CD PROJEKT

The role of the administrative, management and supervisory bodies

Management Board

Composition of the Management Board as of 31 December 2024

The Management Board consisted of 6 executive members:

*Until 31.12.2024

The Management Board is guided by principles listed in 2021 Code of Best Practice for WSE Listed Companies.

Supervisory Board

Composition of the Supervisory Board as of 31 December 2024

The Supervisory Board consisted of 5 members:

*Until 31.12.2024

Independence: In 2024 two members of the Supervisory Board – Michał Bień and Jan Łukasz Wejchert – met independence criteria specified in the Auditor Act, and had no actual and material links to any shareholder controlling at least 5% of the total number of votes at the Company.

Percentage of independent members: 40% (2 out of 5 members)

Changes in 2024:

On 17 October 2024:

• Mr. Adam Kiciński notified members of the Supervisory Board of his resignation from membership of the Management Board, effective at the end of 2024, along with his intent to seek appointment to the Supervisory Board
• Four Supervisory Board members submitted their resignation effective at the end of day on 31 December 2024:
  • Ms. Katarzyna Szwarc (Vice-Chair and Member)
  • Mr. Michał Bień (Member and Chair of Audit Committee)
  • Mr. Maciej Nielubowicz (Secretary and Member and Member of Audit Committee)
  • Mr. Jan Łukasz Wejchert (Member and Member of Audit Committee)

On 28 November 2024, the General Meeting adopted resolutions:

• Dismissal (effective at end of day on 31 December 2024) and reappointment (effective on 1 January 2025) of Mr. Marcin Iwiński as Member of the Supervisory Board
• Appointment of Ms. Beata Cichocka-Tylman, Mr. David Gardner, Mr. Adam Kiciński and Ms. Agnieszka Słomka-Gołębiowska

Committees

Audit Committee

The Audit Committee operated throughout 2024. Five meetings of the Audit Committee took place in 2024.

Duties related to sustainability:

• Monitoring the effectiveness of risk management systems as relates to sustainability
• Monitoring sustainability disclosures

Sustainability expertise: One of the members of the Audit Committee possesses professional knowledge in matters related to sustainability.

Sustainability governance structure

Management Board level:

• The CFO (Chief Financial Officer – Member of the Board) has oversight of sustainability disclosures
• Management of impact, risks and opportunities in individual areas of sustainability is performed by the appropriate Members of the Management Board, as determined by their respective responsibilities

ESG Management Group:

• Appointed by the Management Board in 2023
• Consists of top managers
• Members assigned specific duties related to managing organizational impact in their respective areas of responsibility – including setting goals and managing risks with regard to key aspects of sustainability

ESG Team:

• Operating since 2022 in the framework of the Investor Relations Department
• Manager holds periodic meetings with the CFO to report on:
  • Implementation of goals related to specific areas of sustainability
  • Company's activities aiming at ensuring that disclosures provided by the CD PROJEKT Group are consistent with the applicable regulations

Goal-setting and monitoring process:

• Specific goals related to key impact, risks and opportunities are drafted by members of the ESG Management Group
• Goals submitted to the Management Board for approval in the first quarter of each year
• Monitoring implementation is the responsibility of the ESG Team
• Status update meetings with members of the ESG Management Group responsible for each goal are held after the close of each quarterly period
• Status of implementation of goals is presented to the CFO and to the Audit Committee following the close of the given financial year

Sustainability discussions and expertise

Frequency of sustainability discussions:

Members of the Management Board discuss matters related to sustainability at meetings with representatives of departments charged with managing these matters. In 2024 such meetings concerned various aspects of the Company's activities, including:

• Outcomes of workforce engagement surveys
• Employment
• Establishment of business relations
• New technologies (including AI)
• IT security

Training and external advice:

• Members of the Supervisory Board and of the Management Board may solicit external advice in implementing specific sustainability-related projects
• The governing bodies of the Company have access to a knowledge base maintained by the Polish Association of Listed Companies, which includes summaries, reports, training materials and conference materials
• ESG Team members provide regular updates to the governing bodies of the Company regarding legislative changes and best practices related to sustainability management and sustainability disclosures
• Members of the ESG Team participate in external training courses and topical conferences
• Where required, seek external support in implementing specific projects

Integration of sustainability-related performance in incentive schemes

Statement on sustainability linkage

In 2024 the variable remuneration paid out to members of Company bodies under the CD PROJEKT S.A. Remuneration Policy was not directly tied to achievement of sustainability goals, including the GHG emissions reduction goal.

Remuneration paid out to members of the Management Board during the financial year was not directly tied to achievement of sustainability goals.

Remuneration paid out to members of the Supervisory Board in 2024 was not directly tied to achievement of sustainability goals.

Long-term incentive schemes

Incentive Program B for 2023–2027

On 18 April 2023 the General Meeting adopted resolutions introducing Incentive Program B for the years 2023-2027, which (along with the accompanying Incentive Program A) superseded the above-mentioned Incentive Program for 2020-2025. Entitlements corresponding to the first stage of Incentive Program B were assigned to members of the Company's Management Board on 26 May 2023, while entitlements corresponding to the second stage of the program were assigned on 8 March 2024.

First stage of Incentive Program B (tranche for 2023-2026)

Number of entitlements and value of potential benefits (in PLN thousands) assigned to members of the Management Board at the first stage of Incentive Program B:

Second stage of Incentive Program B (tranche for 2024-2027)

Number of entitlements and value of potential benefits (in PLN thousands) assigned to members of the Management Board at the second stage of Incentive Program B:

The potential benefits listed in the above table for entitlements assigned at the first and second stage of the share-based Incentive Program B to members of the Management Board reflect the fair value of the corresponding entitlements, based on an actuarial assessment valid on the date of assignment. Information concerning assumptions made by the actuary in preparing the assessment of entitlements can be found in the Consolidated Financial Statement of the CD PROJEKT Group for 2024. The listed value corresponds to costs recognized in 2023 and 2024 in association with estimation of entitlements assigned under Incentive Program B and does not include costs associated with estimation of expired entitlements assigned under the preceding program.

The difference between the market price of CD PROJEKT shares on any given date and the corresponding take-up or purchase price for shares acquired in the framework of Incentive Program B may differ significantly from the assessment provided by the actuary on the date of assignment of entitlements and recognized in the Group's statement of costs. Moreover, future benefits which may potentially be obtained by participants of the program depend on fulfilling a range of goals and conditions applicable to the program, and also on the future price of shares at the moment such shares are taken up or purchased by the entitled parties. With regard to entitlements assigned at the first and second stage of Incentive Program B, the base purchase or take-up price of shares acquired by entitled parties (given fulfillment of the program goals and criteria) is 118.05 PLN and 107.75 PLN respectively.

Participation by Supervisory Board members

Persons who held membership of the Supervisory Board in 2024 did not participate in Incentive Programs A and B for 2023-2027.

In the framework of its strategy adopted in 2022 (see the Strategy Update), in the coming years the Studio intends to focus on:

1. Creating revolutionary role-playing games, by developing and publishing the following releases: ■ A new Witcher trilogy, the first installment of which is The Witcher 4 (previously codenamed Polaris); ■ Project Orion – the second game set in the Cyberpunk universe; ■ Project Sirius – a game with multiplayer features set in The Witcher universe; ■ The Witcher Remake – a retelling of the first part of The Witcher, developed with the use of modern technologies, in collaboration with Fool's Theory.

In addition, CD PROJEKT RED is carrying out conceptual work on the third proprietary IP codenamed Hadar.

1. Implementing the franchise flywheel concept, which involves developing an ecosystem of mutually supporting products, rooted in the potential of the Studio's franchises. The Group has announced its openness to collaboration with various external partners in order to create new ways to interact with its franchises. In the framework of the Cyberpunk universe, the Company is involved, among others, in animation and live action projects.

2. Further enrichment of our franchise ecosystem with games offering multiplayer features. In addition to flagship projects listed in the Strategy Update, the Studio also engages in work on other unannounced projects which augment the franchise flywheel concept. These include game projects, along with various initiatives which match the broad definition of digital entertainment and will be publicly revealed once the Company has verified its commercial potential or launched the corresponding information campaigns.

Achieving the Group's ambitious business goals depends, among others, on its commitment to increasing team engagement by shaping a robust, healthy organizational culture based on mutual respect and observance of legal and ethical standards while promoting continuous talent development. Our initiatives, rooted in the so-called five ambitions, support our plan to ensure sustainability at the CD PROJEKT Group and contribute to long-term increases in its value.

Key products and business model

Videogame development commenced in 2002 and initially focused on the studio's RPG debut: The Witcher. This game, set in Andrzej Sapkowski's fantasy world, was released in October 2007.

The Studio's key product portfolio currently includes the following videogames: ■ The Witcher; ■ The Witcher 2: Assassins of Kings; ■ The Witcher 3: Wild Hunt with two expansion packs – Hearts of Stone and Blood and Wine; ■ Cyberpunk 2077 with its expansion pack – Phantom Liberty.

Sales of CD PROJEKT RED games are carried out under the following core business models: ■ sales of territorial distribution rights (for box and digital editions), settled post factum on the basis of monthly or quarterly sales reports / licensing reports submitted by the Company's business partners; ■ supplies of physical box editions to the Company's business partners for retail resale; ■ sales of batches of activation codes which permit the game to be downloaded and installed; ■ sales carried out through optional microtransactions in GWENT: The Witcher Card Game.

Digital distribution agreements concluded by the Company are typically settled in monthly cycles, while distribution of physical videogame editions follows quarterly reporting cycles. Depending on the specific partner or contract, the Company also collects licensing reports – these are submitted 30, 45 or 60 days following the end of each reporting period (typically each month or quarter).

Key suppliers and clients in the value chain

Development of large-scale RPGs is a process which involves collaboration with dozens of companies – this includes typical B2B relationships as well as contractual arrangements with representatives of the creative industry and artists from around the world. Thus, our business partners include actors, musicians, graphic artists, writers and translators, as well as – among others – videogame distributors, manufacturers of gaming consoles and computer hardware, developers of software, technologies and game engines, external studios (e.g. audio and motion capture) or providers of streaming services.

In 2024 CD PROJEKT RED sales to two clients – Valve Corporation and Sony Interactive Entertainment – exceeded 10% of the Group's consolidated sales revenues and totaled 395 746 thousand PLN and 181 562 thousand PLN respectively (40.2% and 18.4% of the Group's sales revenues respectively). These clients are not affiliated with CD PROJEKT S.A. or any of its subsidiaries. No other client accounted for more than 10% of consolidated sales revenues of the CD PROJEKT Group.

The videogame development process relies on certain bought-in tools and technical solutions; however, these do not result in significant concentration of supply. No CD PROJEKT RED supplier accounted for more than 10% of the segment's total revenues in 2024.

Interests and views of stakeholders

General approach

Dialogue is important to us. We want to be transparent with stakeholders in current matters related to the Group's business, and also receive feedback on our products and other business activities. Stakeholder opinions are taken into account in the CD PROJEKT Group's sustainability management process. At periodic meetings with representatives of departments whose responsibilities include matters related to sustainability, Management Board members receive information of issues regarded as important by the Company's stakeholders – which includes employees, gamers, business partners, investors and analysts. Examples of such feedback include conclusions from Culture Amp surveys.

The list of key stakeholder groups with which we most frequently interact – updated during our 2023 double materiality assessment – is presented below.

Key stakeholder groups and engagement channels

Own workforce

The Group's greatest strength and value are rooted in members of our team. Their talent, commitment and motivation make up the CD PROJEKT Group's human capital. They and their creative ideas drive the success of our company. Aware of their importance, we strive to build a safe work environment, emphasize career development, and instill a sense of agency and responsibility among our team members. The voice of the team is important to us – which is why we undertake numerous initiatives to foster a feedback culture, encouraging team members to ask questions and share their opinions. We also build engagement by carrying out open, transparent and internal communication.

In 2022 we rolled out the Culture Amp tool for measuring team engagement. This helps us keep track of the condition of our organization and implement – in collaboration with internal teams – solutions which address the issues and shortcomings identified by our team members.

In 2021 the Company appointed RED Teams Representatives (RTR). RTR is an advisory body to the CD PROJEKT Management Board, which represents the interests of those employed at CD PROJEKT. RTR are elected from among all team members and constitute a representative body which advises the CD PROJEKT Management Board. The main role of RTR is to identify organizational threats requiring corrective action, propose solutions and implement them in collaboration with the Management Board.

In 2023 a company committee was established at CD PROJEKT in the framework of one of Poland's nationwide trade unions. This committee was later transformed into an inter-company committee. The committee operates independently of RTR. The Company acknowledges both bodies, and the goal of its cooperation with each of them is to ensure a balance between the interests of employees and organizational efficiency, thus promoting equitable and smooth development.

In 2023 employees and RTR took part in a double materiality assessment.

Consumers and end-users

"Always remember about gamers" is one of our core values which guide us in our daily work as we develop top-quality products, decide on pricing or provide services and customer support. We believe in building strong, long-term relations with the gaming community gathered around our products – whether games or tie-in products based on our proprietary IPs.

At CD PROJEKT we emphasize open, transparent communication. We engage with gamers in eleven languages (English, Polish, Russian, German, French, Spanish, Japanese, Brazilian Portuguese, Korean, simplified Chinese and traditional Chinese). We also have a presence on all top social media platforms such as Facebook, X, Twitch and TikTok, and on their regional counterparts – e.g. Bilibili in China or NaverCafe in Korea. Numerous direct communication channels, coupled with their global reach, enable us to better understand the expectations and opinions voiced by our community.

We pay attention to suggestions and comments received from gamers. Some of them are taken into account when making business decisions, e.g. rolling out further upgrades to existing games or charting future development plans for specific franchises or products. Community representatives have also taken part in a double materiality survey conducted at the CD PROJEKT Group in 2023.

At GOG we communicate with platform users via social media where everyone may react to our posts and provide their own opinions and comments. GOG team members often follow up on these, engaging in discussions in order to better understand user feedback or provide on-the-spot technical support. GOG also communicates with users in a similar manner on discussion forums, on its website and on the Reddit platform.

GOG carries out inclusive, active communication with the gaming community, analyzing feedback and replying to questions and comments. On popular communication fora (which include the GOG forum, dedicated Discord servers, a Twitch channel, Reddit and top social media platforms) team members moderate discussions and provide backstage peeks at the work going on at GOG. Thanks to its Community Wishlist, GOG is able to find out which games are particularly sought after by platform users and take action to provide access to such games. Moreover, in 2024 GOG rolled out a dedicated communication channel on Discord – "GOG Core Community", to which the most faithful GOG users are successively invited. Invitees receive access to exclusive content such as interviews and platform updates and are able to contact our team members directly.

Integration into strategy and business model

Stakeholder opinions are taken into account in the CD PROJEKT Group's sustainability management process. At periodic meetings with representatives of departments whose responsibilities include matters related to sustainability, Management Board members receive information of issues regarded as important by the Company's stakeholders.

Community representatives and employees took part in the double materiality survey conducted in 2023. Some suggestions and comments received from gamers are taken into account when making business decisions, e.g. rolling out further upgrades to existing games or charting future development plans for specific franchises or products.

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

Risk management process

[ESRS 2 SBM-3]

In 2021 a Risk Management Procedure was introduced at the Company, formalizing methods of managing and mitigating strategic risks. In December 2023 we updated this procedure and begun to apply an enhanced risk management process.

The risk management process in place at the Company permits identification, assessment and analysis of risks, as well as further action in order to achieve an acceptable level of risk given the identified threats, and thereby reduce the likelihood or mitigate the consequences of potential circumstances which may have a negative effect on the activities of the Company, including its financial stability. While identifying strategic risks, we also work to identify opportunities which may ameliorate the circumstances related to risks under analysis, and determine means of handling risks (which may involve acceptance, mitigation, transfer or avoidance of the given risk).

The risk management process involves:

• Managerial staff which bears responsibility for the given areas covered by risks (Risk Owners)
• Persons appointed by the respective Risk Owners to manage given risks on a daily basis (Risk Custodians)
• The Privacy & Compliance team which operates within the framework of the Company's Legal Department

For each risk, a Risk Owner is designated. One Risk Owner may manage multiple risks. Risk management at other member companies of the CD PROJEKT Group is the responsibility of their respective Management Boards.

Each risk identified at the Company is subjected to analysis in order to determine its impact and likelihood of materialization. In determining this likelihood the Company acknowledges existing control systems and their effectiveness, while impact assessment is based on potential consequences for the Company – both financial and otherwise.

We monitor the status of individual risks using Key Risk Indicators (KRIs), defined by Risk Owners individually for threats and opportunities identified within each risk.

The significance of a risk is determined by plotting the product of the likelihood and impact of that risk on the risk value matrix. Following assessment, the Risk Owner decides how to deal with the risk – in a way which is commensurate with its significance.

Risk Owners prepare contingency plans for circumstances when risk indicators exceed the threshold of acceptability. The aim of this process is to ensure that the Group's business model and strategy remain robust in the face of the identified risks.

Significant (strategic) risks

The following risks have been identified as significant for the activities of the CD PROJEKT Group. While due diligence was applied in identifying and describing such risks, in the course of its daily activities the Group may be exposed to new types of risks which it has not heretofore identified.

BUSINESS MODEL RISKS

Risk associated with focusing on a limited number of projects with long investment cycles and unpredictable commercial potential

CD PROJEKT RED focuses on developing multifaceted role-playing games with nonlinear storylines and based on cutting-edge technological solutions. Given the scope of such projects and their development lifecycles which span multiple years, these games – often referred to as "AAA" – require above-average development and marketing budgets, the vast bulk of which must be expended before any revenues are generated by the corresponding project. A hypothetical unsuccessful release of an AAA game may potentially result from e.g. failure to meet gamers' high expectations with regard to quality, gameplay appeal or content, technical issues associated with the game or negative reviews by journalists and market experts. Sales revenues in the wake of an unsuccessful release may be insufficient to recoup prior expenditures on development and promotion of the game.

Double materiality assessment process

Description of the processes to identify and assess material impacts, risks and opportunities [ESRS 2 SBM-3], [ESRS 2 IRO-1]

In 2023 we carried out a survey of material aspects of sustainability, in line with the double materiality principle described in ESRS standards. A wide community of stakeholders, both external and internal, was invited to participate in the survey, which lasted between July and November 2023 and comprised the following stages:

Table 19: Stages of the double materiality assessment

The survey produced a matrix of ESG aspects regarded as potentially material for the CD PROJEKT Group. Each of these was assessed by applying the five-point Likert scale, and subsequently plotted on the matrix, based on aggregate score.

Chart 6: Matrix of material ESG topics for CD PROJEKT Group

1. Player protection
2. Reducing greenhouse gas emissions in the value chain and implementing energy-efficient solutions
3. Transparency of remuneration and diversity on the Management Board
4. Involvement in community initiatives and cooperation with NGOs
5. Sustainable production of packaging and game accessories
6. Reinforcing the DEI culture at CD PROJEKT
7. Transparency in relations with business partners
8. Strengthening inclusive leadership and team members' engagement
9. Cybersecurity and privacy protection of customer data
10. Creating a comfortable working environment and taking care of work-life balance
11. Business ethics
12. Building engaged communities around our products
13. Responsible communication and marketing of our products
14. Implementing accessibility features in our games
15. Offering competitive compensation package and equal career opportunities
16. Management and protection of intellectual property

We decided to treat as material any aspect which received a score of at least 3 on any of the impact and financial materiality scales. In addition, we also decided – despite the non-attainment of the required score threshold – to elevate the materiality of the aspect titled "Reducing greenhouse gas emissions in the value chain and implementing energy-efficient solutions" due to the fact that, much like any business activity, we do have impact on our environment, including the natural environment and the climate. Furthermore, we decided to merge two aspects – "Strengthening the diversity culture at CD PROJEKT" and "Fostering inclusive leadership and engagement of team members" into a single aspect. We regard inclusive leadership as an indispensable component of our diversity and inclusion culture, and the level of engagement will be subject to monitoring as one of the KPIs in this scope.

The double materiality survey revealed 12 material aspects which, in turn, determine the scope of disclosures provided in this Statement.

Material impacts by ESRS topic

Table 20: Materiality assessment – impact of the CD PROJEKT Group

Climate-related risks and opportunities

Description of the processes to identify and assess material climate-related impacts, risks and opportunities [ESRS 2 IRO-1]

At the CD PROJEKT Group our impact on climate change emerges through emissions of greenhouse gases, over 99% of which come from our value chain. Management of climate-related impacts and emissions indicators is presented in sections E1-4 and E1-6, as appropriate.

In order to identify the means by which the CD PROJEKT Group might be affected by climate change, in 2022 we carried out a scenario analysis process, taking into account CD PROJEKT Group's activities in Poland. In the future we intend to expand this analysis to cover the entire value chain.

Climate-related risks and opportunities are assessed in the context of two climate change scenarios:

1. RCP 2.6 – increase in average temperatures by 1.5°C compared to the preindustrial period – in line with the aspirational goal of the Paris Agreement: greater likelihood and scope of transformational risks:

   • attainment of UE emissions reduction goals for 2030 and 2050
   • Poland implements actions intended to achieve climate neutrality by 2050
   • significant increase in emissions-related costs
   • significant increase in energy costs
   • significant increase in ecological awareness among consumers, greater demand for low-emissions products
   • new capabilities and faster-than-ever increase in the efficiency of renewable energy sources

2. RCP 8.5 – maintaining the existing pace of increase in greenhouse gas emissions ("business as usual"); increase in global average temperatures by 4.5°C compared to the preindustrial period, resulting in irreversible destabilization of the Earth's climate; lower likelihood and scope of transformational risks:

   • non-attainment of UE emissions reduction goals for 2030 and 2050
   • Poland fails to meet the climate neutrality goal and significantly diverges therefrom
   • moderate increase in emissions-related costs
   • gradual and moderate increase in energy costs
   • moderate increase in ecological awareness among consumers, greater demand for low-emissions products
   • no new significant capabilities and lower-than-expected increase in the efficiency of renewable energy sources

Climate-related risks and opportunities have been assessed in three separate timeframes:

• short-term perspective – by 2025
• medium-term perspective – 2026-2030 (based on interim EU climate goals – reduction in emissions by 55% by 2030)
• long-term perspective – 2031-2050 (based on long-term climate goals – achieving climate neutrality by 2050)

Our analysis covered 29 physical threats (16 chronic; 13 acute) and 4 transformational threat categories: regulatory, market, technological and reputational. The following summary presents threats which may affect the CD PROJEKT Group irrespective of the likelihood of materialization.

Table 21: Summary of the threats related to climate change

Own workforce - Material impacts, risks and opportunities

[ESRS 2 SBM-3]

The CD PROJEKT Group has impact on its workforce in various ways, including by upholding appropriate employment standards, including attractive salary packages and additional benefits, enabling well-being of team members – among others by providing a safe and comfortable work environment, and offering career and personal development opportunities in the framework of our available development paths. Specific regulations in this regard are included, among others, in Rules of the Game. Business and Ethics Standards at the CD PROJEKT Group.

The following employment-related issues were identified in our double materiality survey:

1. Creating a comfortable working environment and taking care of work-life balance
2. Offering competitive compensation package and equal career opportunities
3. Reinforcing diversity culture at CD PROJEKT, i.a. by fostering inclusive leadership

No risks related to violations of human rights, including child labor, forced labor or human trafficking have been identified at any member company of the CD PROJEKT Group.

With regard to employment, in the framework of our Risk Management Procedure we identify risks related to recruitment, retention of employees and team building. A description of these risks is provided in the section titled "Risk management at the Group" elsewhere in this report. We do not expect the implementation of the plan for transitioning to a low-emissions economy to have a major impact on persons employed at the CD PROJEKT Group.

With regard to employment, we identify, among others, the following opportunities:

1. Increased engagement on the part of our workforce may translate into increased quality of our videogames (which may, in turn, improve their commercial potential) and a low level of voluntary churn (which means reduced recruitment and onboarding costs).
2. Offering competitive employment conditions and equal career advancement opportunities, while caring for the work environment and the work-life balance, may bolster CD PROJEKT's image as an employer of choice for persons considering a career in the gamedev industry.
3. Actions which aim at fostering a work culture rooted in safety and mutual respect enable us to develop immersive games which reflect the diversity of environments and perspectives while addressing important social issues. This, in turn, builds engagement on the part of gamers and entices them to reach for our releases.

In the area of employment we focus on maximizing the positive impact of our organization on our workforce, fully exploiting the identified opportunities, and minimizing the likelihood of materialization of any identified risks. The presented impacts, risks and opportunities apply equally to all team members.

Consumers and end-users - Material impacts, risks and opportunities

[ESRS 2 SBM-3]

At CD PROJEKT RED we believe we can influence the world at large by developing games which enrich gamers' perceptions. This is why we do not shy away from confronting socially important topics in the stories we tell – although we refrain from moralizing and advancing specific viewpoints.

Our games depict social inequalities, the various paths people take through life, and the problems they face. We want to make sure that the characters populating the worlds we create represent a diverse set of mindsets, social groups, and backgrounds. In The Witcher 3: Wild Hunt, we tackle, among others, the issues of domestic violence, strained family relationships, and discrimination. For its part, Cyberpunk 2077 addresses alienation and dehumanization of society. Our products reach millions of people around the world — so we want to focus on what's important and encourage gamers to reflect upon the choices that surround them.

In the scope of gamer relations, we focus on maximizing the positive impact of CD PROJEKT activities on the communities gathered around our releases, and on exploiting the arising business opportunities. We build strong relations with gamers based on ongoing dialogue and responsible marketing communication. We work to expand our communities by enriching our franchises with entertainment products representing formats other than video games. In parallel, we want to entice more gamers to reach for our releases – by adding, insofar as possible, additional accessibility features to existing games. We also localize our games into foreign languages – The Witcher 3: Wild Hunt is now available in 17 language versions, including 9 fully dubbed versions, while Cyberpunk 2077 has 17 language localizations, including 11 fully dubbed releases.

Given our activity profile, we have not thus far identified any negative impact on the gaming community.

The following aspects of community relations have been identified as significant in our double materiality survey:

1. Building engaged communities around our products
2. Implementing accessibility features to our games
3. Responsible communication and marketing of products

Risks and opportunities in the scope of community relations

Under the CD PROJEKT S.A. Risk Management Procedure, with regard to community relations, we have identified a risk titled "Risk of failure to meet expectations resulting from promotional campaigns" described in the section titled "Risk management at the Group" elsewhere in this report.

The identified opportunities in this area include:

• reinforcing engagement on the part of the gaming community gathered around our releases, and expanding the circle of gamers interested in the Studio's games, which may result in increased revenues – for existing as well as future releases
• responsible guiding of gamers' expectations with regard to the Company's products, which may result in positive sentiment around future releases, and, as a result, bolster their sales
• reaching an expanded community of customers with varied accessibility requirements, resulting in increased sales revenues obtained by the Studio

The impact, risks and opportunities identified in the area of community relations apply equally to all end users of our games.

Social engagement - Material impacts, risks and opportunities

[ESRS 2 SBM-3]

The CD PROJEKT Group takes action to positively affect its social environment, instill shared values in our employees, and assist others with our resources and skills. We engage in social projects, national and international charity drives and aid campaigns through knowledge sharing, material donations and financial support. We also carry out projects targeted at the young generation, enabling participants to develop their skills and gain experience in the gaming industry. Our commitments in this regard are enshrined in the business strategy as part of one of our ESG ambitions: "use our resources and competencies to support others".

We regard social engagement as a way to maximize our positive impact on the social environment, and do not identify any potential negative impact or threats in this scope.

Business conduct - Material impacts, risks and opportunities

Description of the processes to identify and assess material impacts, risks and opportunities [ESRS 2 IRO-1]

The following significant aspects related to business conduct were identified in our double materiality survey:

1. Business ethics
2. Transparency in relations with business partners
3. Cybersecurity and privacy protection
4. Management and protection of intellectual property

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

Double Materiality Assessment Process (2023)

In 2023 CD PROJEKT carried out a survey of material aspects of sustainability, in line with the double materiality principle described in ESRS standards. A wide community of stakeholders, both external and internal, was invited to participate in the survey, which lasted between July and November 2023.

Step-by-Step Methodology

The assessment comprised the following stages:

Table 19 - Stages of the double materiality assessment

Inputs to the Assessment

• Internal evaluation workshops
• Analysis of available documentation
• Market benchmark
• Workshop with external experts
• Analysis of gathered materials
• In-depth internal workshops
• Quantitative analysis (surveys targeting team members and gamers)
• In-depth interviews with CFO, Board Member and VP of Finance

Stakeholder Consultation

The list of key stakeholder groups with which CD PROJEKT most frequently interacts was updated during the 2023 double materiality assessment. Stakeholders included:

Internal stakeholders:

• Team members (engaged via meetings, e-mail, surveys, opinion polls, periodic reviews and feedback collection, and whistleblowing mechanism called Speak Up)

External stakeholders:

• Gamers and other customers
• Capital market participants (institutional and retail investors, rating agency analysts including ESG rating agencies, sell-side analysts, buy-side analysts, representatives of capital market institutions and organizations)
• Business partners

Scoring Criteria

Impact Materiality:

• Severity and irreversibility of consequences were assessed through quantitative surveys
• Five-point Likert scale was applied

Financial Materiality:

• Financial and impact scope materiality assessed through in-depth interviews with senior finance leadership
• Five-point Likert scale was applied

Materiality Matrix and Threshold

The survey produced a matrix of ESG aspects regarded as potentially material for the CD PROJEKT Group. Each aspect was assessed by applying the five-point Likert scale, and subsequently plotted on the matrix based on aggregate score.

A cutoff point was determined and approved by the CFO, resulting in a final list of 12 sustainability aspects regarded as material for the CD PROJEKT Group.

Frequency and Last Review

The double materiality assessment was conducted in 2023 (between July and November 2023).

Use of Value Chain Mapping

Value chain mapping was used in the first stage of the assessment through internal evaluation workshops and analysis of available documentation, resulting in a schematic description of the CD PROJEKT Group value chain.

Climate-Related IRO Process

In 2022 CD PROJEKT carried out a scenario analysis process to identify climate-related impacts, risks and opportunities, taking into account CD PROJEKT Group's activities in Poland. In the future the company intends to expand this analysis to cover the entire value chain.

Climate scenario analysis:

• Two climate change scenarios assessed: RCP 2.6 (1.5°C increase) and RCP 8.5 (4.5°C increase)
• Three timeframes: short-term (by 2025), medium-term (2026-2030), long-term (2031-2050)
• Covered 29 physical threats (16 chronic, 13 acute) and 4 transformational threat categories (regulatory, market, technological, reputational)

Material Topics Identified

The following material issues were identified:

Employment:

1. Creating a comfortable working environment and taking care of work-life balance
2. Offering competitive compensation package and equal career opportunities
3. Reinforcing diversity culture at CD PROJEKT, i.a. by fostering inclusive leadership

Business Conduct:

1. Business ethics
2. Transparency in relations with business partners
3. Cybersecurity and privacy protection
4. Management and protection of intellectual property

Policies related to climate change mitigation and adaptation

CD PROJEKT S.A. Environmental Policy

Policy name: CD PROJEKT S.A. Environmental Policy

Adoption and oversight:

• Adopted by the Management Board in 2022
• Climate-related responsibilities supervised by the CFO – Board Member responsible for CD PROJEKT's environmental and climate policy

Key content / principles:

The Policy lists the following pledges:

1. We will roll out and subsequently improve an Eco-Management System consistent with the ISO 14001 standard and the EMAS regulation
2. We will mitigate the impact of our activities on the environment and the climate
3. We will take environmental issues into account when making business decisions

The CD PROJEKT S.A. Environmental Policy and Environmental Statement also contain a range of detailed commitments related to:

• Climate change mitigation and adaptation
• Increasing the energy efficiency of buildings
• Use of renewable energy sources

International standards and guidelines:

• ISO 14001 standard
• EMAS regulation (EcoManagement and Audit Scheme - EU environmental certification system introduced on the basis of Regulation (EC) No 1221/2009)

Public availability:

• The company has an Environmental Statement that provides a comprehensive overview of impact on the environment and the climate, ensuring transparency and equal access to information for all stakeholders
• CD PROJEKT S.A. is registered in the EMAS register with ID PL 2.14-009-98 (confirmation available on websites maintained by the General Directorate for Environmental Protection and the European Commission)

Monitoring implementation:

• In 2023, CD PROJEKT became the first gaming company in the world to obtain an EMAS certificate
• Each year the company submits to an external audit carried out by a licensed environmental auditor to confirm continued compliance with all requirements listed in the EMAS regulation and validate the CD PROJEKT S.A. Environmental Statement
• The company maintains an EMAS eco-management system through which it performs ongoing identification and assessment of aspects of activities, products and services which have, or may have, an impact on the environment
• Climate threats and opportunities were first analyzed in 2022 and are subject to ongoing monitoring and annual reviews supervised by the CFO
• The outcomes of these reviews drive suitable actions involving members of the ESG Management Group, depending on their specific competences

Actions and resources in relation to climate change policies

In 2024 climate-related responsibilities were fulfilled by the following actions:

1. Developing a Decarbonization Plan for the CD PROJEKT Group

• Scope: CD PROJEKT Group operations
• Responsibility: Operations and ESG teams

2. Maintaining EMAS eco-management system

• Description: Ongoing identification and assessment of aspects of activities, products and services which have, or may have, an impact on the environment
• Scope: Own operations
• Responsibility: Operations and ESG teams

3. Changing the supplier of electrical power at the Warsaw campus

• Description: Since 2025 electrical energy will be produced solely from renewable sources
• Scope: Warsaw campus (own operations)
• Time horizon: Implemented from 2025
• Responsibility: Operations and ESG teams

4. Deployment of solar panels

• Description: Solar panels on the rooftop of the office building under construction, plus preparing a plan for similar deployment in the parking structure
• Scope: Own operations (new office building)
• Responsibility: Operations and ESG teams

5. Optimizing use of electrical energy

• Description: Deploying a BMS system in the parking structure
• Scope: Own operations (parking structure)
• Responsibility: Operations and ESG teams

6. Construction of new office building

• Description: Investment pursuant to the technical criteria of the "Adaptation to climate change" objective listed in the "Construction of new buildings" activity section in Commission Delegated Regulation (EU) 2021/2139
• Scope: Own operations
• Resources: Investment expenses will be disclosed as part of taxonomy disclosures once the building is occupied
• Responsibility: Operations and ESG teams

7. Less Emissions campaign (third edition)

• Description: Encouraging employees to use zero-emissions means of commuting to offices
• Scope: Own operations (employee commuting)
• Responsibility: Operations and ESG teams

Resources allocated

• Teams: Operations and ESG teams
• Financial resources: Costs are accounted for in annual financial planning cycles for the corresponding teams. Investment expenses for the new office building will be disclosed as part of taxonomy disclosures once the building is occupied.
• Expected outcome: The reduction effect of most of the above actions will materialize in 2025, estimated at approximately 2,040 tCO2e/year

Link to targets

These actions support the CD PROJEKT Group's target to reduce absolute GHG emissions in Scopes 1 and 2 by 42% by 2030 (compared to 2023 baseline), and are carried out in accordance with the CD PROJEKT Environmental Policy and Environmental Statement.

Targets related to climate change mitigation and adaptation

Scope 1 and 2 GHG Emission Reduction Target

Target:
Reduce absolute GHG emissions at the CD PROJEKT Group in Scopes 1 and 2 by 42% by 2030 (compared to 2023 baseline).

Key characteristics:

• Target type: Absolute reduction target
• Baseline year: 2023
• Target year: 2030
• Scope: Covers the entirety of CD PROJEKT Group operations (100% of emissions at CD PROJEKT S.A., 100% at GOG sp. z o.o., and 100% at CD PROJEKT RED Inc.)
• Greenhouse gases covered: CO₂, CH₄, N₂O, HFCs, PFCs, SF₆, NF₃ (converted to CO₂e per GHG Protocol)
• Science-based: Set in accordance with SBTi methodology and rooted in decisive scientific evidence. Has not been subjected to SBTi validation.
• Measurement: Implementation tracked using market-based (MB) approach for Scope 2 emissions
• Supporting framework: CD PROJEKT Environmental Policy and Decarbonization Plan

Baseline (2023):

• Scope 1: 28 tCO₂e (0.01% of total carbon footprint)
• Scope 2 (market-based): 1,941 tCO₂e (0.57% of total carbon footprint)
• Total Scope 1+2: 1,969 tCO₂e

Target value (2030):

• 827 tCO₂e (combined Scope 1+2)

Progress to date (2024):

• Scope 1: 29 tCO₂e (+4% vs. baseline)
• Scope 2 (market-based): 1,994 tCO₂e (+3% vs. baseline)
• % fulfillment compared to baseline year: 0%

Key decarbonization levers:

• Electrical energy (estimated contribution: 95%) – increasing share of renewable energy, improving energy efficiency, expanding solar panels at Warsaw campus
• Thermal energy (estimated contribution: 5%) – modernizing infrastructure, reducing reliance on heating, deploying intelligent heat management technologies

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Scope 3 Preparatory Target

Goal by 2026:
Prepare assumptions for a long-term reduction target for the value chain by 2050.

Status:
As of the preparation date of this statement, the 2050 emissions reduction goal for the entire value chain has not been set. Preparations began in 2025.

Context:

• Material Scope 3 categories identified:
  • Category 1 (Purchased Goods and Services): ~62% of Scope 3 emissions
  • Category 11 (Use of Sold Products): ~36% of Scope 3 emissions
• Materiality threshold: 5% share in total carbon footprint
• Scope 3 baseline (2023): 330,168 tCO₂e
• Scope 3 (2024): 398,123 tCO₂e (+21% vs. 2023)

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Long-term Alignment

The targets are designed to align with:

• Paris Agreement goal of limiting global warming to 1.5°C
• EU commitment to reduce emissions by 55% by 2030 (compared to 1990 levels)
• EU goal of climate neutrality by 2050

Note: The Decarbonization Plan does not cover Scope 3 emissions reductions. A separate plan will be developed in parallel with setting the Group's future reduction goal for this scope.

Energy consumption and mix

Scope and methodology

The disclosure covers all energy carriers used at the CD PROJEKT Group, including CD PROJEKT S.A. Organizational boundaries are determined by operational control and cover 100% of energy consumption at CD PROJEKT S.A. (the parent entity), 100% at GOG sp. z o.o., and 100% at CD PROJEKT RED Inc.

Greenhouse gas emissions are computed in accordance with the GHG Protocol. For electrical energy, market-based approach coefficients are provided by suppliers; location-based approach uses the average emissions coefficient for Poland published by KOBiZE (National Center for Emissions Management). For thermal energy, intensity coefficients reported for Poland by the Energy Regulatory Office are applied. Fuel-related and refrigerant-related emissions use DEFRA coefficients based on IPCC AR6.

Self-generated renewable energy is produced by solar panels deployed at the CD PROJEKT S.A. campus in Warsaw. In 2024, following upgrades, the solar panels generated 14% more energy than the year before. This energy is fully consumed by CD PROJEKT S.A.

Energy consumption by source (CD PROJEKT Group)

Energy consumption by source (CD PROJEKT S.A.)

Key changes in 2024:

• Total energy consumption at the Group increased by 4% (from 3,771 MWh to 3,910 MWh) due to inclusion of electrical energy consumed by CD PROJEKT RED Inc.
• At CD PROJEKT S.A., total energy consumption increased by 1% (from 3,542 MWh to 3,582 MWh).
• Consumption of petroleum fuels and petroleum products decreased by 93% because no additional fuel was purchased for emergency generators (deployed in Warsaw and Wrocław) which provide backup power to CD PROJEKT S.A. server rooms.
• The amount of renewable energy consumed in 2024 (124 MWh) is equivalent to the electrical energy generated by the company's own solar panels at the Warsaw campus.

Energy intensity

Since CD PROJEKT does not carry out business activities in sectors with significant impact on the climate (as defined by ESRS), energy intensity indicators are not published.

Gross Scopes 1, 2, 3 and Total GHG emissions

Methodology and scope

Greenhouse gas emissions are computed in accordance with the GHG Protocol. The assessment covers greenhouse gases: CO2, CH4, N2O. Estimations of Scope 1 and 2 emissions have been consolidated according to the operational control criterion on the level of the CD PROJEKT Group, accounting for 100% of emissions generated at the analyzed companies. Scope 3 emissions cover the Polish subsidiaries of the CD PROJEKT Group. CD PROJEKT RED Inc., due to the limited scale of its activities, has not reached the materiality threshold and is therefore not included in estimations of Scope 3 emissions for the period.

Scope 1 – Direct GHG emissions at locations owned or supervised by the Group. Covers emissions from combustion of fuels in mobile and static sources, and releases of coolant agents.

Scope 2 – Indirect GHG emissions related to generation of electrical and thermal energy consumed by the Group. Calculated using the market-based approach (based on emissions indicators published by energy suppliers) and the location-based approach (assuming emissions indicators which depend on geographical location – e.g. that of Poland).

Scope 3 – Other indirect GHG emissions not covered in Scopes 1 and 2, occurring anywhere in the value chain.

Fuel-related and refrigerant-related emissions are calculated on the basis of coefficients listed in the DEFRA database, which is based on IPCC's Sixth Assessment Report on Global Warming Potentials (AR6). For thermal energy, intensity coefficients reported for Poland by the Energy Regulatory Office were used. For electrical energy, coefficients provided by suppliers (market-based approach) and the average emissions coefficient for electrical energy in Poland, calculated on the basis of statistics published by KOBiZE (location-based approach) were used. DEFRA and Climatiq coefficients were applied to certain classes of raw materials and services.

For liquid fuels (gasoline and diesel) which contain biocomponents, OOS (outside of scopes) emissions were calculated by applying the appropriate coefficients from the DEFRA database. The resulting OOS emissions were respectively: 1.37 tCO2e in 2021, 0.98 tCO2e in 2022, 1.45 tCO2e in 2023 and 1.62 tCO2e in 2024. OOS emissions are published independently of scopes.

Based on calculations for 2022-2023 covering all Scope 3 categories, the following categories are regarded as material:

• Cat. 1 Purchased Goods and Services (approx. 62% of Scope 3 emissions)
• Cat. 11 Use of Sold Products (approx. 36% of Scope 3 emissions)

The remaining 10 Scope 3 categories (cats 2-9 and 12-13) are regarded as immaterial, since their aggregate share in the Group's total carbon footprint was 1.52% in 2022 and 1.73% in 2023 respectively. Categories 10, 14 and 15 are not applicable to the CD PROJEKT Group.

The materiality threshold for Scope 3 emissions is set at a 5% share of the given category in the CD PROJEKT Group's total carbon footprint.

Organizational boundaries for the reported Scope 1 and 2 GHG emissions are determined by operational control and cover 100% of emissions produced at CD PROJEKT S.A. as the parent entity, 100% of emissions produced at GOG sp. z o.o. and 100% of emissions produced at CD PROJEKT RED Inc.

2023 is the baseline year for Scope 1 and 2 emissions.

CD PROJEKT Group – Scope 1, 2, 3 and Total GHG emissions

*Reduction goal applies to Scopes 1 and 2 combined.

CD PROJEKT S.A. – Scope 1, 2, 3 and Total GHG emissions

GHG intensity

Scope 1 sub-breakdown

Scope 1 emissions at the Group in 2024 were equivalent to 29 tCO2e, which is 4% more than in 2023. This increase in emissions is due to leakage of refrigerant from an air conditioning installation at the CD PROJEKT S.A. campus. These emissions were generated solely at CD PROJEKT S.A.

Scope 1 emissions cover combustion of fuels in mobile and static sources, and releases of coolant agents. No further disaggregation by stationary combustion, mobile combustion, process emissions, or fugitive emissions is provided.

Scope 2 breakdown

Scope 2 GHG emissions at the Group were calculated using the location-based (LB) and market-based (MB) approach. In 2024 the Scope 2 carbon footprint was 1,811 tCO2e (LB) and 1,994 tCO2e (MB) for the CD PROJEKT Group, including 1,623 tCO2e (LB) and 1,785 tCO2e (MB) for CD PROJEKT S.A. respectively. Location-based results are lower than their market-based counterparts which is due to differences in the applied coefficients. In the location-based approach KOBiZE figures were applied, while in the market-based approach figures published by energy suppliers were used. In the case of the main supplier of energy to offices and server room, the value of the corresponding indicator is higher than its KOBiZE counterpart.

Scope 2 GHG emissions at the Group increased by 3% in 2024 when calculated according to the market-based approach, which is due to inclusion of emissions at CD PROJEKT RED Inc., whereas in the location-based approach a decrease by 5% was reported, owing to the greater share of renewable sources in the Polish energy mix in 2024, and the corresponding reduction in Poland's emissions coefficients related to production of energy.

Scope 3 breakdown by category

The Group's Scope 3 carbon footprint in 2024 amounted to 398,123 tCO2e, including 141,516 tCO2e attributable to CD PROJEKT S.A.

Category 1: Purchased goods and services – accounts for 65% of the Group's total carbon footprint. The main drivers of emissions in this category include digital distribution of products on the GOG.COM platform. Category 1 emissions related to services and raw materials purchased by the Group in 2024 were reported at 260,165 tCO2e, which is 25% more than in 2023. The difference is mainly due to increased emissions from GOG's digital distribution in 2024 compared to 2023 figures.

Category 11: Use of sold products – covers emissions from use of products sold by CD PROJEKT, i.e. estimated emissions from consumption of electrical energy required to run our games (Cyberpunk 2077, Phantom Liberty and The Witcher 3: Wild Hunt). Emissions in this category were reported at 137,958 tCO2e, which is 13% more than in 2023. These emissions account for nearly 35% of the Group's total carbon footprint.

Categories 2-9 and 12-13 – regarded as immaterial (aggregate share in the Group's total carbon footprint was 1.52% in 2022 and 1.73% in 2023). Not reported separately for 2024.

Categories 10, 14 and 15 – not applicable to the CD PROJEKT Group.

Summary

In 2024 Scope 1 and 2 emissions accounted for 1% of the total emissions at the CD PROJEKT Group. The vast majority of Scope 1 and 2 GHG emissions (99%) generated by the Group's operating activities falls within Scope 2, i.e. indirect emissions resulting from generation of electrical and thermal energy purchased by the Group. Scope 3 covers 99% of the CD PROJEKT Group's total emissions.

The total carbon footprint of the CD PROJEKT Group in 2024 was 399,963 tCO2e (location-based method) or 400,146 tCO2e (market-based method). CD PROJEKT S.A. accounted for 143,168 tCO2e in LB emissions and 143,330 tCO2e in MB emissions respectively.

GHG removals and GHG mitigation projects financed through carbon credits

No GHG removals or GHG mitigation projects financed through carbon credits were carried out at the CD PROJEKT Group in 2024.

Internal carbon pricing

The CD PROJEKT Group does not apply internal pricing systems for carbon dioxide emissions.

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

Phase-in exemption applied

CD PROJEKT has omitted the following disclosures based on ESRS 1 Appendix C:

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66
• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a)
• ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c)
• ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c)
• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69

Policies related to own workforce

CD PROJEKT has disclosed several policies related to its own workforce:

Work Rules

• Scope: All employees regardless of contract type, position or type of work performed
• Key content: Basic reference for rights and responsibilities shared by employees

Pay Rules

• Key content: Specify the remuneration and any additional benefits for which team members are eligible

Diversity Policy

• Key content: Counteracts all forms of discrimination
• Related initiatives: The company is a signatory of the Diversity Charter – an international initiative bringing together European employers who take action to promote diversity in the workplace
• Related strategy: D&I Strategy explains planned D&I activities

Rules of the Game. Business and Ethics Standards at the CD PROJEKT Group

• Key content: Covers issues such as:

  • Inclusion, health, personal development, equitable workplace conditions and diversity
  • Human rights commitments with regard to employees
  • Detailed description of approach towards counteracting all forms of discrimination
  • Everyone accorded the same rights – regardless of gender, disability, race, religion, background, age, worldview, skin color or sexual orientation

• Specific commitments:

  • No discrimination in the recruitment process – competences and skills are all that counts
  • Objective criteria used when making personnel decisions (e.g. raises, promotions)
  • Organization of webinars and internal training on counteracting discrimination, harassment, mobbing and other forms of undesirable conduct
  • Training for team managers in matters related to inclusive leadership
  • Does not condone any form of forced labor
  • Opposition to all forms of modern slavery, child labor and human trafficking

• Alignment with international standards: Consistent with the UN Universal Declaration of Human Rights and OECD guidelines concerning enterprises and human rights

Occupational Health and Safety (OHS)

• Governance: Managed by the Occupational Health and Safety (OHS) Commission, which provides advice and consultancy for the employer
• OHS Commission mission: Enforcing OHS rules at the workplace; during periodic meetings, members discuss issues related to workplace safety, formulate tips and recommendations for the employer, and apply for solutions which aim to improve workplace safety and comfort

Human Rights Policy

• Key content: Pledges to respect human rights with regard to all social groups affected by the company's activities – including gamers
• Alignment with international standards: Actions are consistent with the UN Universal Declaration of Human Rights and UN Guiding Principles on Business and Human Rights

Taking action on material impacts on own workforce

Governance

On the operational level, HR matters are the responsibility of the VP of HR, whereas issues related to organizational culture, diversity and internal communication are handled by the Culture, Diversity and Inclusion Director. Both areas are supervised by the Chief People Officer, and – on the level of the Management Board – the Joint COO.

HR-related activities in 2024

The following actions were taken:

1. Performance development – Rolling out an internal feedback system titled "Performance development"

2. Back to RED – Developing and enacting best practices related to reintegration of team members following a prolonged leave

3. CD PROJEKT values deep dive meetings – A series of internal deep dive meetings to discuss CD PROJEKT values

4. Coffee with the Board – Reviving the "Coffee with the Board" internal meeting series

5. InsideRED – Deploying an internal communication platform

6. In case of hate - response rules – Enacting response rules at CD PROJEKT Group

7. Life insurance programme – Enabling team members – regardless of location – to obtain life insurance policies for themselves and for their closely related persons

8. SpeakUp! onboarding integration – Since 2025 an introduction to SpeakUp! regulations are also provided as part of onboarding training courses which all new hires undergo

Effectiveness of actions

The effectiveness of activities related to employment is assessed, among others, in the framework of the Culture Amp engagement survey, by monitoring the voluntary churn level and the equal pay. Values of these indicators for the reporting period are presented in the following subsections.

Targets related to own workforce

2024 Targets (Completed)

The following goals were set for 2024:

2025 Targets

The following goals are set for 2025:

1. Maintain the engagement score for CD PROJEKT employees (as measured in the Culture Amp survey): Minimum of 75%
2. Maintain the gender pay gap (based on Compa Ratio – CR levels): Maximum of 2%
3. Carry out pilot training in the area of diversity and incorporate them in the general development path (qualitative)
4. Develop a strategy to strengthen the well-being of employees (qualitative)

Additional Information

• These goals were proposed by the HR and Organizational Culture, Diversity and Inclusion teams, and subsequently accepted by the Management Board.
• Neither employees nor their representatives took part in setting the goals or in evaluating the achievement thereof.
• Targets are monitored via Culture Amp engagement survey, voluntary churn level, and equal pay metrics.

Characteristics of the undertaking's employees

Methodology

The following figures (number of persons) are valid as of 31 December 2024. This data is consistent with disclosure provided in:

• Note 43 "Employment" in the Consolidated Financial Statement of the CD PROJEKT Group as concerns the CD PROJEKT Group,
• Note 43 "Employment" in the Separate Financial Statement of CD PROJEKT S.A. as concerns CD PROJEKT S.A.

The CD PROJEKT Group's own workforce comprises persons employed in Poland and in the USA under contracts of employment.

Headcount by gender, country of employment and contract type

Departures and churn rate during the reporting period

Non-employees within own workforce

Non-employees included in own workforce comprise creators and artists employed under civil law contracts, and self-employed contractors.

Gender breakdown of top managerial staff at CD PROJEKT S.A. (as of 31 December 2024)

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

Non-employees within own workforce

Methodology note: Non-employees included in our own workforce comprise creators and artists employed under civil law contracts, and self-employed contractors.

Counting methodology: Number of persons (headcount) as of 31 December 2024.

Scope: The disclosures cover all team members. By employees we mean persons who have signed a contract of employment with the Company. Our workforce also includes non-employees - individuals covered by other types of civil law contracts, self-employed service providers and persons whose involvement with the Company is mediated by employment agencies.

Collective bargaining coverage and social dialogue

The Group's greatest strength and value are rooted in members of our team. Their talent, commitment and motivation make up the CD PROJEKT Group's human capital. The voice of the team is important to us – which is why we undertake numerous initiatives to foster a feedback culture, encouraging team members to ask questions and share their opinions.

Social dialogue mechanisms

In 2021 the Company appointed RED Teams Representatives (RTR). RTR is an advisory body to the CD PROJEKT Management Board, which represents the interests of those employed at CD PROJEKT. RTR are elected from among all team members and constitute a representative body which advises the CD PROJEKT Management Board. The main role of RTR is to identify organizational threats requiring corrective action, propose solutions and implement them in collaboration with the Management Board.

In 2023 a company committee was established at CD PROJEKT in the framework of one of Poland's nationwide trade unions. This committee was later transformed into an inter-company committee. The committee operates independently of RTR. The Company acknowledges both bodies, and the goal of its cooperation with each of them is to ensure a balance between the interests of employees and organizational efficiency, thus promoting equitable and smooth development.

Collective bargaining coverage

No collective labor agreement is in force with regard to the Group's employees.

In 2023 employees and RTR took part in a double materiality assessment.

Diversity metrics

Gender breakdown of top managerial staff at CD PROJEKT S.A. (as of 31 December 2024)

The table lists the number of persons involved. The Supervisory Board consisted of five persons (women: 20%; men: 80%) while the Management Board consisted entirely of men.

Gender breakdown of top managerial staff at CD PROJEKT S.A. (as of the preparation date of this Statement)

The table lists the number of persons involved. Following changes in the composition of governing bodies which took effect on 1 January 2025, as of the preparation date of this Statement the Supervisory Board consisted of five persons (women: 40%; men: 60%) while the Management Board consisted entirely of men.

Employment by age group

The table lists the number of persons involved. Data is valid for 31 December 2024.

Adequate wages

CD PROJEKT Group employees receive remuneration commensurate with their workload. All wages are above the minimum wage. In order to be able to continue offering competitive salary packages, the company revises its pay matrix each year, based on market benchmarks and professional job evaluation tools.

Benchmark used: The disclosure references that all wages are above the minimum wage and that pay matrix revisions are based on "market benchmarks and professional job evaluation tools," but does not specify any living wage benchmark.

Coverage: Not disclosed.

Geographic scope: Not disclosed.

Targets/commitments: Not disclosed.

Methodology: Annual revision of pay matrix based on market benchmarks and professional job evaluation tools. No details provided on living wage calculation or methodology for assessing adequacy of wages against basic living needs.

Social protection

[ESRS S1-11]

In line with Polish social security regulations applicable to contracts of employment, as well as internal standards in force at CD PROJEKT RED Inc., all employees of the Group are covered by social security programs (social support, medical coverage) in the event of loss of income as a result of illness, layoffs, workplace accidents (including accidents which result in disability), parental leave or retirement.

Coverage

100% of employees are covered by social protection against:

• Illness
• Layoffs (unemployment)
• Workplace accidents (including those resulting in disability)
• Parental leave
• Retirement

Type of scheme

Coverage is provided through:

• Polish social security regulations (applicable to contracts of employment)
• Internal standards at CD PROJEKT RED Inc.

Both public schemes (Polish social security) and company-specific programs (internal standards) are mentioned.

Persons with disabilities

Percentage of persons with disabilities

Contextual information

In line with Polish social security regulations applicable to contracts of employment, as well as internal standards in force at CD PROJEKT RED Inc., all employees of the Group are covered by social security programs (social support, medical coverage) in the event of loss of income as a result of illness, layoffs, workplace accidents (including accidents which result in disability), parental leave or retirement.

Training and skills development metrics

Performance evaluations and career development reviews

Percentage of employees who received feedback in the framework of performance evaluation and career development reviews during the reporting period:

Average number of training hours per employee

Average number of training hours in the reporting period:

Health and safety metrics

Coverage of health and safety management system

100% of Group employees and 0% of other members of its workforce were covered by an OHS system, pursuant to legal regulations.

Fatalities and work-related accidents

During the reporting period:

• Fatalities: No workplace-related fatalities or workplace-related health conditions were reported
• Recordable work-related accidents: Two workplace accidents were reported at the Group (including one at CD PROJEKT S.A.)
• Occupational diseases: No cases of occupational diseases were reported
• Days lost: No lost days were reported as a result of any of the above

Note: No injury rates (e.g. LTIFR, TRIR) per hours worked were disclosed.

Work-life balance metrics

Pursuant to labor law, all employees are entitled to parental leave.

Employees who took advantage of parental leave during the reporting period

Compensation metrics (ESRS S1-16)

Pay gap

CD PROJEKT reports a gender pay gap of 32.46% for the CD PROJEKT Group and 27.58% for CD PROJEKT S.A. as of 31 December 2024.

The pay gap is calculated as the difference between the gross hourly remuneration rate for women and men divided by the average gross hourly rate for men. The calculation covers all individuals employed under contracts of employment as of 31 December 2024, with remuneration converted into FTE equivalents and into PLN.

The company also reports a Compa Ratio (CR) of 99% for both the CD PROJEKT Group and CD PROJEKT S.A. The Compa Ratio is used internally to analyze potential differences between remuneration offered to women and men at CD PROJEKT, as the company considers this coefficient to accurately reflect the gender-related variability of remuneration packages given the employment structure in the gamedev industry. The CR is based on midpoint values of pay ranges offered at respective employment tiers, representing the CR value for women divided by the corresponding CR value for men.

Remuneration ratio

The ratio of the annual total compensation for the organization's highest-paid individual to the median annual total compensation for all other employees is:

• 37.31 for the CD PROJEKT Group
• 35.74 for CD PROJEKT S.A.

The total employment ratio covers all individuals employed under contracts of employment between 1 January and 31 December 2024 whose employment spanned the entire reporting period. Remuneration has been converted into PLN. The following components of compensation packages were taken into account: base remuneration, overtime pay, duty allowance, lump-sum compensation associated with remote work, and any additional revenue increments.

Methodology

Pay gap: Difference between the gross hourly remuneration rate for women and men divided by the average gross hourly rate for men. Calculation covers all individuals employed under contracts of employment as of 31 December 2024, with remuneration converted into FTE equivalents and into PLN.

Remuneration ratio: Covers all individuals employed under contracts of employment between 1 January and 31 December 2024 whose employment spanned the entire reporting period. Components include base remuneration, overtime pay, duty allowance, lump-sum compensation associated with remote work, and any additional revenue increments. Remuneration converted into PLN.

Compa Ratio: Based on midpoint values of pay ranges offered at respective employment tiers. The presented values represent the CR value for women divided by the corresponding CR value for men.

Incidents, complaints and severe human rights impacts

Complaints received through whistleblowing channels

A total of 30 complaints were received in 2024 through internal whistleblowing channels, including:

1. Improper conduct in relations with employed persons:

• 2 reports of improper conduct were received in 2024
• Following investigations carried out in accordance with internal procedure, no actual irregularities were declared

2. Irregularities:

• 28 reports of potential irregularities were received in 2024:
  • 6 reports of alleged irregularities in the recruitment process
  • 1 report of an alleged irregularity in the procurement process
  • 1 report of an alleged irregularity in the process of identifying infringements of CD PROJEKT S.A.'s intellectual property rights
  • 20 reports which were, on their face, baseless and did not name any alleged irregularity

Investigation outcomes

Following separate investigations covering each case, the company determined that 2 minor irregularities did occur:

• 1 irregularity in the recruitment process
• 1 irregularity in the process of identifying IPR infringements

These irregularities had no negative impact on the Company's operations and action was taken to mitigate them.

Incidents of discrimination and severe human rights impacts

No instances of discrimination and no human rights-related incidents (including forced labor, human trafficking or child labor) were identified.

Fines and penalties

No penalties or fines were imposed upon any member company of the CD PROJEKT Group in the context of human rights violations.

Business conduct policies and corporate culture

CD PROJEKT has established several policies addressing business conduct and corporate culture:

Rules of the Game. Business and ethics standards at the CD PROJEKT Group

• Enactment and governance: Formally enacted by the Management Board in 2021
• Scope: CD PROJEKT Group
• Key content: The Standards explain which types of conduct are supported and which are not tolerated, covering areas including:
  • Human rights
  • Privacy protection
  • Compliance
  • Whistleblowing
• International standards alignment: Aligned with the UN Universal Declaration of Human Rights and UN Guiding Principles on Business and Human Rights (referenced in relation to the Human Rights Policy)

Fair Play – Code for Suppliers

• Enactment and governance: Enacted by the Management Board in 2023
• Scope: Suppliers and their supply chains
• Key content: Lists CD PROJEKT's commitments and expectations regarding suppliers, covering:
  • Ethics and compliance
  • Human rights
  • Environmental protection
• Implementation: Currently provided to suppliers on an informational basis; compliance is voluntary

SpeakUp! Policy for preventing irregularities at CD PROJEKT S.A.

• Enactment: Rolled out in 2023
• Scope: CD PROJEKT S.A. employees and third parties
• Key content:
  • Basic rules governing whistleblowing
  • Rights and duties related to reporting irregularities
  • Details of persons involved in the whistleblowing process
  • Protection against reprisals for whistleblowers, witnesses, and those providing assistance
• Reporting channels:
  • For employees: internal online form (can be filled anonymously), in person, or in writing
  • For third parties: anonymized form on CD PROJEKT website or in writing to the Company
• Governance: Reports may be received by the Chief Compliance Officer, a delegated member of the Management Board, a delegated member of the Supervisory Board, VP of HR, or a Trusted Person (elected by employees in democratic ballot)
• Oversight: The Management Board provides the Supervisory Board with an annual report on the number of reports received, types of irregularities alleged, and follow-up actions taken
• Monitoring: In 2024, a planned survey was carried out to assess employees' awareness of whistleblowing policies and tools and their trust in these mechanisms. Since 2025, introduction to SpeakUp! regulations is provided as part of onboarding training for all new hires
• International standards alignment: References the UN Convention against Corruption and protection of whistleblowers (EU legislation)

Anti-corruption Policy

• Enactment: Formally adopted in 2022
• Scope: CD PROJEKT Group
• Key content: Contains basic guidelines on recognizing, preventing, and mitigating corruption risk in business activities and dealings with public bodies, including pledges to:
  • Maintain accounts in a diligent, accurate, verifiable and timely manner
  • Disburse payments in accordance with law and internal financial control standards
  • Maintain transparency in recruitment processes
  • Screen beneficiaries of charitable activities
  • Rules on accepting and giving gifts, resolving conflicts of interest, and engaging with third parties
• Governance: Reviewing and investigating corruption reports is the responsibility of the Chief Compliance Officer and the Privacy & Compliance Team. The Management Board and Supervisory Board receive summaries of notifications, outcomes, and training
• Monitoring: Annual anti-corruption training courses focus on raising awareness through practical examples and case studies. Training covers employees involved in procurement, business and administrative processes (Procurement, IT and Security, Business Development and Administration departments). In 2024, 7 participants underwent counteracting corruption training for selected teams
• International standards alignment: References standards of anti-corruption and anti-bribery (EU legislation requirement)

Information Security Policy

• Status: Update work began in 2024 with focus on simplifying language
• Scope: CD PROJEKT Group
• Key content: Specifies ways of securing information processed by the Group. Based on its provisions, Group member companies introduce internal procedures to ensure information security
• Implementation: Screening of external partners (software suppliers) who require access to IT infrastructure or production data, including analysis of risks and assessment of cybersecurity measures. The Company does not engage with partners who fail to meet security requirements

Personal Data Privacy Policy

• Status: Mentioned but detailed content not disclosed in excerpts

Additional policies and codes mentioned:

• GOG code of conduct: Applies to all GOG platform users to help build a safe online space for discussions
• Regulations for public online forums: Set forth rules for engaging in discussions, specify unallowed messaging and behavior, and spell out penalties
• Human rights policy: Pledges to respect human rights with regard to all social groups affected by activities, including gamers. Actions are consistent with the UN Universal Declaration of Human Rights and UN Guiding Principles on Business and Human Rights
• Best practices (internal): Guide interaction with gamers who report technical issues

Training and awareness

In 2024, CD PROJEKT organized the following business conduct training courses:

• Confidentiality and whistleblowing: 97 participants (onboarding process)
• SpeakUp! Policy for preventing irregularities: 16 participants (interactive e-learning)
• Counteracting corruption: 7 participants (selected teams)
• Cybersecurity: 112 participants (onboarding process)
• Personal data protection: 15 participants (selected teams) and 5 participants (e-learning)

Basic principles of business conduct (protection of inside information, personal data protection, and whistleblowing) are trained during onboarding for new hires. In-person, remote, and e-learning courses are available to all team members.

Incidents and compliance

In 2024:

• 30 complaints were received through internal whistleblowing channels (2 reports of improper conduct, 28 reports of potential irregularities)
• Following investigations, two minor irregularities were confirmed (one in recruitment process, one in IPR infringement identification process) with no negative impact on Company operations
• No instances of discrimination or human rights-related incidents (including forced labor, human trafficking, or child labor) were identified
• No corruption incidents were reported
• No penalties or fines for breaches of anti-corruption regulations or human rights violations were imposed

Incidents of corruption or bribery

Confirmed incidents

No corruption incidents were reported in 2024.

Convictions and fines

No penalties for breaches of anti-corruption regulations were imposed upon the Company in 2024.

Investigation and speak-up procedures

The Company's approach to preventing corruption is described in the Anti-corruption Policy in CD PROJEKT Group. Reviewing and investigating reports of corruption is the responsibility of designated persons at the CD PROJEKT Group whose independence is assured – in particular, of the Chief Compliance Officer along with the Privacy & Compliance Team which assists the CCO in compliance-related matters.

The Management Board and the Supervisory Board receive summaries which specify the number and nature of notifications, the related outcomes, and the training carried out in the framework of preparing annual reports for the Company and the CD PROJEKT Group. Every year the Management Board presents the Supervisory Board with its report on the functioning of the internal control system, risk management, compliance and internal audit function - which also includes the aforementioned summary.

Under the SpeakUp! Policy for preventing irregularities at CD PROJEKT S.A., anyone who reports an irregularity is eligible for protection against the negative consequences of whistleblowing (protection against reprisals). Similar protection is also accorded to witnesses and anyone who provides assistance in submitting the report. Inquiries are carried out in accordance with legal regulations, internal by-laws, and the need to ensure confidentiality and impartiality.

Training

Annual anti-corruption training courses focus on raising awareness among employees on the basis of practical examples and storytelling elements. The training covers identifying corruption attempts, counteracting corruption and avoiding conflicts of interest. It is based on a set of case studies, which help explain the correct course of action and dispel common myths related to corruption practices. This training covers all employees involved in procurement, business and administrative processes - among others, members of the Procurement, IT and Security, Business Development and Administration departments.

In 2024, 7 participants received anti-corruption training for selected teams.

Political influence and lobbying activities

Political engagement approach

The CD PROJEKT Group did not engage in any lobbying activities in 2024. The Group's pledge to maintain political neutrality and refrain from supporting any political party is enshrined in Rules of the Game. Business and Ethics Standards at the CD PROJEKT Group.

Political contributions

In line with this pledge, in 2024 the Group made no financial or material contributions to any political groups.

Lobbying expenditure

The CD PROJEKT Group did not engage in any lobbying activities in 2024.

EU Transparency Register

The CD PROJEKT Group is not registered in the EU transparency register, nor in any transparency register belonging to a member state.

Public office

No member of the Company's governing bodies held any similar public office, including membership of regulatory bodies, in the two years preceding their respective appointments.

Payment practices

In the framework of managing liabilities at the CD PROJEKT Group, the company diligently monitors the flow of invoices and takes care to discharge financial liabilities within their respective contractual deadlines. While 30 days is the recommended payment timeframe, the actual deadlines depend on business needs and are, in each instance, specified in agreements concluded with contractors.

Timely payment performance (2024)

Legal proceedings

CD PROJEKT Group member companies currently do not face any legal proceedings resulting from payment arrears.