already exceeded (93% reduction vs. 2019)
• Outcomes achieved (2024):
  • 98% of electricity from renewable sources
  • 42% reduction in total energy consumption since 2019
  • 137,380 tCO₂e reduction since 2019 from renewable electricity transition
  • 32 countries now using 100% renewable electricity

Sub-action: Global Energy Command Center (ECC)

• Scope: Own operations (offices and campuses)
• Time horizon: Launched 2022; ongoing expansion
• Resources: Partnership with Schneider Electric; technology investment in digitization and asset monitoring
• Outcomes:
  • 29% reduction in energy consumption across India campuses
  • 25 GWh electricity saved in 2024 vs. 2019 in India
  • Expanded from 6 buildings and 8 campuses (2022) to 23 campuses and 66+ buildings (2024) in India
  • Rollout planned to France, Europe, LatAm, Americas, and APAC by 2025
  • ECC monitors indoor air quality, energy and water intensity, performance of critical assets, renewable electricity generation

Sub-action: ISO 50001 energy management certification deployment

• Scope: Own operations
• Outcomes: Facilitates identification and prioritization of energy conservation measures per site

Sub-action: Green lease framework

• Scope: Own operations (office buildings)
• Time horizon: Ongoing (deployed for several years)
• Outcomes: Externally recognized by Green Lease Leaders program; applies criteria including renewable energy, energy efficiency, EV charging points, proximity to public transport
• Resources: Global real estate team; collaboration with landlords

Sub-action: On-site solar generation

• Scope: Own operations
• Outcomes (2024): Over 14,000 MWh generated by on-site solar PV, accounting for 14% of Capgemini India's total electricity consumption

Sub-action: Battery Energy Storage Solution (BESS)

• Scope: Own operations (India campuses)
• Resources: 2.5 MWh capacity in Noida campus; 3.5 MWh capacity in Mumbai campus
• Outcomes (2024):
  • 525 MWh of excess solar energy stored and used, saving 376 tCO₂e
  • 1,417 MWh stored during non-peak hours for use during peak hours
  • Over €27,000 saved; reduced grid pressure

Sub-action: Automated energy data collection and validation tool

• Scope: Own operations globally
• Time horizon: Implementation in progress; operational by 2025
• Coverage: Offices in France, Europe, LatAm, Americas, APAC; India already fully integrated

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B – Alternative Fuels

Action: Transition away from natural gas, diesel, and LPG

• Scope: Own operations (heating, back-up generation, cooking)
• Outcomes (2024): 58% reduction in combined natural gas, LPG, and diesel emissions since 2019
• Focus: Upgrading to advanced HVAC systems using refrigerants with lower Global Warming Potential (GWP) than conventional F-gas

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2. Sustainable IT

Action: Reducing IT energy consumption and embedded carbon footprint

• Scope: Scope 1, 2, and 3 emissions
• Time horizon: Ongoing
• Outcomes (2024):
  • Refurbished around 7,000 laptops, reducing embedded carbon and raw material extraction
  • 10% reduction in IT equipment (servers, networking, communication, laptops, phones, endpoints) vs. 2023 through decommissioning
• Resources: Sustainable IT training programs for employees; optimized configuration management

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3. Travel and Smart Delivery

Action: Reduce business travel emissions and transition to electric vehicle fleet

• Scope: Scope 3 (business travel, employee commuting)
• Time horizon: 100% electric vehicle fleet by 2030
• Outcomes (2024):
  • Business travel emissions decreased by 51% compared to 2019
  • 26% of fleet now fully electric; 71% including plug-in hybrids
  • Over 2,600 EV charge points installed across the Group
• Resources: Enhanced travel dashboards offering detailed emissions and travel pattern insights; remote work enablement; sustainable mobility support options

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4. Supply Chain

Action: Empower suppliers on net-zero journeys

• Scope: Upstream value chain (Scope 3)
• Time horizon: Near-term and ongoing
• Focus: High-emission categories (IT & Telecommunications, Real Estate, Facility Management)
• Resources: Actionable reduction strategies; sustainability integrated into procurement decisions

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5. Decarbonizing Scope 3 Emissions

E – Extending Product Lifetime

Action: Focus on extending lifetime of purchased equipment

• Scope: Scope 3 (purchased goods)
• Note: Majority of purchases relate to services rather than physical products

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6. Nature & Climate Solutions

Action: Investment in nature-based carbon credit portfolio

• Scope: Outside value chain (carbon removal and avoidance)
• Time horizon: Retire credits equivalent to operational emissions by 2025; add supply chain by 2030; Net Zero by 2040
• Resources (2024): 314,312 carbon credits retired (up from 236,191 in 2023)
  • 62,916 tCO₂e removal credits
  • 251,396 tCO₂e avoidance/reduction credits
• Partnerships: Projects across improved forestry management (IFM), cookstoves, avoided deforestation, afforestation, grassland, mangroves
• Standards: Climate Action Reserve (CAR), Gold Standard (GS), Verra (VCS, CCB)

Sub-action: Direct Air Capture (DAC) investment

• Scope: Carbon removal outside value chain
• Resources: Long-term offtake agreement with Climeworks to permanently remove 13,000 tons of CO₂
• Technology: Direct air capture with permanent underground storage
• Locations: Climeworks operates plants in Iceland; projects announced in USA (Project Cypress), Canada, Norway, Kenya

Sub-action: Tree planting initiatives

• Scope: Nature-based solutions
• Time horizon: 20 million trees by 2030
• Outcomes (2024): Around 17 million trees planted
• Resources: Partnership with Ecologi (B-Corp climate action platform); Capgemini Forest reached over 1 million trees planted across 16 countries
• Link to policy: Commitment to 1t.org (World Economic Forum 1 trillion trees campaign)

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7. Collective Action: Employee Environmental Training

Action: Sustainability Campus employee training

• Scope: Own workforce (all employees globally)
• Time horizon: Launched 2022; mandatory awareness module from September 2024
• Resources: Sustainability Campus platform; translations into 8 languages; specialized training for specific roles and industries
• Outcomes (2024):
  • Mandatory Sustainability awareness module: average rating 4.6/5
  • 19 new modules introduced (Sustainable Product Design, Wind, Solar, Hydrogen, Food Waste, etc.)
  • 5 modules updated
  • Green Talk podcasts: over 7,000 listens
  • Awards: Brandon Hall Gold for Best Unique/Innovative L&D Program; Gold for Best Use of Blended Learning; Bronze for Best Learning Strategy

Sub-action: Green IT Essentials Module

• Scope: IT roles (own workforce)
• Focus: Impact of digital technology on the environment

Sub-action: Energy efficiency campaigns

• Scope: Own workforce (multiple countries)
• Resources: Group Sustainability and CRES teams
• Focus: Office and home energy efficiency

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8. Global Leadership

Action: Form global partnerships and vocal support for decarbonization

• Scope: Advocacy and collective action
• Time horizon: Ongoing commitments
• Partnerships and memberships:
  • LEAF Coalition (Lowering Emissions by Accelerating Forest finance): public-private partnership to halt tropical deforestation by 2030
  • First Movers Coalition on Carbon Removal: Contract at least 50,000 tons or $25m of durable carbon dioxide removals by 2030
  • Race to Zero: Business Ambition for 1.5°C (signatory since 2020)
  • RE100: 100% renewable electricity by 2025 (signatory since 2020)
  • EV100: Electric fleet by 2030; support for customer EV infrastructure (signatory since 2021)
  • UNICEF Green Rising: 3-year partnership (2023) to mobilize 10 million young people for climate action
  • 1t.org (1 trillion trees campaign): 20 million trees by 2030 (joined 2021)
  • European Green Digital Coalition (joined 2022)
  • UN Global Compact Communication on Progress Early Adopters Program (joined 2022)
  • European Commission Sustainable Consumption Pledge (joined 2023)
  • TCFD (Task Force on Climate-related Financial Disclosures, signatory since 2020)
  • Science Based Targets initiative (SBTi): Targets validated 2022 as aligned with Corporate Net Zero Standard and 1.5°C trajectory (first targets set 2016)
  • World Economic Forum Alliance of CEO Climate Leaders (joined 2021)
  • UN Global Compact Caring for Climate (signatory since inception 2007)

Recognitions (2024):

• CDP A-List
• Ecovadis Platinum (top 1%; 100% Environment score)
• DJSI Europe Index constituent (79/100 vs. industry average 49/100)
• CDP Supplier Engagement Leader
• Financial Times Europe's Climate Leaders 2024 (top 10)
• TIME World's Most Sustainable Companies (ranked 4th in sector)

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Summary of Key Quantified Resources

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Linkage to Policies and Targets

• 2040 Net Zero target: All actions contribute to Scope 1, 2, and 3 emission reductions
• RE100 commitment: 100% renewable electricity by 2025 (98% achieved in 2024)
• EV100 commitment: 100% electric fleet by 2030 (26% fully electric in 2024)
• SBTi-validated targets: 1.5°C trajectory and Corporate Net Zero Standard
• Carbon credit strategy: Retire credits equivalent to operational emissions by 2025; add supply chain by 2030

Targets related to climate change mitigation and adaptation

Capgemini has set comprehensive climate targets validated by the Science Based Targets initiative (SBTi) aligned to the Corporate Net-Zero Standard.

Headline Net Zero Target

Overall commitment: Become net zero by 2040, with a 90% absolute reduction across Scope 1, 2 and 3 emissions by 2040 (compared to 2019 baseline).

Science Based Targets initiative (SBTi) validated targets

Supporting Targets

Additional Targets

• Carbon contribution program: Retire carbon credits equivalent to operational emissions by 2025 and supply chain emissions by 2030
• Tree planting: Plant 20 million trees by 2030 (17 million planted by end of 2024) as part of WEF 1t.org commitment
• Total waste per employee: Reduce by 80% by 2030 (baseline year 2019)
• Waste to landfill: Reduce to zero and below 5% incineration by 2030
• Durable carbon removal: Contract at least 50,000 tons or $25m by 2030 (39,500 tons contracted to date) as part of First Movers Coalition

Target Coverage

• Near-term 2030 targets cover 100% of Scope 1 and 2 emissions and 98% of Scope 3 emissions
• Long-term 2040 targets cover 100% of all reported Scope 1, 2 and 3 GHG emissions

Validation and Framework

• All climate targets validated by Science Based Targets initiative (SBTi) as aligned with Corporate Net-Zero Standard
• Targets aligned to limit global temperature rise to 1.5°C
• Capgemini was one of the first companies in its sector to have net zero targets validated by SBTi (validated in 2022)

Energy consumption and mix

Total energy consumption and disaggregation by source (2024, 2023, 2019)

Scope and methodology: Energy consumption data covers Capgemini's global operations across 42 countries representing 99.8% of the Group's operations by headcount. Data is measured in accordance with the GHG Protocol Corporate Standard and aggregated through the Group's centralized carbon accounting system. Missing data for 0.2% of operations is estimated using extrapolation methods validated by the carbon accounting team.

Renewable electricity share: 98.0% of total electricity from renewable sources (2024); 95.9% (2023); 28.3% (2019).

Renewable energy share: 84.0% of total energy from renewable sources (2024); 82.1% (2023); 24.5% (2019).

Notes on categorisation:

• Purchased electricity from fossil sources is based on purchases of electricity on standard utility contracts with no specified breakdown and no energy attribute certificates purchased.
• Purchased electricity from renewable sources includes all renewable electricity purchased through power purchase agreements, renewable electricity tariffs or through energy attribute certificates.
• Consumption of self-generated renewable electricity refers to electricity generated at Capgemini sites (from solar photovoltaic panels) and consumed directly at those sites.

Energy production from renewable sources (section incomplete in excerpt)

The report indicates an 'Energy production from renewable and non-renewable sources' table header but the data table was truncated in the provided excerpts.

Gross Scopes 1, 2, 3 and Total GHG emissions

Overview

Capgemini discloses GHG emissions across Scopes 1, 2, and 3 in accordance with its climate commitments. The Group has committed to reducing operational emissions (Scopes 1 and 2) by 80% by 2030 and by 90% by 2040 (vs. 2019 baseline), and to reducing Scope 3 emissions by 50% by 2030 and 90% by 2040 (vs. 2019 baseline).

Scope 1: Direct GHG emissions

Scope 1 emissions arise from direct combustion of fuels in owned or controlled sources.

Note: The Group does not separately disclose sub-breakdown of Scope 1 into stationary combustion, mobile combustion, process emissions, or fugitive emissions.

Scope 2: Indirect GHG emissions from purchased energy

Scope 2 emissions relate to purchased electricity, heat, steam, and cooling.

Note: The report presents Scopes 1 and 2 as a combined figure. The Group transitioned to 98% renewable electricity in 2024, with a 100% target by 2025.

Scope 3: Indirect GHG emissions from value chain

Scope 3 emissions cover upstream and downstream value chain activities.

Scope 3 category breakdown

Note: The report does not provide a full breakdown by all 15 GHG Protocol Scope 3 categories. Categories explicitly mentioned are 3.1 (Purchased goods and services), 3.6 (Business travel), and 3.7 (Employee commuting). The report notes that the Group has found reducing absolute Scope 3.1 emissions challenging in the context of significant business growth since 2019, though a 14% reduction was achieved in 2024 vs. 2023.

The report also references indirect energy consumption and GHG emissions related to external data centers, cloud services, and AI development as material impacts, but does not provide quantified emissions data for these categories (likely part of Cat. 3.1).

Total GHG emissions

GHG intensity

The Group does not disclose a revenue-based intensity metric (tCO2e/€M revenue) in the excerpts provided. Per-employee intensity metrics are provided for business travel and commuting (see Scope 3 table above).

Regulated emissions (e.g. EU ETS)

Not disclosed.

Biogenic CO2 emissions

Not disclosed separately from Scope 1.

Methodology and scope notes

• The Group's emissions accounting covers own operations (Scopes 1 and 2) and upstream/downstream value chain (Scope 3).
• The baseline year is 2019 for all reduction targets.
• The Group committed to carbon neutrality for own operations by 2025 and across the supply chain by 2030, and to becoming a net zero business by 2040.
• Operational emissions (Scopes 1+2) exclude employee commuting. A separate metric tracks commuting emissions per employee.
• The Group has transitioned to 98% renewable electricity in 2024 (100% target by 2025).
• Business travel and commuting targets are set per employee to account for headcount growth.
• The report notes that Scope 3.1 (Purchased goods and services) is challenging to reduce in absolute terms due to business growth, but progress was made in 2024 (14% reduction vs. 2023).
• The report identifies indirect energy consumption related to external data centers, cloud services, and AI as a material impact under climate change mitigation, but does not quantify these emissions separately.
• The Group reports emissions related to its Indian operations, which house approximately 50% of total headcount and are subject to specific business continuity and resilience measures.

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

Materiality Assessment

The 2024 Climate Change Risk Assessment confirmed no material risks arising from climate change surpass the threshold for materiality defined through the Double Materiality Assessment.

Climate Risk and Opportunity Assessment Process

In 2024, Capgemini launched a refreshed climate risk and opportunity assessment process with key stakeholders across the Group. The company has been assessing climate risks for many years but has significantly evolved this process in recent years, specifically with a focus on:

• Improving how the company quantifies potential impacts
• Making more extensive use of climate scenario analysis
• Improving quantification of the financial impacts of climate risks specific to Capgemini

Time Horizons

For the purposes of the risk assessment, the following time horizons have been defined:

Methodology for Quantification

Scenario Analysis

In both physical and transition scenario analysis, the scenarios selected have been used to explore the 'most extreme' climate risk scenarios and improve understanding of the full range of risks and opportunities facing the business.

Physical Risk Analysis:

• Physical hazard exposure scenarios leveraged to understand the maximum physical hazard exposure for the global asset portfolio
• Assessment of revenue at risk and asset value at risk, considering the potential impact of physical hazards on global sales and delivery teams
• Scenarios based on IPCC's RCP & SSP

Transition Risk Analysis:

• Extreme transition scenario aligned to a global temperature increase of 1.5 °C

Desktop Research and Third-Party Analysis

Capgemini undertook a desktop research exercise to define the climate scenarios most relevant for the business, selecting appropriate scenarios based on the lifecycle and characteristics of Capgemini assets and planning cycles. The company onboarded a third party to enable:

• Geo-spatial analysis of the hazard exposure of assets (office sites and IT infrastructure), analyzed to rooftop level to inform understanding of the level of physical risk exposure from key physical hazards
• Client and sector transition exposure analysis across key revenue generating sectors, to inform an understanding of potential revenue at risk as a result of failure to achieve a low carbon transition

Scope of Analysis

The analysis considered the following entities across the value stream:

Upstream (supply chain, suppliers, strategic partners and investors):

• Focused on a subsection of the supplier network, defining most critical suppliers which uphold critical business operations
• Investor priorities

Direct Operations (business strategy and people):

• Critical infrastructure including office locations and data centers, and key project locations (inclusive owned, leased and third-party managed)
• People: when working from home, from the office, and from client sites
• Business strategy and corporate objectives

Downstream (clients and end users):

• Revenue generating client activity and ability to deliver across business lines and market units
• Key clients defined as most strategic clients, a sub sector of the client base which account for significant revenue generation
• Non-revenue generating client activity and ability to deliver across key delivery centers

Policies related to own workforce

Capgemini discloses multiple policies applicable to its own workforce, embedded within broader corporate governance and human rights frameworks. The following policies are explicitly named and described:

Code of Business Ethics

Scope: All employees group-wide

Key content:

• Introduces Capgemini's Values and ethical principles
• Covers five key areas including 'safe and inclusive work environment' and 'Speaking up culture'
• Sets overall commitment to equality, diversity and inclusion
• Provides for a harassment-free environment with possible disciplinary sanctions
• Covers human rights, harassment-free workplaces, conflict of interest management, and encourages a culture of speaking up and non-retaliation

Public availability: Available to all employees through the intranet and to stakeholders on www.capgemini.com

International standards alignment: UN Global Compact principles (signatory since 2004), Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work

Governance and oversight: The Chief Ethics Officer, a Group Executive Committee member, is the Head of Ethics and reports directly to the Chief Executive Officer. Ultimate accountability lies with the CEO. The Group Head of Ethics and Chief Ethics Officer report annually to the Ethics and Governance Committee of the Capgemini SE Board of Directors.

Monitoring: Mandatory annual e-learning (Ethics@Capgemini) assigned to all employees, with completion tracked. Target: maintain minimum 90% completion rate annually (2024-2030). 2024 result: 94.0% completion rate.

Human Rights Policy

Scope: Full value chain including all Capgemini activities: permanent headcount, temporary agency staff, freelancers, independent workers, employees of subcontractors, trainees, supply chain, client interactions, and local communities where Capgemini operates

Key content:

• Sets out ten human rights commitments:
  1. Equal opportunity and fair treatment
  2. Freedom of expression
  3. Freedom of association and collective bargaining
  4. Harassment-free work
  5. Safe and healthy workplace
  6. Protection against child labor, forced labor, and human trafficking
  7. Data privacy
  8. Right to education
  9. Digital inclusion
  10. Protecting human rights through ethical approach on AI solutions
• Considers vulnerability of certain groups (migrant workers, women, indigenous people)

Public availability: Published on Capgemini intranet (accessible by all employees) and external website www.capgemini.com. Published December 2021; updated 2024.

International standards alignment: Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights (UNGPs), ILO Declaration on Fundamental Principles and Rights at Work with core Conventions, UN Global Compact

Governance and oversight: Ultimate accountability lies with the Chief Executive Officer. Implementation responsibility lies with operational and functional leaders across the Group, supported by implementation program driven by Chief Ethics Officer and country Ethics & Compliance Officers. Annual reporting to Ethics and Governance Committee of Capgemini SE Board of Directors.

Monitoring: Country human rights assessment questionnaire developed in 2022 to assess exposure to human rights impacts per country. Pilot assessment conducted in India (50% of workforce). Deployment ongoing to other countries following risk-based approach. Integrated into Ethics@Capgemini mandatory e-learning.

Diversity and Inclusion Policy

Scope: All Capgemini employees; local policies may exist reflecting local requirements while aligned with Group guidelines. Strongly recommended for freelancers and independent contractors.

Key content:

• Defines diversity as encompassing all personal attributes including sex, gender identity, age, race/ethnicity, nationality, sexual orientation, ability status, social origin, cultural identity, faiths, working methods, skills, and experience
• Four main ambitions:
  1. Be a destination company where all talents can thrive
  2. Offer an inclusive workplace with equal opportunities for all
  3. Build an inclusive and engaging culture
  4. Support local communities and broader society
• Commitment to equal opportunity and fair treatment irrespective of social, cultural, ethnic or national origins, religious or other beliefs, caste, gender identity/expression, marital status, pregnancy status, sexual orientation, disability, age, skin color, race, parental status, political ideology, military/veteran status, trade union activity, etc.

Public availability: Available through internal and external channels, distributed to all employees and executives as well as to clients, partners and suppliers upon request. Published on Capgemini external website and investor website.

International standards alignment: Women's Empowerment Principles (signatory since 2011, UN Women and UN Global Compact), Valuable 500 (joined 2020), ILO Global Business and Disability Network (member of Steering committee), UN Standard of Conduct for Business tackling LGBT+ discrimination (CEO signatory 2022), WEF Partnering for Racial Justice in Business (founding member), UN SDG 16

Governance and oversight: Head of Global Sustainability Services & Corporate Responsibility (Group Executive Board member) is most senior leader accountable for implementation. Results monitored regularly by Group Executive Committee and reported annually to Strategy and CSR Committee of Capgemini SE Board of Directors and to the Board of Directors.

Monitoring: Active monitoring through recruitment mix, promotion rates, and equal pay for equal work. Employee Networks Groups include @women@capgemini, OUTfront, CAPability and Neuroability, and CulturAll.

Employee Relations Policy

Scope: Group-wide, with local management responsible for implementation given country specificities

Key content:

• Articulated around social foundations including:
  • Providing equal opportunities and fair treatment
  • Maintaining a harassment-free environment
  • Ensuring freedom of association and collective bargaining
  • Promoting effective policies to improve working conditions
  • Improving relationships with internal and external labor stakeholders
• Supports collective dialogue and negotiations with trade unions, local works councils, International Works Council and other representative associations

Governance and oversight:

• Group Management (Group HR & Group Employee Relations Team): provides guidance and advice to local management, monitors policy application, provides implementation assistance, fosters skills development
• Local management (HR Directors, local Employee Relations specialists, Managing Directors): responsible for implementation, managing local employee relations, reporting serious difficulties to Group, sharing local practices

Monitoring: International Works Council established in 2001 facilitates dialogue between employee representatives and Group Management across all countries.

Health & Safety Policy

Scope: All Capgemini employees and contractors across all geographies where the Group operates. Applies whether working on Capgemini sites or client sites.

Key content:

• Defines minimum expected standard at Group level for Health & Safety
• Proactive, preventative, and inclusive approach to protecting welfare of people while at work
• Commitments to ensure a safe workplace
• Reiterates commitment to maintaining work environment free of harassment and prohibits retaliation
• Covers physical and mental health protection

Public availability: Presented to Executive Human Resources Committee September 2024, International Works Council Bureau October 2024, IWC plenary session November 2024. Published on external website December 2024.

International standards alignment: Commitment to align with Human Rights Policy commitments including safe and healthy workplace. ISO 45001 certification in Germany, Netherlands, Italy, and India (59% of global headcount covered).

Governance and oversight:

• Group Management (Group HR & Group Health and Safety Team) with support of Group Health and Safety Committee: provides guidance and advice to local management, monitors policy application, provides implementation assistance
• Local management (country HR leaders, local H&S specialists, chairmen of country boards/Managing Directors): CHRO/HRD responsible for implementation and management of local H&S topics
• Countries required to implement within maximum two years from publication date

Monitoring: Centralized data collection for new Health and Safety metrics established in 2024. Local works councils or local Health and Safety committees informed December 2024, with implementation starting 2025.

SpeakUp Policy

Scope: All stakeholders – employees across the Group, clients, suppliers, and business partners

Key content:

• Web and phone-based ethics reporting, incident management and advisory tool
• Voluntary, confidential, allows anonymity
• Hosted by independent service provider, managed by Group Ethics Office, supported by global network of General Counsels, Ethics & Compliance Officers and SpeakUp investigators
• Enables reporting of unethical behaviors or requests for advice/guidance
• Commitment to listen to employees, be fair when investigating, show organizational justice, maintain confidentiality, protect reporters from retaliation

Public availability: Available to all employees through intranet and to all stakeholders

Governance and oversight: Managed by Group Ethics Office, supported by network of General Counsels, Ethics & Compliance Officers and SpeakUp investigators. All alerts investigated by Ethics Department and local officers.

Monitoring: Substantiated alerts result in appropriate sanctions. Statistics on alerts shared internally. 'Ethics Radio' podcast series discusses sanitized SpeakUp cases to strengthen speaking-up culture.

ESG Policy

Scope: Group-wide

Key content:

• Compiles sustainability ambitions and targets embedded in strategy and value creation model
• Covers environmental, social and governance commitments
• Includes targets for supplier commitment to ESG standards (80% of purchase amount by 2030)
• Includes target for Ethics@Capgemini e-learning completion (>90% annually 2024-2030)
• Includes target for Ethical Culture score (>80% of employees with score 7-10 out of 10)

Governance and oversight: Adopted in 2021 and updated in 2024, approved by Board of Directors of Capgemini SE. Based on double materiality assessment conducted in 2021 and updated in 2024 in consultation with internal and external stakeholders.

Monitoring: Reported in annual Sustainability Statement with specific metrics and targets tracked.

Blue Book

Scope: All Capgemini Group

Key content:

• Compiles all Capgemini Group policies and guidelines
• Brings together coherent range of commonly adopted principles, values, policies and processes
• Includes dedicated section on rewards, compensation and benefits
• Internal rules encompassing various employment aspects

Public availability: Available to all employees through intranet (not available on external website)

Compensation & Benefits Policy

Scope: Whole Group with progressive deployment; local adaptation in relation to legislation, cultures, tax systems, local market dynamics and business specificities

Key content:

• Total rewards philosophy to attract, retain and motivate employees
• Foundation for consistent people decisions aligned with core values and business/talent ambitions
• Five key objectives: attract talents, drive performance, retain value creators, drive appropriate behaviors, support skills & career evolution and favor mobility
• Four pillars:
  1. Market competitive reward
  2. Supporting employee engagement
  3. Optimizing ROI
  4. Supported by efficient processes

Governance and oversight: Compensation and Benefits team manages deployment and monitors implementation. Works with analytics team to develop reports leveraging Pulse survey data.

Monitoring: Compensation and Benefits handbook developed for HR community. Regular benchmarking to ensure market alignment. Monitored through internal tools and analytics.

Group Flexible Work Policy (Global Flex Work Policy)

Scope: Group-wide

Key content:

• Sets fundamentals of Capgemini hybrid model
• More remote working and flexibility in terms of working hours and work location
• Enables employees to balance work and personal life

Conflict of Interest Policy

Scope: All employees

Key content:

• Management of conflicts of interest
• Supported by specific tool 'Declare' rolled out across 43 countries in 2024 to cover ~93% of Group's workforce
• Continued rollout to remaining countries planned for 2025

Public availability: Available to all employees through intranet and on www.capgemini.com

Monitoring: Integrated into Ethics@Capgemini mandatory e-learning. Tool-based tracking through Declare platform.

Data Protection Policy

Scope: All employees

Key content:

• Addresses risks and negative impacts associated with data protection
• Privacy by design approach
• Three levels data protection controls program

Public availability: Available to all employees

International standards alignment: Binding Corporate Rules for cross-border data transfers

Monitoring: Continuous monitoring of new laws on data protection. ISO 27001 certification.

People Security and Safety General Policy

Scope: Group-wide to all Capgemini employees and contractors in all geographies where the Group operates

Key content:

• Ensures Capgemini helps employees when serious issues arise that could impact life and/or well-being
• Covers actions and advice for travelers and local employees
• Framework based on ISO 31030
• Includes Travel Security and Safety Management Policy and building safety requirements

Governance and oversight:

• People Security Head (reports to Group Security Head, who reports to Group General Secretary) defines and validates policy at Group level
• Network of Country Security Officers (CCSOs) required to promote and deploy policies locally and adapt to local laws
• Country boards supervise implementation
• Group Security Center operates 24/7 to implement policy requirements and provide assistance

Monitoring: Implementation monitored by Group Security. Mass notification tool deployed to reach employees and contractors in security emergencies.

Code of Ethics for AI

Scope: All AI solutions developed and delivered by Capgemini across different industries; entire lifecycle of AI systems from design to deployment; all employees

Key content:

• Seven ethical principles:
  1. AI with delimited impact
  2. Sustainable AI
  3. Fair AI
  4. Transparent and explainable AI
  5. Controllable AI
  6. Robust and safe AI
  7. AI respectful of privacy
• Human-centricity at core of AI solutions
• Respect for universal fundamental rights, UN Universal Declaration of Human Rights, UN Global Compact
• Build AI solutions that improve life for humans and do not exacerbate or create harm

Public availability: Available to employees and stakeholders

International standards alignment: UN Universal Declaration of Human Rights, UN Global Compact, EU AI Pact (signatory 2024)

Governance and oversight: Integrated into Human Rights Policy commitment on protecting human rights through ethical approach on AI solutions

Monitoring: Dedicated training on Code of Ethics for AI to be deployed in 2025 for all employees. Target: at least 80% completion annually (2025-2030).

Sustainable Procurement Policy

Scope: All purchasing activity across the Group

Key content:

• Human rights, Health and Safety, well-being and labor violations are non-negotiable requirements for suppliers
• Encourages working with suppliers to promote ESG challenges including diversity, equity and inclusion
• Non-negotiable commitments and proactive/differentiating practices
• Covers selecting suppliers with aligned ESG/CSR performance and ambitions

Governance and oversight: Head of Procurement responsible for ensuring commitment to Supplier Standards of Conduct

Monitoring: Global Purchasing System collecting data ensuring transparency from sourcing to payment. ESG rating database for suppliers.

Freelancers Group Policy

Scope: Engagement of freelancers and independent contractors

Key content:

• Provides framework for setting consistent rules regarding freelancer engagement

Additional policy frameworks mentioned:

• Anti-Corruption Policy: Zero tolerance for corruption, aligns with UN Global Compact 10th principle. Chief Compliance Officer (reports to Group General Secretary) oversees anti-corruption program. Annual reporting to Ethics and Governance Committee.

• Competition Laws Policy: Implemented under accountability of Group General Counsel (Group Executive Committee member)

• Export Control and Sanctions Program: Implemented under accountability of Group General Counsel

• Group Cybersecurity Policy: Addresses cybersecurity risks

• Environmental Policies: Separate environmental management policies

• Supplier Standards of Conduct: Requires suppliers to adhere to standards including human rights, updated 2024 to align with Human Rights Policy. Target: 80% of purchase amount with committed suppliers by 2030 (60% achieved in 2024).

Characteristics of the undertaking's employees

Total headcount and FTE

Capgemini reported a global headcount of over 340,000 employees as of December 31, 2024 (exact figure not disclosed in excerpts, but noted as having "over 340,000 employees worldwide").

Headcount by gender

As of December 31, 2024:

• Women: 39.7% of global headcount
• Men: 60.3% (calculated)

Gender distribution in leadership positions:

• Women in Executive Committee: 25.7% (in 2024)
• Women in Executive leadership positions: 29% (in 2024)
• Target for women in Executive leadership positions: 30% by 2025

Historical gender distribution in leadership:

Headcount by region

The document mentions that India accounts for approximately 50% of the Group's total headcount (around 170,000 employees based on global headcount estimate).

Regional presence mentioned includes:

• Europe (operations in UK, Benelux, Nordic countries, France, Poland, Portugal, Romania, etc.)
• North America (United States)
• Asia-Pacific (India, China, Japan, Australia)
• Latin America (Brazil, Guatemala)
• Middle East and Africa (Morocco, Tunisia)

Specific regional headcount breakdowns not disclosed in excerpts.

Headcount by contract type

Not disclosed in excerpts.

Headcount by employment type (full-time/part-time)

Not disclosed in excerpts.

Employee turnover

Not disclosed in excerpts.

New hires

Not disclosed in excerpts.

Employee training

Average completed learning hours per headcount (at year end, trained during reporting period):

Total training volume: 25.73 million hours of employee training (year not specified, appears to be cumulative or annual).

Employee share ownership

Approximately 8% of the capital is owned by employees.

Diversity policy

The Group has established diversity targets for management bodies:

• Progressive increase in female representation on Executive Committee
• Target of 30% women in Executive leadership positions by 2025
• Target of 35% women in leadership positions by 2030
• Specific annual objectives set for gender diversity in Vice-President community
• Focus on international representation: 60% of Executive Committee members (21 out of 35) are international as of December 31, 2024

Board composition

At December 31, 2024, the Board of Directors comprised:

• Total members: 13 (excluding Directors representing employees and employee shareholders in independence calculation)
• Independent Directors: 9 out of 11 eligible members (82%)
• Women Directors: 5 out of 13 (approximately 38%)
• Directors representing employees: 2
• Directors representing employee shareholders: 1

Characteristics of non-employees in the undertaking's own workforce

Number of non-employees in own workforce

Capgemini defines "non-employees" as individuals contracted through an intermediate company, delivering services for Capgemini on a Time & Material basis. This definition encompasses independent contractors, as well as some employees from small, medium and large companies.

All non-employees are managed through Capgemini's service provider management system called Vendor Management System (VMS).

Methodology

Data on non-employees is collected through a Group Procurement Power BI dashboard, updated by the Vendor Management System (VMS) which manages the relationship with Capgemini non-employees from end to end. The number of non-employees is then extracted and controlled. The reporting unit for non-employee figures is non-employee "Headcount" number, and the data is reported annually on a Y-1 basis.

Policies and management

In 2024, Capgemini worked on a new "Individual contractors" Group Policy that will be released in 2025. This policy will provide a framework for setting consistent rules regarding non-employee workers at Capgemini to ensure:

• The use of this workforce segment is compliant with applicable regulations and risk-mitigated
• All parties have clarity over their respective role and responsibilities
• A unique seamless experience for non-employee workers

The policy will cover various aspects of the non-employee lifecycle journey, including sourcing and staffing, contractualization rules, differentiation from permanent staff, ensuring ethical and compliance awareness, and training of Engagement Managers.

Monitoring and communication

Capgemini ensures reaching employees and contractors in case of security emergency through a new and more powerful mass notification tool. The company's SpeakUp alert mechanism is available to Capgemini employees, contractors and other stakeholders.

Collective bargaining coverage and social dialogue

Governance and framework

Capgemini published an Employee Relations Policy in November 2023, which forms the backbone of its approach to social dialogue. The policy emphasizes:

• Commitment to creating and maintaining constructive and respectful social dialogue
• Promoting ongoing, high-quality dialogue for the benefit of the Company and its employees
• Belief that business and growth go hand in hand with constructive and mature dialogue

The Human Rights Policy includes a dedicated commitment to ensuring freedom of association and collective bargaining. Capgemini respects employees' right to form and join a trade union, in accordance with national laws, and recognizes such organizations for the purpose of collective bargaining.

International Works Council (IWC)

The International Works Council was first created in 2001 and has one key objective: facilitating constructive dialogue between employees and management. The last IWC agreement was signed on April 23, 2021, with an amendment on May 18, 2022.

The IWC has a maximum of seventy members in total and 99% of the Capgemini Group is represented in the IWC (except in Europe with Serbia, Ukraine and Switzerland).

The IWC has four annual plenary meetings plus monthly Bureau meetings. In 2024, 6 plenary sessions and 12 Bureau meetings were held, covering topics including:

• Group Transformation Programs
• Business and HR updates
• Sustainability Services & Corporate Responsibility
• Diversity and Inclusion
• Policies (Health and Safety, Employee Relations, Travel)

Board representation

Since 2016, two Directors representing employees have been appointed to the Board of Directors:

• One Director designated by the most representative trade union in France
• One Director designated by the International Works Council from among its statutory members

A Director representing employee shareholders is also appointed when employees hold over 3% of share capital.

Country-level social dialogue

The Group operates under a global model with local adjustments to match local legislation, local maturity in diversity and inclusion, and cultural sensitivity. Examples of country-level actions include:

France: Health at Work agreement signed in June 2017 with an amendment in December 2019; working from home agreement; 2,500 employees have benefited from the Flexabroad framework.

Belgium: Negotiation of a single Works Council and single Health and Safety Committee; various collective agreements on work regulations, alcohol and drugs, and employment measures for employees over 45.

Italy: Multiple agreements signed with unions covering performance bonuses, industrial relations protocols, and video surveillance installations.

Brazil: 18 annual salary negotiations with 18 different unions; 2 additional agreements on working conditions; 6 profit-sharing agreements; 2 agreements on holiday flexibility; approximately 6% of employees are union members.

Spain: New trade union landscape after integration of Altran; working groups established with unions on employability and social fund.

India: Formal Works Committees operate as per statutory requirements covering 100% of employees; multiple preventive healthcare and insurance initiatives.

Metrics

Employees coverage by collective bargaining agreements

Collective bargaining information (EEA countries with >50 employees representing >10% total employees)

Targets

The Group target is to maintain at least 99% of employees represented by the International Works Council (IWC) (99% corresponding to the 2024 coverage rate). This target may be adjusted in case of significant changes in scope due to material acquisitions or divestitures.

Methodology notes

All Group countries are covered by the Employee Relations Policy and 99% of employees are covered by representation to the International Works Council. The percentage of employees covered by collective bargaining agreements and workplace representation are collected and consolidated by the Group HR Employee Relations Team. Only France discloses detailed percentages in application of the European Sustainability Reporting Standards disclosure thresholds, as the only country meeting the regulatory thresholds for detailed disclosure (>50 employees representing >10% of total employees in the EEA).

Diversity metrics

Gender split at top management

Board of Directors composition

At December 31, 2024:

• Total Directors: 14 (12 elected by shareholders + 2 employee representatives)
• Women: 5 out of 14 Directors
• Gender ratio: 45% women (excluding employee representatives per French law methodology)
• Independent Directors: 82%
• Average age: 59 years
• Average length of office: 5 years
• International representation: 43%

Age band distribution of total workforce

Coverage: 99.6% of total headcount for 2024.

Total workforce gender distribution

Gender distribution by function

Recruitment distribution by gender and age

Vice-President appointments (promotions & external hires)

Persons with disabilities

Note: Subject to legal restrictions on collection of data in certain jurisdictions.

Workforce seniority distribution (2024)

Nationalities

The Group employs people from more than 160 nationalities.

ESG targets

• 2025 target: 30% women in executive leadership positions
• 2030 target: 35% women in executive leadership positions
• 2030 target: Maintain at least 40% of women in total workforce
• Current achievement: 29% women in executive leadership positions (2024), 39.7% women in total workforce (2024)

Methodology notes

Gender and age distribution metrics are available monthly via People Insights Power BI, updated from the Global Data Hub. Data are controlled by Group HR Reporting Team and consolidated at year-end. Directors representing employees and employee shareholders are not included when calculating Board independence rates and gender diversity ratios under AFEP-MEDEF Code provisions.

Adequate wages

Benchmark Used: Capgemini has been working with the Fair Wage Organization since 2023. The company uses the Fair Wage database to analyze yearly its position regarding adequate wages.

Coverage and Results: In 2024, all Capgemini employees were paid an adequate wage, in line with applicable benchmarks. The company states: "The results of this analysis demonstrated that in 2024 all our employees were paid an adequate wage, in line with applicable benchmarks."

Scope: The assessment covers the company's own workforce globally. The statement confirms "all Group employees were paid at an adequate wage level" in 2024.

Methodology: Capgemini uses the Fair Wage Organization database to conduct yearly analysis of employee compensation positioning. The company states it aims "to ensure that we pay workforce at or above the minimum wage in each country and ideally at the adequate wage level."

Target: Capgemini has set a target to "maintain the compensation and social protection levels of all our employees, which are aligned or above fair levels and in line with local market practices." The company notes this target may need adjustment in case of significant acquisitions or divestments.

Additional Context: The disclosure also identifies a salient risk related to "potential impacts on the human rights of workers providing facilities management services: non-compliance with international standards on the living wage and decent working time for personnel providing maintenance, security, cleaning, waste collection and construction services" - indicating living wage considerations extend to value chain concerns.

Social protection

Coverage of social protection benefits

Capgemini employees are protected through a combination of private benefits packages and public social protection systems. The Group has developed a database with an external partner to monitor the nature of social benefits across all operating countries to ensure holistic market-aligned coverage.

Unemployment

In all countries where Capgemini operates, own workforce is covered against loss of income due to unemployment and receives unemployment income provided mostly through public programs.

Employment injury and disability

Capgemini employees are protected against loss of income due to employment injury and acquired disability through either:

• Worker compensation insurance
• Long-term or short-term disability insurances provided by Capgemini
• Additional sources of income provided by public bodies

Parental leave

The vast majority of Capgemini employees are protected against loss of income through parental leave policies and/or public sources. The Group offers approximately 23 weeks for primary parent leave across the Group.

Specific country enhancements in 2024:

• United Kingdom: Maternity leave increased from 18 weeks (100% paid) to 26 weeks and renamed as primary parental leave. Paternity leave increased from 2 weeks 100% paid to 4 weeks and renamed as partner leave.
• India: Fare welcome 2.0 program revamped with pre-childbirth maternity support for 1 year, post maternity assistance and childcare.
• France and India: Childcare facilities available.

Retirement

Capgemini employees are protected against loss of income due to retirement either by having private pension plans in place and/or through public pension systems.

Healthcare (sickness and medical care)

The total reward package includes healthcare (sickness and medical care) aligned to competitive market practices.

Life and disability coverage

Life and disability coverage is provided as part of the benefits package.

Wellness benefits

Wellness benefits related to giving birth or raising a child are provided.

Scheme type

Social protection is provided through:

• Private schemes: Benefits packages provided by Capgemini including healthcare, long-term and short-term disability, life insurance, and private pension plans
• Public schemes: Social contributions made on behalf of employees providing coverage through public systems for unemployment, employment injury, disability, parental leave, and retirement

Governance and monitoring

The Group has implemented a strong cross-function governance, supported by a global partner covering all Group countries, to monitor, optimize, develop and improve employee benefit coverage.

Target

Capgemini has set a target to maintain the compensation and social protection levels of all employees, which are aligned or above fair levels and in line with local market practices.

In 2024, all Group employees benefited from social protection against loss of income due to major life events as described above.

Persons with disabilities

Overall metrics

Regional breakdown

Methodology and scope

Data collection approach:

• Employees can choose to self-disclose their disability in the global tool "My Connect" wherever this functionality is available
• In countries where this functionality is not available (e.g., Australia), data is collected manually
• Data is collected and consolidated by the Group HR Reporting Team

Definition: The metrics capture people officially recognized with a disability, impairment or neurodivergence. The Group recommends employees undergo administrative recognition processes so they can be better supported and equipped to feel fully included in the workplace.

Legal restrictions and scope exclusions:

• The possibility to collect and/or disclose the number of people with disability depends on each country's local regulations
• The data presented does not cover the full scope of the Group due to these legal restrictions

Multi-year trend: After a rise of 46% between 2020 and 2022, the representation of people officially recognized with a disability, impairment or neurodivergence, increased by 8% in 2024. This progression reflects efforts in recruiting more of these talents, adapting job ads and interview processes, and encouraging more existing employees to self-declare.

Training and skills development metrics

Percentage of employees who participated in regular performance and career development reviews

By geographical areas and by gender (2024)

Total Percentage of employees that participated in regular performance and career development reviews by employee category: 91.9%

The percentage is extracted from the global performance management solution GetSUCCESS, which provides tracking of completed year-end performance forms. At the date of this Sustainability Statement, Capgemini Engineering Germany is not included in the scope of these figures.

Learning Hours

Total number of learning hours and average per employee by breakdown (2024)

Average Completed Learning Hours, including learning in the flow of work, per headcount at the end of the year

By geographical areas and by gender (2024)

Trainings are integrated automatically into the Group Learning & Development dashboard on a pre-defined frequency. For the purposes of calculating training statistics, only learning that is complete is included in the calculations for both compliance and volume-based calculations. Statistics on mandatory e-learning are consolidated via the Group Learning Management System (LMS), MyLearning.

2030 Target

Total investment in training

Not disclosed.

Key training achievements (2024)

• 25.7 million learning hours consumed in 2024
• 98% of people learn in NEXT, Capgemini's digital ecosystem
• 122,000 employees hold 242,000 certifications
• 61,000 new certifications awarded in 2024
• 57,000 people attended global learning events
• 55,000 have used GARI for peer-to-peer learning
• 313,000 users of the Gen AI campus
• 47,000 Connected Managers
• 100% VPs enrolled to VP360
• 320,000 skilled in sustainability
• 175,000 learners in Industry Campus
• 175,000 upskilled in the Cloud Campus

Health and safety metrics

Coverage by Health and Safety management system

Scope: At December 2024, four countries are ISO 45001 certified (India, The Netherlands, Germany and Italy), representing more than 59% of own employees. Beyond ISO certification, Capgemini has established 4 pillars to characterize a Health and Safety Management System (Strategy, Risk identification, Action Plan, Dedicated resource). Spain, Poland, Ireland, Portugal, UK and France also meet these criteria. Coverage is based on headcount figures from Group HR through the OneHR dashboard.

Work-related accidents

Note: The rate is calculated per 1,000,000 working hours (0.005796 × 1,000,000). Data collected at country level by local Health and Safety SPOCs and consolidated by the Group Health and Safety Team.

Fatalities

Days lost

Not disclosed.

Methodology note: This is the first year of centralized Health and Safety data collection following the publication of the Group Health and Safety Policy in December 2024. Countries will implement the policy within two years. Mental health risks such as burn-out are excluded as legal/social security recognition varies by country.

Work-life balance metrics

Parental leave policies

Capgemini reports that the vast majority of Capgemini employees are protected against loss of income through parental leave policies and/or public sources.

The Group offers approximately 23 weeks for primary parent leave across the Group.

Policy enhancements

Several countries upgraded their parental leave policies:

United Kingdom:

• Maternity leave (renamed primary parental leave): increased from 18 weeks (100% paid) to 26 weeks (100% paid)
• Paternity leave (renamed partner leave): increased from 2 weeks (100% paid) to 4 weeks (100% paid)

India:

• Fare Welcome 2.0 program revamped in 2024 with:
  • Pre-childbirth maternity support for 1 year
  • Post maternity assistance
  • Child care support

Facilities

• Childcare facilities exist notably in France and India
• Maternity or lactation rooms included in global Space design guidelines

Data limitations

No quantitative metrics disclosed for:

• % of employees entitled to family-related leave (by type and gender)
• % of entitled employees who took family-related leave (by gender)
• Return-to-work rate after parental leave (by gender)
• Multi-year comparisons of utilization rates

Compensation metrics

Capgemini reports compensation metrics for fiscal year 2023 (not 2024) on a limited scope basis covering approximately 75% of global headcount.

Pay gap

Capgemini does not disclose a global unadjusted gender pay gap. The company states:

"As we believe that equal pay for equal work is the right approach and an appropriate reflection of a fair representation of the gender gap, we have chosen to not disclose the global raw gender pay gap as in a Group present in more than 50 countries, with different business models and varied gender and pyramid structures in each country, such a globally calculated parameter is not providing a relevant picture."

Instead, Capgemini reports adjusted gender pay gaps on an 'equal pay for equal work' basis for the top 5 countries by headcount (representing close to 75% of global workforce) as at December 31, 2023:

Note: A negative value indicates a pay gap in favour of men; a positive value indicates a pay gap in favour of women.

The pay gaps were calculated using a regression analysis tool certified by EDGE on 2023 fixed compensation data. Data for the United States and United Kingdom was audited by EDGE as part of the certification process.

Remuneration ratio

Capgemini reports total remuneration ratios for the same top 5 countries (highest paid individual in the country to median employee in that country):

For France, the highest paid individual is the CEO. The ratio was calculated considering base salary and target variable cash compensation for all employees in the country, comparing the highest corresponding compensation to the median.

Methodology

Scope: Data covers the top 5 countries by headcount, representing close to 75% of global workforce. Global metrics are not disclosed.

Pay gap methodology: Calculated using EDGE-certified regression analysis tool on 2023 fixed compensation data, on an 'equal pay for equal work' basis. The EDGE methodology allows comparison on an equal work basis but does not fully factor the variety of business lines within each country.

Remuneration ratio methodology: Based on base salary and target variable cash compensation, comparing highest compensation in the country to the median of the country.

Timing: Metrics reported are for fiscal year 2023, not 2024.

Incidents, complaints and severe human rights impacts

Number of incidents of discrimination, including harassment & human rights complaints

Methodology notes

Discrimination incidents, including harassment, include:

• i) alerts collected through the SpeakUp tool
• ii) legal actions having resulted in a final adverse judgment against the Group
• iii) complaints to OECD National Contact Points (NCPs), relating to discrimination or harassment during the reporting year, as applicable

Complaints filed through channels for people in the own workforce to raise concerns on human rights issues other than discrimination or harassment cover alerts relating to working conditions and data privacy collected through the SpeakUp tool during the reporting year.

Following the double materiality assessment, Capgemini has not been identified as at risk of being connected to any severe human rights issues or incidents.

No complaint against a Group entity was filed to or pending before a National Contact Point for OECD multinational enterprises in 2024.

Status of complaints

The document notes that substantiated alerts result in appropriate remediation such as corrective actions, disciplinary actions for individuals (based on the severity of the alerts) and a review or update of related processes and improvement action plans. However, specific status breakdowns (open/resolved/under investigation) are not disclosed.

Business conduct policies and corporate culture

Capgemini has a comprehensive business conduct framework rooted in its seven core values (freedom, trust, team spirit, honesty, boldness, modesty, and fun) established by founder Serge Kampf. The company maintains that sound ethics is an essential foundation for profitable and sustainable business.

Code of Business Ethics

Policy name: Code of Business Ethics

Scope: All Group employees worldwide (must be signed by all new recruits); all members of the Capgemini SE Board of Directors and the Group Executive Board

Approval and oversight:

• Endorsed by all members of the Capgemini SE Board of Directors and the Group Executive Board
• Board of Directors' Charter includes extract from the Code of Business Ethics
• Ethics & Governance Committee oversees implementation

Key content/principles:

• Defines and documents the Group's values, action principles, and rules of conduct concerning:
  • Employees
  • Business integrity
  • Commercial relations
  • Group and third-party assets
  • Corporate Social Responsibility
• Five key areas including:
  • Safe and inclusive work environment
  • Speaking up culture
  • Commitment to equality, diversity and inclusion
  • Harassment-free environment with disciplinary sanctions
  • Perfect integrity in conduct of business and management of employees

Public availability: Available in multiple languages to all employees and external stakeholders on intranet and www.capgemini.com

Links to international standards:

• Aligns with the Group's commitment to UN Universal Declaration of Human Rights
• UN Global Compact

Monitoring and implementation:

• Annual mandatory e-learning training (Ethics@Capgemini) assigned to all employees since 2021
• 2024 completion rate: 94.0% of headcount
• Target: maintain >90% completion rate through 2030
• SpeakUp ethics helpline for reporting violations
• Monthly Pulse survey includes questions on values and ethical culture
• Annual ethical culture survey (Ethics Pulse)
• Target: keep >80% of employees with positive perception of Values, culture, and ethical behaviors through 2030

Human Rights Policy

Policy name: Human Rights Policy

Scope: Full value chain including employees, supply chain, client interactions, and local communities where the company operates

Approval and oversight:

• Published December 2021
• Chief Ethics Officer responsible for implementation program
• Country Ethics & Compliance Officers support implementation
• Ultimate accountability lies with Group CEO
• Monitored by Ethics and Governance Committee of the Capgemini SE Board of Directors

Key content/principles: Ten human rights commitments:

1. Equal opportunity and fair treatment
2. Freedom of expression
3. Freedom of association and collective bargaining
4. Harassment-free work
5. Safe and healthy workplace
6. Protection against child labor, forced labor, and human trafficking
7. Data privacy
8. Protecting human rights through ethical approach on AI solutions
9. Right to education
10. Digital inclusion

Public availability: Published on Capgemini intranet (accessible by all employees) and external website www.capgemini.com

Links to international standards:

• Universal Declaration of Human Rights
• United Nations Guiding Principles on Business and Human Rights (UNGPs)
• International Labor Organization's Declaration on Fundamental Principles and Rights at Work (ILO Declaration)

Monitoring and implementation:

• Mandatory annual training through Ethics@Capgemini e-learning
• Country human rights assessment questionnaire deployed following risk-based approach (pilot completed in India in 2022)
• SpeakUp ethics helpline for reporting violations
• Annual reporting to Ethics & Governance Committee
• Dedicated training sessions conducted in 2022 for Ethics & Compliance Officers and Internal Auditors

Anti-Corruption Policy

Policy name: Anti-Corruption Policy (part of Group Compliance Program)

Scope: Group-wide, all geographies and business lines

Approval and oversight:

• Compliance Committee headed by Chief Compliance Officer in conjunction with Legal Department
• Global network of local Ethics & Compliance Officers
• Annual presentation to Ethics & Governance Committee of Board of Directors
• Chief Audit Officer presents annual audit results on Sapin II Law compliance to Ethics & Governance Committee

Key content/principles:

• Zero tolerance for bribery and corruption
• Corruption risk mapping (updated annually)
• Specific accounting and non-accounting controls
• Internal control self-assessments by Finance teams

Links to international standards: Part of compliance with French Sapin II Law

Monitoring and implementation:

• Updated corruption risk map in 2024
• Review of corruption risks across countries where Group operates
• Ongoing monitoring and improvement of action plans
• Internal audit conclusions on understanding and application of anti-corruption programs

Competition Laws Policy

Policy name: Competition Laws Policy

Scope: Group-wide

Approval and oversight:

• Part of Group Compliance Program overseen by Compliance Committee
• Legal Department monitors changes in legislation

Key content/principles:

• Commitment to fair competition
• Compliance with anti-trust laws
• Updated toolkits on competition matters including best industry practices (notably on Consortia and Dawnraid processes)

Monitoring and implementation:

• Regular training provided by Legal Department
• Improvement and update of existing toolkits in 2024

Export Control and Sanctions Policy

Policy name: Export Control and Sanctions Policy (also referenced as Export Control and Trade Sanctions Policy)

Scope: All countries where Capgemini does business

Approval and oversight: Part of Group Compliance Program

Key content/principles:

• Compliance with applicable export and import trade control laws
• Compliance with sanctions and embargoes

Monitoring and implementation:

• Improved integration of export control and trade sanctions process in deal review process in 2024
• Updated toolkits
• Monitoring of regulatory evolutions related to Russia, Belarus, and other sensitive countries

Data Protection Policy

Policy name: Data Protection Policy (including Binding Corporate Rules)

Scope: Group-wide, covering all use of technology and processing of data

Approval and oversight:

• Group Data Protection Office
• Data Protection Champions appointed within Cybersecurity organization at Group and local level
• Steering Committees at regular intervals

Key content/principles:

• Compliance with data protection regulations
• Process for managing Data Subject Requests
• Binding Corporate Rules for data transfers

Public availability: Available to employees; external stakeholders can submit requests through dedicated channels

Monitoring and implementation:

• Enhanced data protection risk control levels in 2024
• Updated Data Protection Risk Assessment
• New mandatory data protection training module launched for all employees in 2024
• ISO 27001 certification
• Monitoring of new laws on data protection

Diversity & Inclusion Policy

Policy name: Diversity & Inclusion Policy

Scope: Group-wide, covering all employees

Approval and oversight: Group HR with oversight from Group Executive Board and D&I Board

Key content/principles: Four main ambitions:

1. Be a destination company where all talents can thrive
2. Offer an inclusive workplace with equal opportunities for all
3. Strengthen an inclusive culture, engaging all workforce
4. Make business and technology transformation an opportunity for local communities and broader society

Public availability: Available on intranet and external website www.capgemini.com

Monitoring and implementation:

• Monthly reporting through People Insights dashboard
• Quarterly updates to Group Executive Board, D&I board, and country boards
• EDGE certification process
• Employee networks (94 groups totaling 45,000 employees)
• Annual Information to International Works Council

Employee Relations Policy

Policy name: Employee Relations Policy

Scope: Group-wide

Approval and oversight:

• Group Management (Group HR & Group Employee Relations Team)
• Local management (HR Directors, local Employee Relations specialists, Managing Directors)

Key content/principles: Social foundations including:

• Providing equal opportunities and fair treatment
• Maintaining a harassment-free environment
• Freedom of association and collective bargaining
• Social dialogue and consultation

Monitoring and implementation:

• International Works Council (established 2001)
• Local works councils and employee representative bodies
• Regular consultation and dialogue

Health & Safety Policy

Policy name: Health & Safety Policy (also referenced as Group Health and Safety Policy)

Policy name (additional): People Security and Safety General Policy

Scope: All employees, whether working on Capgemini sites or client sites; covers all countries where Group operates

Approval and oversight:

• Presented to Executive Human Resources Committee (September 2024)
• Presented to International Works Council Bureau (October 2024) and plenary session (November 2024)
• Group Health and Safety Committee created in 2024
• Group Management (Group HR & Group Health and Safety Team)
• Local management (country HR leaders, local H&S specialists, chairmen of country boards/Managing Directors)

Key content/principles:

• Proactive, preventative, and inclusive approach to protecting welfare of people while at work
• Commitment to safe workplace
• Reiterates commitment to harassment-free work environment and prohibits retaliation
• People security and safety (managing threats, mitigating risks, controlling effectiveness)

Public availability: Published on external website December 2024

Monitoring and implementation:

• Global community of H&S correspondents across countries
• ISO 45001 certification (Germany, Italy)
• Annual summary to be submitted to IWC Bureau in December 2025
• Local works councils/Health & Safety committees informed December 2024

ESG Policy

Policy name: ESG Policy

Scope: Group-wide, consolidated scope

Approval and oversight:

• Approved by Board of Directors in 2021, updated in 2024
• Board of Directors monitors and steers Group ESG strategy
• CEO sets targets

Key content/principles: Priorities include:

• Maintain high ethical standards at all times for mutual growth
• Zero tolerance for bribery and corruption
• Commitment to fair competition
• Compliance with laws including Trade controls
• Target: suppliers covering 80% of purchase amount to commit to ESG standards by 2030
• Target: >80% employees with positive perception of Values, culture, and ethical behaviors through 2030

Monitoring and implementation:

• Regular monitoring and reporting
• Integration into business strategy and operations

Code of Ethics for AI

Policy name: Code of Ethics for AI

Scope: All AI solutions developed and delivered by Capgemini across all industries; entire lifecycle of AI systems from design to deployment

Approval and oversight: Approved by Capgemini Group Executive Board

Key content/principles: Seven guiding principles:

1. AI with Delimited Impact (human benefit, respects fundamental human rights)
2. Sustainable AI (environmental sustainability, long-term societal impacts)
3. Fair AI (free from bias, inclusive)
4. Transparent and Explainable AI (understandable, traceable, auditable)
5. Controllable AI (human oversight and accountability)
6. Robust and Safe AI (resilient, reliable, fallback plans)
7. AI Respectful of Privacy (data protection, privacy by design)

Public availability: Available to employees and stakeholders

Links to international standards:

• Draws on UN Universal Declaration of Human Rights
• UN Global Compact
• EU AI Pact (Capgemini signatory since 2024)

Monitoring and implementation:

• Dedicated training to be deployed in 2025
• Target: ≥80% of headcount to complete mandatory e-learning on Ethics in AI by 2030
• Advanced security measures to prevent AI weaponization
• Vulnerability follow-up and security controls on approved Generative AI tools

SpeakUp Policy

Policy name: SpeakUp Policy

Scope: All stakeholders including employees, customers, suppliers, business partners, and value chain workers

Approval and oversight:

• Group Ethics Office manages the platform
• Supported by global network of General Counsels, Ethics & Compliance Officers, and SpeakUp investigators

Key content/principles:

• Framework for submitting alerts on unethical behaviors
• Ask for advice and guidance on ethical dilemmas
• Voluntary, confidential, allows anonymity
• Protection against retaliation
• Web and phone-based ethics reporting

Public availability: Available 24/7 in several languages; accessible on external website and integrated in Supplier Standards of Conduct

Monitoring and implementation:

• Independent service provider hosts platform
• All alerts investigated promptly, independently, objectively
• Compliance with EU Directive 2019/1937 on protection of whistleblowers
• Annual statistics shared with employees
• Ongoing communication through Ethics Radio initiative
• 365 discrimination incidents (including harassment) reported in 2024

Conflict of Interest Policy

Policy name: Conflict of Interest Policy

Scope: All employees

Approval and oversight: Group Ethics Department

Key content/principles:

• Framework for identifying and managing conflicts of interest
• Strengthened management of conflicts aligned with policy

Monitoring and implementation:

• Dedicated tool "Declare" implemented
• Rolled out across 43 countries in 2024 covering ~93% of Group workforce
• Continued rollout to remaining countries planned for 2025

Supplier Standards of Conduct

Policy name: Supplier Standards of Conduct

Scope: Tier 1 suppliers and suppliers further down value chain

Approval and oversight: Group Procurement

Key content/principles:

• Standards required within business relationships with suppliers
• Compliance with international, national and local law including:
  • Human rights
  • Social and labor rights
  • Occupational Health and Safety
• Non-negotiable requirements: human rights, Health and Safety, well-being, and labor violations
• Provisions for Tier 1 suppliers to flow down requirements through their supply chain
• Includes reference to SpeakUp helpline

Public availability: Updated in 2024 and deployed with main suppliers; new version aligned with Group Human Rights Policy and ESG Policy; available externally

Monitoring and implementation:

• ESG Pledge with main suppliers
• ESG rating database
• Supply chain ESG risk mapping
• Performance measures for ESG risk
• Scrutiny and compliance controls for contingent workforce
• Annual assessment of strategic suppliers through business review meetings

Sustainable Procurement Policy (also referenced as Procurement Policy)

Policy name: Sustainable Procurement Policy / Procurement Policy

Scope: All procurement activities group-wide

Approval and oversight: Head of Procurement

Key content/principles:

• Human rights, Health and Safety, well-being and labor violations are non-negotiable requirements
• Encourages working with suppliers to promote ESG challenges (diversity, equity, inclusion)
• Supplier diversity policy (increase spend with diverse suppliers)

Monitoring and implementation:

• Incorporation of ESG and Carbon objectives into procurement processes in 2024
• Active participation in diverse supplier organizations (CAMSC, CCAB, NGLCC, NMSDC, NaVOBA, WEConnect International, WBENC, DisabilityIN)
• Monitoring of diverse supplier spend
• Database of suppliers' diversity certifications

Freelancers Group Policy

Policy name: Freelancers Group Policy

Scope: All non-employee workers (freelancers/independent contractors) at Capgemini

Key content/principles:

• Provides framework for setting consistent rules regarding non-employee workers

Public availability: New policy in 2024

Business Travel Assistance Policy

Policy name: Business Travel Assistance Policy

Scope: All employees traveling for business

Key content/principles:

• Covers all emergencies worldwide
• Travel safety support

Public availability: New policy in 2024

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Additional governance mechanisms

Beyond formal policies, Capgemini has established several governance bodies and mechanisms:

• Ethics & Governance Committee of the Board (established 2006): ensures promotion of seven core values and implementation of corruption prevention system
• Audit & Risk Committee of the Board: confirms major risks are identified and managed
• Compliance Committee: headed by Chief Compliance Officer, coordinates actions on corruption, duty of care, competition, sanctions, embargoes, and data protection
• Group Health and Safety Committee (created 2024): includes Group H&S team, Real Estate, and Security
• International Works Council (created 2001): facilitates dialogue between employee representatives and Group Management across all countries

The Chairman of the Board (Paul Hermelin) has been entrusted by the Board with a mission to promote the Group's values and culture.

Corporate culture

Capgemini's corporate culture is anchored in seven core values established in 1967: freedom, trust, team spirit, honesty, boldness, modesty, and fun. These values are shared by team members worldwide and remain constant while nurturing diversity and individual freedoms.

The ethical culture is described as an aspiration to guide behavior, starting with questioning actions and decisions to define "doing the right thing." This values-based approach has enabled high ethical standards while nurturing team diversity.

For the twelfth consecutive year (2024), Capgemini was recognized as One of the World's Most Ethical Companies® by the Ethisphere Institute, highlighting the Group's strong ethical culture rooted in its core values.

The company measures cultural effectiveness through:

• Monthly Pulse survey (over 140,000 anonymous responses monthly) including questions on values and ethical culture
• Annual ethical culture survey (Ethics Pulse) embedded in Pulse since 2021
• Target: maintain >80% of employees with positive perception of Values, culture, and ethical behaviors through 2030

Incidents of corruption or bribery

Confirmed incidents

Capgemini reported zero confirmed incidents of corruption or bribery during the 2024 reporting period.

Convictions and fines

Disciplinary actions

While specific counts were not provided, the company states that "substantiated allegations lead to disciplinary sanctions, up to and including termination of employment, in line with our commitment to zero tolerance of corruption."

Contracts terminated

No information disclosed on contracts terminated with business partners due to corruption or bribery.

Investigation and speak-up procedures

Capgemini operates SpeakUp, a 24/7 web and phone-based ethics helpline available to all stakeholders (employees, clients, suppliers, business partners). The helpline is:

• Hosted by an independent service provider
• Managed by the Group Ethics Office
• Supported by a global network of General Counsels, Ethics & Compliance Officers and SpeakUp investigators
• Voluntary, confidential, and allows anonymity

In 2024, the company reported 1,226 total alerts through SpeakUp (compared to 1,059 in 2023). Alerts are investigated "promptly, independently and objectively" in accordance with EU Directive 2019/1937 on whistleblower protection.

The company maintains a strict non-retaliation policy: "The Group prohibits retaliation against anyone for raising or helping to address an alert. Any known reporter who reports an alert in 'good faith' and all those who are involved in the investigation (e.g., witness, investigation team) are protected from retaliation, irrespective of the outcome of the investigation."

Retaliation is defined as "any negative action taken against a reporter or other person participating in the investigation" and "is grounds for disciplinary action, up to and including dismissal."

Political influence and lobbying activities

Political engagement approach

Capgemini's Group Anti-Corruption Policy reiterates the Group's long-standing rule strictly prohibiting contributions to political organizations.

The Group commits that any advocacy activities undertaken directly or indirectly are consistent with the goals of the Paris Agreement. Capgemini is not aware of any exclusion from the EU Paris aligned benchmarks.

Ethical standards and guidelines

Compliance with the Group Anti-Corruption Policy is facilitated by specific policies, processes and tools relating to:

• Travel and expenses
• Procurement and third-party due diligence
• Management of conflicts of interest
• Ethics helpline – SpeakUp

The Group's Code of Business Ethics, Group Anti-Corruption Policy, Group Conflict of Interest Policy, SpeakUp Policy and Supplier Standards of Conduct are all publicly available on the Group's website (www.capgemini.com).

Political contributions

Capgemini strictly prohibits contributions to political organizations. The Group maintains a long-standing rule against making political contributions.

Total political contributions: €0

Trade association memberships

Capgemini holds memberships in various trade associations and coalitions, though specific dues/contributions are not disclosed. Key memberships include:

• Business Ambition for 1.5°C targets (signed 2020)
• World Economic Forum's Alliance of CEO Climate Leaders (2021)
• RE100 (2020) – committed to 100% renewable electricity by 2025
• EV100 (2021) – committed to electric fleet by 2030
• First Movers Coalition (2023) – carbon removal commitments
• European Green Digital Coalition (2022)
• United Nations Global Compact Communication on Progress Early Adopters Program (2022)
• European Commission's Sustainable Consumption Pledge (2023)
• TCFD (Taskforce for Climate-related Financial Disclosures) signatory (2020)
• UN's Race to Zero campaign – founding member
• LEAF Coalition (2022) – tropical forest protection
• 1t.org (WEF) – committed to planting 20 million trees by 2030
• Business for Societal Impact (B4SI) Network (2024)
• Paris Call for Trust and Security in Cyberspace (signatory since November 2018)
• World Economic Forum's Partnering for Racial Justice in Business initiative (founding member)
• Edison Alliance (2023) – digital economy access pledge
• Low Carbon 100 Europe

Lobbying expenditure

No specific lobbying expenditure data is disclosed in the document. The Group's approach to advocacy emphasizes alignment with the Paris Agreement goals.

Focus areas

While Capgemini does not engage in political contributions or formal lobbying, the Group's advocacy efforts focus on:

• Climate change and net zero transition
• Digital inclusion and accessibility
• Sustainability and circular economy
• Diversity, equity, and inclusion
• Responsible technology and cybersecurity

EU Transparency Register

No mention of registration in the EU Transparency Register or equivalent registries is provided in the document.