CCC

Reference: page 154

As at 31 January 2025 the Supervisory Board comprised five members (one woman, four men; 20% women, 80% independent), and the Management Board comprised two members, both men. The disclosure profiles each member's sustainability expertise, noting board access to the Group's sustainability team. It describes the Audit Committee as a standing Supervisory Board committee chaired by Filip Gorczyca that in 2024 addressed ESG matters including the materiality assessment, ESG-linked financing, the regulatory environment and reporting scope. It sets out the ESG governance structure across the Supervisory Board/Audit Committee, Management Board and management personnel, and explains how governing bodies set objectives on impacts, risks and opportunities, with the Management Board holding final responsibility for the Risk Register and Corporate Risk Map.

Reference: page 158

The Management Board receives a sustainability activity report every two weeks, reviewed at meetings where it is updated on material impacts, risks and opportunities, due diligence processes and the applicable policies, actions, metrics and targets. These updates are presented once a year to members of the Audit Committee and the Supervisory Board during dedicated sessions. The Management Board and Sustainability Department regularly monitor progress toward GO.25 Sustainability Strategy objectives, informing policy adjustments and planned actions. Sustainability-related risks and opportunities addressed during the reporting period included the transition toward sustainable development, limited employee upskilling opportunities, departures of employees with key knowledge, rising raw material prices from climate events, difficulty sourcing suppliers meeting climate standards, shifting consumer preferences, deforestation and microplastics.

Reference: page 159

Supervisory Board remuneration comprises solely fixed components not linked to sustainability matters. Management Board remuneration comprises fixed components and variable components, including individual short-term bonuses, short-term team bonuses and long-term bonuses. Short-term bonuses are tied to short-term objectives and may be directly or indirectly linked to sustainability targets. During the reporting period the Company exercised the option to temporarily waive application of the Remuneration Policy, as permitted under Art. 90f of the Public Offering Act and section 9 of the Policy, authorised by a Supervisory Board resolution and effective from the second half of the 2022 financial year. The waiver concerned variable remuneration for Management Board members. As a result, Management Board remuneration in 2024 was not linked to sustainability matters, including those related to climate. The Remuneration Policy is approved by the General Meeting.

Reference: page 159

The disclosure maps the core elements of the CCC Group's due diligence process to the paragraphs of the sustainability statement where related information is reported. Embedding due diligence in governance, strategy and business model is covered by SBM-1, S1-1, S2-1, S3-1, S4-1 and G1-1. Engaging with affected stakeholders in all key steps is covered by SBM-2 and the corresponding topical -2 disclosures. Identifying and assessing adverse impacts is covered by SBM-3 and IRO-1. Taking actions to address those adverse impacts is covered by E1-3, E2-2, E5-2, S1-3, S2-3, S3-3, S4-3 and G1-3. Tracking the effectiveness of these efforts and communicating is covered by E1-6, E2-4, E2-5, E5-4, E5-5, S1-17, S2-4, S3-4 and S4-4.

Reference: page 160

The process to identify and assess sustainability risks is fully integrated into the Group's overall risk management system, covering internal and external context. The system rests on the corporate structure and a risk management process spanning identification, measurement, assessment, mitigation, monitoring and reporting. Functions responsible are the Management Board, Risk Owners, Risk Stewards and Internal Audit, with Internal Audit coordinating the process. Each risk is assessed on a 1 to 4 scale across likelihood and impact dimensions (financial, reputational, business continuity, legal), on both gross and net bases. An integrated internal control system ensures accurate and complete reporting, including sustainability disclosures, using preventive, detective and corrective controls. It is integrated with the financial reporting control framework, overseen by the Audit Committee, operated by the Management Board, and regularly reviewed by Internal Audit.

Reference: page 164

The CCC Group's business model centres on expanding its retail network across full-price and off-price segments through an omnichannel platform built on four complementary business lines (CCC, HalfPrice, eobuwie and MODIVO), with a new Worldbox line in development. Total revenue for the period was PLN 10,302.8 million and Group headcount was 15,704. The Group is not active in fossil fuels, chemicals, controversial weapons or tobacco. Sustainability is embedded in the GO.25 Strategy, built around three pillars (Environment, Employees, Society) supporting the main product-related goal, and underpinned by the Paris Agreement, the European Green Deal, TCFD and the EU circular economy action plan. The disclosure presents the Group's structure, shareholding, strategic objectives such as reducing natural leather use by 40% by 2030, and a detailed value chain model spanning upstream, own operations and downstream.

Reference: page 175

The CCC Group engages stakeholders in shaping its strategy and business model through participation in the materiality assessment and through surveys and interviews on material sustainability topics. Key stakeholders, identified during the 2024 materiality assessment, include consumers, employees, merchandise suppliers, suppliers and subcontractors, value chain workers, legislative bodies and public administration, investors, financial institutions, local communities and media. The disclosure sets out the engagement method and the topics and purpose of engagement for each group. Insights are analysed and integrated into strategic decision-making, and were used to develop the GO.25 Strategy and will inform the next growth strategy. The Management and Supervisory Boards receive regular updates on stakeholder feedback, which is incorporated into strategic and operational reporting, and stakeholder views are taken into account when modifying the strategy or business model.

Reference: page 178

The materiality assessment identified 21 material IROs: 15 material impacts and 6 material risks, with no material opportunities. The impacts span all topical standards, covering GHG emissions (E1), microplastics from synthetic products (E2), water and marine resources (E3), biodiversity and deforestation (E4), resource inflows and waste (E5), working conditions for own workforce (S1) and value chain workers (S2), affected communities (S3), consumer data protection and access to product information (S4), and corporate culture, whistleblower protection, supplier relationship management and bribery (G1). The six risks comprise rising raw and processed material prices, limited availability of suppliers meeting climate and social standards, deforestation, shifting smart consumption trends, unauthorised access to IT infrastructure, and transformation of processes toward sustainability. Each IRO is mapped to its nature, value chain segment and time horizon, and linked to GO.25 strategic objectives.

Reference: page 186

In 2024 the CCC Group conducted a comprehensive materiality assessment aligned with the CSRD and ESRS, using the MAX 4 MATERIALITY ASSESSMENT MATRIX methodology developed by MATERIALITY Sp. z o.o. The assessment covered all 90 sustainability matters listed in ESRS 1 AR 16 and drew on five equally weighted information sources: a comparative analysis of 16 fashion companies, a management questionnaire, an expert questionnaire, an evaluation by three MATERIALITY experts, and surveys and interviews with 11 external stakeholder representatives. Impact materiality assessed scale, scope, irremediable character and likelihood on a 1 to 5 scale; financial materiality assessed scale of effects and likelihood. The assessment ran June to September 2024, was validated at a workshop on 3 September 2024 and approved by the Management Board on 20 September 2024, identifying 10 key stakeholder groups, 15 impacts and 6 risks.

Reference: page 188

The topics covered under ESRS E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1 were assessed as material through the materiality assessment and are reported in this document, alongside the cross-cutting ESRS 2 General Disclosures. The disclosure introduces an ESRS compliance table listing the disclosure requirements covered by the undertaking's sustainability statement. The report does not include disclosures stemming from other legislation or generally accepted sustainability reporting pronouncements. Information is incorporated by reference to other sections of the Directors' Report and to the financial statements, including the strategy and business model under ESRS 2 SBM-1, which references section 2 'CCC Group Development Strategy'. Phase-in provisions under Appendix C to ESRS 1 were applied to a defined set of disclosure requirements.

Reference: page 200

The CCC Group states it has not adopted a transition plan for climate change mitigation. It is developing a Decarbonisation Strategy that will serve as its transition plan in 2025; work on this began in 2022 to map the pathway and measures to reach net-zero emissions. The Group does have GHG reduction targets under its GO.25 Sustainability Strategy and Sustainable Finance Framework: Scope 1+2 reduction of 56% by 2030 against a 2022 baseline (43,548.9 Mg CO2e to 19,161.5 Mg CO2e) and Scope 3 reduction of 40% by 2030 against a 2021 baseline. The targets are not explicitly based on a 1.5C pathway, and no SBTi validation or formal net-zero year is stated. Decarbonisation levers include renewable energy, energy efficiency, low-emission materials, and hybrid fleet vehicles. The Environmental Policy was approved by the President of the Management Board, with annual Management Board evaluation.

Reference: page 204

The CCC Group updated and implemented its Environmental Policy in 2022, aligning it with the GO.25 Sustainable Development Strategy and the EU Taxonomy Regulation (EU) 2020/852 and its Technical Screening Criteria. The Policy applies to all Group companies regardless of business profile. It sets six priorities including climate change mitigation, climate change adaptation, protection of water and marine resources, circular economy, pollution prevention, and biodiversity protection. Mitigation focuses on low- and zero-carbon energy generation and storage, energy efficiency, climate-neutral mobility, and renewable materials. Adaptation focuses on solutions to mitigate negative climate impacts. The Policy was ratified by a formal internal order issued by the President of the Management Board; the Management Board annually evaluates implementation and reports to the Supervisory Board. The Environmental Protection Department, reporting to the Supply Chain Managing Director, implements the Policy. The environmental and decarbonisation strategies sit within the GO.25 framework.

Reference: page 206

The Group's priorities are cutting GHG emissions by raising the share of renewable energy, including internally generated solar power, and improving operational energy efficiency. Mitigation actions include eliminating unnecessary energy use in retail stores, continuous energy efficiency improvements in stores and equipment, using energy efficiency criteria for store site selection, prioritising new buildings that meet EU Taxonomy Technical Screening Criteria, constructing and renovating owned buildings to those criteria, applying low-carbon transport criteria for logistics partners, encouraging low-carbon employee business travel, prioritising low-carbon materials in product design, and monitoring plant and animal raw materials to avoid deforestation. Adaptation actions include constructing and renovating buildings resilient to weather extremes, heatwaves and droughts, and optimising inventory and product categories for changing weather. The Group is a signatory to the Fashion Industry Charter for Climate Action under the UNFCCC.

Reference: page 207

The CCC Group has defined GHG reduction targets across all three scopes under the GO.25 Sustainability Strategy and the Sustainable Finance Framework. Under GO.25: a 40% reduction in Scope 1+2 emissions by 2025 versus 2019, and a 10% reduction in Scope 3 by 2025 versus 2021. Under the Sustainable Finance Framework adopted in 2024: a 56% reduction in Scope 1+2 by 2030 versus a 2022 baseline of 43,548.9 Mg CO2e (targeted cut of 24,387.4 Mg CO2e to 19,161.5 Mg CO2e), and a 40% reduction in Scope 3 by 2030 versus a 2021 baseline of 1,205,421.9 Mg CO2e (cut of 482,154.9 Mg CO2e to 723,253.1 Mg CO2e). The base year for Scope 1+2 was changed to 2022 from 2019. Targets are not explicitly based on a 1.5C pathway. Supporting actions include renewable energy transition, building modernisation, hybrid fleet, low-emission materials, and FSC-certified packaging.

Reference: page 208

Total energy consumption (fuel, electricity, heat and cooling) by the CCC Group in 2024 was 101,378.06 MWh, up 6.29% year on year. Of this, 72,534.56 MWh (71.55%) came from fossil sources and 28,843.50 MWh (28.45%) from renewable sources, comprising 28,736.24 MWh purchased and 107.25 MWh self-generated non-fuel renewable energy. Purchased or generated electricity, heat, steam and cooling accounted for 86.25% of total consumption; the remaining 13.75% was crude oil, petroleum products and natural gas. Fuel from crude oil and petroleum products was 9,423.39 MWh and natural gas 4,511.50 MWh. There was no coal or nuclear consumption. Energy intensity from high climate impact sector activities per net revenue fell to 9.84 MWh per PLN 1 million from 10.10, a 2.61% decrease. The Group sources renewable energy certified under Poland's Green Energy Sales Guarantee System (PTCE), though these are not Guarantees of Origin.

Reference: page 210

In 2024, Gross Scope 1 emissions were 3,145.37 Mg CO2e (down 4.05% YoY), market-based Scope 2 emissions were 23,735.84 Mg CO2e (down 11.08%), and location-based Scope 2 emissions were 41,792.13 Mg CO2e (up 2.99%). Scope 3 emissions totalled 1,395,862.63 Mg CO2e, up 12.46% YoY and representing 98.11% of total emissions. Total Scope 1+2 (market-based) plus Scope 3 was 1,422,743.84 Mg CO2e; location-based plus Scope 3 was 1,440,800.14 Mg CO2e. Category 1 (purchased goods and services) was the largest Scope 3 source at 1,215,525.15 Mg CO2e (87.08% of Scope 3). Base years are 2019 for Scope 1+2 and 2021 for Scope 3. Methodology follows the GHG Protocol, covering seven gases with IPCC AR5 GWP factors, using DEFRA 2024, KOBiZE, IEA 2023, ecoinvent, Ademe and EPA emission factors. No biogenic emissions were reported in 2024.

Reference: page 219

The CCC Group did not purchase any offsets or carbon credits in 2024. The Group reports no GHG emissions regulated under emissions trading schemes (reported as nil for both 2023 and 2024). No GHG removals or mitigation projects financed through carbon credits are disclosed. The section also presents other energy-related and intensity indicators, including an estimated carbon footprint per private-label and licensed-brand product. This per-product footprint, based on Scope 3 Category 1 production emissions divided by 51.3 million units (transport excluded), fell to 15.45 kg CO2e in 2024 from 18.80 kg CO2e in 2023, a 17.80% decrease.

Reference: page 220

The CCC Group does not apply internal carbon pricing schemes.

Reference: page 221

CCC addresses pollution through its Environmental Policy, the CCC Group Supplier Code of Conduct, and a chemical substance monitoring procedure. The Environmental Policy covers supply chain and own operations, focusing on preventing or minimising emissions of pollutants to air, water and soil and on avoiding adverse effects on health and the environment from the production, use or disposal of chemicals. The Supplier Code of Conduct addresses substances in commercial products and production, requiring compliance with national and European regulations and accredited laboratory testing. Its Restricted Substances List contains about 50 substances, while the Group's list of used substances contains around 260 items. All policies are overseen by the President of the Management Board.

Reference: page 223

In 2022, CCC Group joined the Zero Discharge of Hazardous Chemicals (ZDHC) initiative to help phase out harmful substances in apparel and footwear production. The Group actively engages with suppliers to ensure products are free from harmful chemical substances. The Supplier Code of Conduct sets detailed requirements for responsible chemical management across the supply chain, with particular focus on the REACH Regulation, which sets concentration limits for chemicals in finished products. Compliance with the Restricted Substances List is a prerequisite for business relationships and order approval, and the Group conducts regular verification to eliminate the risk of restricted substances. In 2024, CCC did not initiate any efforts to regenerate ecosystems where pollution has occurred.

Reference: page 223

The Group has not established any targets for preventing air, water and soil pollution, nor for addressing substances of concern and substances of very high concern. Activities with potential direct impact are addressed in other action areas, particularly those focused on greenhouse gas reduction and the implementation of sustainable product solutions. This specifically includes the target to reduce the use of natural leather by 40% by 2030, as well as the exclusive use of leather certified by the Leather Working Group. This certification ensures that water used in the tanning process is circulated in a closed-loop system and that no pollutants are released into ecosystems.

Reference: page 225

Although there are no specific policies dedicated solely to water, the safeguarding of water resources is an integral component of the CCC Group's Environmental Policy. Currently there are no existing policies addressing the sustainability of oceans and seas. However, it is anticipated that such policies will be developed after a thorough assessment of the Group's impact on water resources, planned for 2025, and after establishing priorities and future courses of action. The CCC Group does not operate any sites located in areas of high water stress. Since 2023, the Group has submitted a full Water disclosure to CDP, providing information on water resource management, water-related risks and opportunities, and the impact of its operations on aquatic ecosystems.

Reference: page 225

In 2024, the CCC Group did not implement any initiatives specifically addressing water and marine resources within the value chain. Following a thorough assessment of the Group's impact on water resources, further initiatives will be implemented in 2026 to 2030, with a particular focus on the value chain. No collective actions were undertaken with external entities to support water and marine resource protection, nor were any initiatives launched in areas exposed to water-related risks, including regions experiencing significant water scarcity. In 2024, no consultations were held with local communities in this regard.

Reference: page 225

The CCC Group has not established any targets for water and marine resources. However, a strategic objective by 2025 is to assess the impacts of the Group and its value chain on water resources and to develop a strategy for enhancing water efficiency management within the Group. To date, no detailed assessment has been carried out regarding the Group's impact on water resources, although the topic has been included in the materiality assessment, and an in-depth assessment is planned for 2025 to analyse impacts in the context of production processes, supporting infrastructure and wastewater management.

Reference: page 226

The CCC Group has not assessed the resilience of its strategy and business model in relation to biodiversity and has not developed a transition plan to align its model with planetary boundaries for biosphere integrity and land-system change. Biodiversity links directly to raw material availability, quality and price. The Group identified one material actual negative impact related to habitat conversion, land use and agricultural expansion along the supply chain, plus one material risk related to deforestation. Natural leather makes up about 6.5% of all materials used in production (around 90 materials and components in total) and has the highest carbon footprint. The Group plans to reduce reliance on leather or substitute it with alternatives.

Reference: page 227

The CCC Group has no dedicated transition plan or specific biodiversity policy, but biodiversity is inherently part of its Environmental Policy. The matter was identified as material in the 2024 materiality assessment and is addressed in the GO.25 Sustainability Strategy. The Environmental Policy approach to preserving and restoring biodiversity focuses on: preserving the natural environment and preventing its deterioration; protecting and restoring ecosystems; sustainable land use and management including soil biodiversity protection, land degradation neutrality and remediation of contaminated sites; sustainable agricultural practices that increase biodiversity or prevent land degradation, deforestation and habitat loss; and sustainable forestry practices. An analysis scheduled for 2025 will focus on biodiversity-sensitive areas in the value chain.

Reference: page 228

In 2024 the CCC Group submitted a full Forest disclosure to CDP, covering impacts and risk management for forest-based products that may contribute to deforestation and forest degradation. As part of its updated procurement policy, the Group plans to gradually reduce the use of natural leather in manufacturing private and licensed labels. Aside from these initiatives, the Group pursued no other biodiversity actions. In 2022 an environmental report was prepared for the head office and logistics centres site in Polkowice, and a Biodiversity Management Plan with care and maintenance guidelines was developed. The site was found to have significant environmental value. No areas near the site are adversely affected by CCC. Specific measures will follow the 2025 impact assessment.

Reference: page 228

As part of its strategy, the CCC Group has pledged to identify and assess its own impact and the impact of its supply chain on biodiversity by 2025. Upon completion of the impact analysis, decisions will be made regarding further actions and specific targets will be set in this area. No quantitative biodiversity targets have yet been established.

Reference: page 228

The CCC Group does not own, lease, or manage any sites located in or near biodiversity-sensitive areas that it is negatively affecting. No specific impact metrics on biodiversity change are reported, as the Group has not yet completed the assessment of its impact on biodiversity, which is scheduled for 2025. In 2024 no consultations were held with local communities in this regard.

Reference: page 229

The Group's commitment to the circular economy is outlined in its Environmental Policy, with strategic initiatives set out in the environmental section of the GO.25 Sustainability Strategy focusing on waste reduction and responsible product management. The Group has also devised a circular economy roadmap. The Policy emphasises shifting away from virgin resources toward secondary (recycled) and renewable resources. Commitments include integrating circular design into all processes, exploring circular business models, extending product lifespan, designing repairable products with spare parts, using recycled and recyclable packaging, and furnishing stores with reusable, disassemblable fixtures. The Environmental Protection Department, reporting to the Supply Chain Managing Director, implements the Policy, which provides for ecodesign of products and packaging.

Reference: page 230

In 2024 the CCC Group implemented several circular economy initiatives. weCare products accounted for 10% of all products purchased from the CCC business line. Packaging optimisation included replacing coated cardboard with uncoated variants at HalfPrice, introducing 100% recyclable poly mailers, and reducing the number of packaging sizes to lower paper consumption. The flagship Give Your Shoes a Second Life used-footwear collection programme collected over 43,600 pairs in 2024, bringing the cumulative total above 109,000 pairs since its 2021 pilot, with new pilots in Hungary and Romania. About 90% of returned footwear is suitable for reuse. The Group also participated in the EkoZwroty collaboration with InPost, collecting close to 10,000 pairs (4,000 in 2024).

Reference: page 232

Under its GO.25 Sustainability Strategy, the CCC Group set 2025 circular economy targets: 100% of product categories to include sustainable collections (baseline 2021: 15% weCare products); 100% of packaging to be recyclable and made from recycled materials; launch of single cardboard packaging in e-commerce; roll out the used shoes collection across 100% of stores in Poland and abroad (baseline: pilot in 20 Polish stores); and reduce waste generated by 30% (baseline 2019: 7,591.9 Mg). Targets are voluntary, not science-based, with no ecological thresholds applied. The 2024 Sustainability Finance Framework sets a target to expand the used footwear collection programme to cover 8% of total sales by 2030.

Reference: page 233

In 2024 the total weight of product and material inflows amounted to 77,927.63 Mg (up 15.56% from 67,433.10 Mg in 2023), of which 73.50% (57,273.87 Mg) were products and 26.50% (20,653.77 Mg) were technical materials. Product inflows included merchandise such as footwear, bags, clothing and accessories, plus textiles, furniture and IT equipment. Secondary reused materials accounted for 3.33% of technical materials (up from 3.20%), totalling 686.97 Mg. No biological materials were used in 2024 and the percentage of sustainably sourced biological materials was 0.00%. Technical materials used in packaging production accounted for 23.88%, and those used in the Group's products and services for 9.88% of total technical material weight.

Reference: page 234

In 2024 the total weight of product outflows was 44,753.23 Mg (up 13.24%), of which 19.68% were recyclable. The total weight of packaging outflows was 17,693.97 Mg, with 94.35% recyclable. The recyclability rate for materials used in CCC business line products was 34.66%. The 2024 complaint rate was 1.7%. Expected and average product durability was 2 years across footwear, bags, apparel, accessories and other products. The Group generated 11,498.59 Mg of waste in 2024 (up 39.90%), including 2.51 Mg hazardous and 11,496.08 Mg non-hazardous; 90.59% was recycled and 1,083.76 Mg (9.43%) was not recycled. Leather offcuts are repurposed for inserts, reinforcements, tongues, zipper sliders and linings.

Reference: page 234

In 2024 the total weight of product outflows was 44,753.23 Mg (up 13.24%), of which 19.68% were recyclable. The total weight of packaging outflows was 17,693.97 Mg, with 94.35% recyclable. The recyclability rate for materials used in CCC business line products was 34.66%. The 2024 complaint rate was 1.7%. Expected and average product durability was 2 years across footwear, bags, apparel, accessories and other products. The Group generated 11,498.59 Mg of waste in 2024 (up 39.90%), including 2.51 Mg hazardous and 11,496.08 Mg non-hazardous; 90.59% was recycled and 1,083.76 Mg (9.43%) was not recycled. Leather offcuts are repurposed for inserts, reinforcements, tongues, zipper sliders and linings.

Reference: page 255

The CCC Group commits to a work environment free from discrimination, with equal pay and development opportunities, respect for freedom of association, and zero tolerance for forced and child labour. Its Code of Ethics formalises adherence to fundamental standards including the UN Guiding Principles on Business and Human Rights, the ILO Declaration, and the OECD Guidelines. Policies cover own workforce through the Code of Ethics, Human Resources Policy, Personal Data Protection Policy, OHS Policy (based on ISO 45001, though uncertified), Diversity Policy, and Minors Protection Policy, plus Work Rules, Remuneration Rules, and Equal Treatment, Non-Discrimination and Anti-Harassment Rules. Only one material impact, related to working conditions and equal treatment, was identified in 2024.

Reference: page 264

Responsibility for engaging with employees lies directly with middle and senior managers in charge of respective organisational units. In day-to-day operations, emphasis is placed on effective work organisation, ensuring employee safety and well-being, maintaining open communication with teams, and continuously assessing employment conditions. Employee engagement is generally conducted directly, with involvement of employee representatives where required, for instance during consultations on the Work Rules with trade unions. Employee feedback is used to inform management decisions on a day-to-day basis.

Reference: page 264

The CCC Group provides multiple channels for raising concerns that are accessible to all employees. Employees receive periodic updates about these channels through email communications and the intranet. Details about the channels available to employees are provided in section 15.4. Reporting via these channels is always anonymous. In 2024, the Group did not assess the effectiveness of the channel nor conduct an analysis of user feedback. Four whistleblowing channels are available: a dedicated online platform, a dedicated email inbox, traditional mail, and a contact form.

Reference: page 265

Actions cover working conditions, secure employment, occupational health and safety, equity and diversity, personal data protection, cybersecurity, social dialogue, and training. The Group aims to reduce the Gender Pay Gap Ratio to 5% and the Glass Ceiling Ratio to 5 p.p. In FY2024, all employees were required to familiarise themselves with the Diversity Policy via e-learning, and 61% of employees received diversity training. Permanent contracts accounted for 65.5% of all contracts in 2023. Remedial actions include internal investigations, disciplinary action, and referral to law enforcement. In 2024 activities did not require significant financial investment, and no measures were taken to mitigate workforce effects from the green transition.

Reference: page 271

Targets related to HR policy and human resource management are outlined in the CCC Group's Sustainability Strategy and verified by an independent external adviser, aligned with the SDGs. The 2025 targets include: attain zero work-related accidents among CCC Group employees, reduce the Glass Ceiling Ratio (GCR) to 5 p.p., provide diversity training to all employees, and reduce the Gender Pay Gap Ratio (GPGR) to 5%. Targets are set in coordination with relevant business units. Employees or their representatives are involved in target-setting through satisfaction surveys. Targets are monitored regularly and are comparable year over year and against the 2019 baseline.

Reference: page 271

At end of 2024 the CCC Group had 15,704 employees under employment contracts (15,478 in 2023, +1.46%), with 96.67% within the European Economic Area and 69.66% in Poland. Women made up 86.42% of the workforce (13,571 women, 2,133 men). Permanent contracts covered 64.17% of employees (10,078 permanent, 5,609 temporary, 17 non-guaranteed hours). Full-time employees numbered 8,411 and part-time 7,293. By region, 15,615 were in Central and Eastern Europe including Poland and 89 in Western Europe. During the period 8,054 employees left, a turnover rate of 51.29% (down from 55.94%). Headcount data is as at 31 January 2025.

Reference: page 275

As at 31 January 2024, 3,246 individuals worked with the CCC Group under arrangements other than employment contracts in 2024, including 2,124 women and 1,122 men. The majority, 62.57%, were engaged via temporary employment agencies. Individuals working under civil-law contracts (contracts of mandate, piece-work contracts, and management contracts) accounted for 30.71%, while 6.72% worked under business-to-business (B2B) contracts. By count, 997 worked under civil-law contracts, 218 under B2B, and 2,031 via temporary employment agencies.

Reference: page 276

In 2024, the number of employees covered by collective bargaining agreements was 862, or 5.49% of the total workforce. More than 90% of employees based in Poland are represented by employee representatives. Dialogue between employees and the company is facilitated by employees' freedom of association, as outlined in the Work Rules. Collective bargaining coverage for employees in the EEA falls in the 0-19% band (Poland), while workplace representation for employees in the EEA falls in the 80-100% band (Poland). The Group has not established any agreements for representation by a European Works Council, SE Works Council, or SCE Works Council.

Reference: page 277

The workforce is divided into senior management, managers, and other employees. In 2024 women represented 36.17% of the 47 senior management, 87.52% of the 2,708 managers, and 86.37% of the 12,949 other employees. At top management level (senior management plus Management Board members), 17 of 47 were women (36.17%) and 30 were men (63.83%). By age, the predominant group was 30-50 years at 47.8% of employees, followed by under 30 years at 45.8%, with 6.4% over 50 years old.

Reference: page 278

In 2024, 100% of all employees under employment contracts received remuneration above the defined adequate wage threshold. The CCC Group defines an adequate wage as one that enables employees and their families to satisfy their basic needs in the context of national economic and social conditions. The benchmark for adequate wages has been set at the level of the national minimum wage.

Reference: page 278

All employees of the CCC Group benefit from social protection programmes provided by the countries where the Group's companies operate. These countries offer various forms of support, including coverage for illness, unemployment, work-related injuries, parental leave, and retirement. Additionally, CCC S.A., CCC.eu Sp. z o.o., HalfPrice Sp. z o.o., and MODIVO S.A. maintain an Employee Benefits Fund to assist employees facing challenging life, family, or financial situations, including those affected by unforeseen events such as severe or chronic illnesses, accidents, or the loss of a close family member.

Reference: page 278

Persons with disabilities providing work under employment contracts accounted for 3.02% of total employees under employment contracts in 2024, up from 2.96% in 2023, a change of 0.06 percentage points year on year.

Reference: page 279

In 2024, the average number of training hours per employee under an employment contract was 9.45 hours for women and 12.69 hours for men. For associates under other arrangements, the average was 3.50 hours for women and 1.62 hours for men. The Group conducted 4,680 career development reviews with women and 399 with men. Among employees who participated in reviews, 29.80% were women and 2.54% were men. Completed-to-scheduled review ratios were 1.00 for senior management and other employees, and 0.96 for managers.

Reference: page 281

In 2024 a total of 63 work-related accidents were recorded among employees under employment contracts (51 minor, 12 major, 0 fatal), up 6.78% from 59 in 2023. Among associates under other arrangements, one minor incident was reported. No accidents involved on-site subcontractors. The workplace accident rate was 3.32 for employees and 0.69 for associates. No cases of work-related ill health were recorded in 2024. Days lost to accidents fell to 682 from 1,275. All 15,704 employees and 2,552 associates were covered by the health and safety management system, though none under a certified and audited system.

Reference: page 283

In 2024, 100% of employees under employment contracts (both women and men) were entitled to take family-related leave, unchanged from 2023. The percentage of entitled employees who took family-related leave was 6.65% for women (down from 7.29%) and 1.08% for men (up from 0.51%). All employees entitled to leave under national legislation are considered eligible and authorised to take such leave.

Reference: page 284

In 2024 the unadjusted Gender Pay Gap for the CCC Group was 28.9%, a decrease of 4.32 p.p. from 33.22% in 2023, calculated for employees under employment contracts using the ESRS formula. The CEO Pay Ratio, the ratio between the highest paid individual's remuneration and the median, was 34.87 in 2024, up 146.6% from 14.14 in 2023. The Glass Ceiling Ratio was 50.25 p.p. for senior management (down 1.71 p.p.) and 1.10 p.p. for managers (down 0.02 p.p.). Women represent 36.17% of senior management and 87.52% of managers.

Reference: page 285

In 2024, a total of 36 reports were submitted through internal whistleblowing channels, primarily concerning inappropriate behaviour by management staff and irregularities in business relations. Following investigations, no instances of workplace bullying or discrimination were identified, and recommendations were issued including development of team communication principles and clearer division of responsibilities. No reports of severe human rights incidents were recorded in 2024, and no reports were filed with National Contact Points for the OECD Guidelines. The total amount of fines, penalties, and compensation for damages resulting from incidents and grievances or complaints in 2024 amounted to PLN 0.

Reference: page 288

The Supplier Code of Conduct is the guiding policy for managing material impacts on value chain workers. It sets standards for suppliers on human rights, labour rights, environmental protection, and business integrity, covering the prohibition of child and forced labour, non-discrimination and diversity, occupational health and safety, fair working hours, fair pay, and the right to unionise, as well as anti-corruption, data protection, and information security. It is based on international standards including the Universal Declaration of Human Rights, the UN Global Compact, ILO Conventions, OECD Guidelines, and the UN Guiding Principles. The Code applies across the entire CCC Group, and the Compliance Officer oversees handling of reported violations. Since 2019, purchase terms have included human rights clauses.

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The CCC Group does not directly collect feedback from workers in its value chain. Communication takes place through supplier representatives, who maintain relationships and exchange information on behalf of workers. Engagement activities include involving suppliers in updating the Supplier Code of Conduct, where feedback was gathered on definitions, requirements, and interpretation of key provisions, and participation in the materiality assessment, where value chain representatives including suppliers shared views through surveys and interviews that directly influenced the final outcomes. Internal and third-party audits form part of ongoing monitoring of supplier cooperation. The Group has not entered into agreements with global trade union federations regarding respect for the human rights of value chain workers.

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To eliminate or mitigate adverse impacts, the CCC Group actively manages risks, conducts regular risk assessments, performs ongoing monitoring and audits, applies sustainability criteria including ethics and human rights in supplier evaluation (since 2022), and handles grievances within its existing whistleblowing system. Suppliers can report concerns or violations of the Code of Conduct to etyka@ccc.eu, and an online contact form is available to everyone regardless of affiliation. CCC does not verify whether suppliers inform their employees of this option. All submissions are followed up, and to date there have been no reports from supplier employees. A policy safeguarding individuals against retaliation is set out in the Whistleblowing Procedure.

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The CCC Group requires suppliers to respect human rights and ethical standards, including prohibiting child and forced labour, ensuring a safe environment free from discrimination and harassment, fair working hours and pay, data protection, and the right to unionise, with a zero-tolerance stance on corruption. Supplier monitoring tools include third-party social and environmental audits, permanent CCC staff stationed in key Asian factories (currently India and Bangladesh), and regular Product Department visits. In 2024, suppliers held 457 social, quality, and environmental certificates (including LWG GOLD, ISO 14001, FSC, GRS, SA 8000:2014, ISO 45001), of which 378 (83%) were verified through audits. Where irregularities are found, corrective and preventive measures are applied. No severe human rights incidents were reported in 2024.

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Targets related to managing material impacts, risks, and opportunities for value chain workers apply to all stages of the value chain. They include: 100% of suppliers to be covered by the updated Supplier Code of Conduct by 2025; 100% of high-risk suppliers to undergo audits by 2025; engaging Tier 1 suppliers to provide non-financial data; and 100% of violation reports to be examined by 2025. In 2024, the targets, along with their underlying assumptions and methodology, remained unchanged. The CCC Group has not yet engaged or collaborated with value chain workers in the process of defining and setting these strategic targets.

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The CCC Group currently has no dedicated policy to directly manage impacts on affected communities. However, the Code of Conduct does encompass principles related to communities, including commitments for suppliers to manage water and wastewater responsibly, practice circular resource management, minimise waste, and ensure proper handling of chemicals. All principles relating to human rights and ethical business conduct for suppliers are set out in the Supplier Code of Conduct, which adheres to recognised international guidelines. A dedicated Human Rights Policy is currently under development and scheduled for implementation in 2025, following preparatory steps including a Human Rights Impact Assessment that commenced in 2024. In 2024 there were no cases of non-compliance with the UN Guiding Principles, ILO Declaration, or OECD Guidelines.

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The CCC Group reports that affected communities primarily include those living near its factories, communities around areas used for animal husbandry and crop cultivation that provide natural resources for footwear and clothing, and communities near the Group's head office and logistics centres. Most affected populations are located in Asian countries, with a smaller proportion in Europe, and they include indigenous peoples. The Group does not describe a dedicated process for engaging directly with affected communities about impacts. To better understand impacts on human rights throughout the supply chain, the CCC Group initiated a Human Rights Impact Assessment project in 2024. Local communities were identified as a material topic in the 2024 materiality assessment, with one potential negative impact on local communities identified.

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The CCC Group does not describe a dedicated process or grievance channel specifically for affected communities to raise concerns. Human rights and ethical conduct for suppliers are governed by the Supplier Code of Conduct, and a Human Rights Policy is under development for implementation in 2025, following the Human Rights Impact Assessment that commenced in 2024. The Group reports that in 2024 it did not take any actions aimed at local communities in the value chain, and no human rights incidents related to affected communities were reported in 2024. There were also no cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration, or the OECD Guidelines in 2024.

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In 2024, the CCC Group did not take any actions aimed at local communities in the value chain. No human rights incidents related to affected communities were reported in 2024. The Group indirectly impacts local communities, including indigenous populations, through collaboration with suppliers located outside the European Union, which may involve social and economic challenges relating to human rights and local cultural conditions. In response to these risks, the Group initiated a Human Rights Impact Assessment project in 2024 to gain a deeper understanding of its operations' impact on human rights throughout the entire supply chain. No material risks or opportunities related to affected communities were identified in 2024.

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The CCC Group has not established specific targets directly related to affected communities. The disclosure indicates that work in this area is at an early stage, with a dedicated Human Rights Policy under development and scheduled for implementation in 2025, following the completion of preparatory steps including the Human Rights Impact Assessment that commenced in 2024. No quantified targets, baselines, or timelines for managing negative impacts, advancing positive impacts, or managing material risks and opportunities for affected communities are reported for 2024.

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Customer rights derive from Consumer Law, supported by an Advertising Code of Ethics, a Privacy Policy, complaints and returns rules, website rules, and the CCC Club loyalty programme rules. The Advertising Code of Ethics safeguards recipients against misleading and unethical advertising, prohibiting discrimination, violence, abuse of trust, and violation of human dignity. The Privacy Policy protects customers' personal data in compliance with GDPR and other legislation across online and offline operations, aligned with the Universal Declaration of Human Rights and OECD Guidelines. Ultimate responsibility rests with the Management Board, supported by a Data Protection Officer. No data breaches were identified in 2024.

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Every materiality assessment or stakeholder dialogue has historically included a consumer representative, typically from the Advertising Ethics Board, with customer insights informing the Group's strategic focus and ESG reporting scope. The CCC Group actively engages with customers through market research, internal analyses, and the Customer Service Office to understand their needs and expectations. The Group does not collect feedback from customers who may be particularly vulnerable to impacts. Marketing communication follows Advertising Code of Ethics principles, requiring advertising to be clear, not misleading, and protective of children and youth. No instances of non-compliance in marketing communications were identified in 2024.

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Consumer complaint procedures aim to resolve disputes fairly and promptly without undue cost. Customers can reach local Customer Service Office teams via helpline, email, electronic form, and chatbot, with WhatsApp and chatbot added in 2024. Complaints on offline purchases can be submitted at any store; online complaints via the website or stores in Poland. CCC S.A. agrees to out-of-court dispute settlement and has implemented a permanent Net Promoter Score survey after online orders. A Whistleblowing Procedure protects consumers from retaliation. The Group seeks to respond within 48 hours. In 2024 nearly 180,000 emails and approximately 228,000 telephone calls were received.

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Key actions cover cybersecurity and personal data protection, customer communication, and product safety. Data protection measures include encryption, a Web Application Firewall, secure password hashing, HTTPS, penetration testing, annual reviews, and employee training, with incident response that notifies affected individuals and resets passwords. The weCare initiative, running since 2022, raises awareness of sustainable choices through labels in offline and online stores and the Give Your Shoes a Second Life collection programme. Product safety relies on a two-stage quality control process and chemical safety testing in accredited laboratories under the Supplier Code of Conduct. Natural fur is prohibited. In 2024 no safety irregularities were identified by regulators.

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The targets relating to consumers are aligned with the nature of the products offered: 100% of products to include information on materials used and production methods (base year 2019), and 100% of product categories to include sustainable collections (base year 2019). These targets reflect the Group's commitment to transparent product information. Although they address environmental considerations, they are not science-based. No changes were made to these targets in 2024, and progress is monitored using data on products and communication methods, including appropriate labelling. Consumers and end-users are not directly involved in setting or monitoring targets, though their representatives contribute to materiality assessments.

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The CCC Group maintains business conduct through a set of policies covering own operations and the value chain. Key documents include the Code of Ethics, Anti-Corruption Code (in effect since 2018), Equal Treatment, Non-Discrimination and Anti-Harassment Rules, Compliance Policy, Conflict of Interest Policy (based on ISO 37001, not certified), Procurement Policy, Supplier Code of Conduct and Whistleblowing Procedure. The Code of Ethics applies to all individuals working for the Group regardless of employment form and is overseen by the Ethics Officer supported by the Compliance Officer. A Whistleblowing Procedure offers anonymous reporting channels, whistleblower protection and prohibits retaliation. Organisational culture rests on customer focus, innovation, responsibility and respect, with mandatory ethics e-learning.

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The CCC Group Supplier Code of Conduct governs all ESG issues in the supply chain, setting standards for suppliers on human rights, labour rights, environmental protection and business integrity. Suppliers must prohibit child and forced labour, provide a safe and non-discriminatory work environment, uphold freedom of association, ensure fair wages and working hours, and protect personal data. They are also required to implement environmental due diligence covering water management, animal welfare and chemical usage. Supply chain management includes audits, monitoring and evaluation. Due diligence is integrated into procurement decisions and documents such as the Procurement Policy (established 2022), General Terms and Conditions of Purchase, Supplier Code of Conduct compliance declarations, and supplier contracts.

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The CCC Group has a zero-tolerance approach to corruption. The Anti-Corruption Code, alongside the Code of Ethics and Whistleblowing Procedure, sets standards to prevent corrupt practices; no separate policy is required. Areas most vulnerable to corruption and bribery are procurement, investments and development. Employees must promptly report actual or suspected incidents through dedicated communication channels, and reports are investigated by the Compliance Officer or Ethics Officer, with the Management or Supervisory Board able to appoint a committee. A non-retaliation policy protects whistleblowers. Mandatory anti-corruption e-learning targets 100% of employees annually. In 2024, 61.97% of individuals identified as at risk (9,731 people) were covered by anti-corruption and anti-bribery training.

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In 2024, the CCC Group reported no incidents of corruption or bribery and no public legal cases regarding corruption or bribery. There were no convictions or fines for violation of anti-corruption and anti-bribery laws, and no breaches in anti-corruption and anti-bribery procedures and standards. There were no confirmed incidents resulting in the dismissal or disciplinary action against Group employees due to corruption or bribery-related incidents, and no confirmed incidents related to contracts with business partners that were terminated or not renewed due to corruption or bribery violations. The number of confirmed incidents during the reporting period was therefore zero.

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The CCC Group lists Political influence and lobbying activities (G1-5) within section 15.4 of its Sustainability Statement governance disclosures. The body of the business conduct section (G1) does not provide substantive disclosure of political contributions, lobbying expenditure or a specific lobbying stance. The Group's overall governance framework rests on its Code of Ethics, Anti-Corruption Code, Compliance Policy and Conflict of Interest Policy, which set ethical standards of conduct, prohibit corrupt practices and require transparent business dealings. No figures for political donations or lobbying activities are stated in the source text for this disclosure.

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The average time the CCC Group takes to settle an invoice from the start of the contractual or statutory payment term is up to 180 days, reflecting the standard payment terms applied, which primarily concern the supply of merchandise. Payment terms for non-merchandise goods typically range from 60 to 180 days. During the reporting period, no legal proceedings related to late payment were initiated. The Group has no formal late-payment policy, but an implemented cost processing procedure governs the flow of cost documents and deadlines. The Group uses reverse factoring, under which the factor bank settles supplier invoices within seven business days, with the Group repaying the factor within the original invoice payment term.