Cembre

The Cembre Group is governed by an eight-member Board of Directors, equally distributed among four executive and four non-executive members. All members have professionalism, skills appropriate to the tasks entrusted to them and experience related to the sectors, products and geographical areas in which the company operates. The non-executive members, 50% of whom are independent (25% of the total membership), can, on the basis of their experience and expertise, offer an external and different point of view to those involved in operational management, thus supporting the adoption of board resolutions and ensuring effective management monitoring. During the financial year 2024, the members of the Board of Directors and the Board of Statutory Auditors attended a training session on the reference sustainability legislation.

In addition, the members of the board of auditors and an independent director have gained knowledge and expertise on sustainability issues by participating in specific training courses, or by following CSRD-related activities in other companies. This is also, for some of them, in the context of acquiring the qualification of 'sustainability auditor', according to the guidelines laid down by the supervisory bodies.

This training effort will continue through 2025.

Further details on the competences of the Board of Directors are available in the Corporate Governance and Share Ownership Report and in the Curriculum Vitae of the members on the company website in the Investor Relations section.

To foster effective interaction between top management and employees, individual performance appraisal and professional development interviews are organised each year, as well as meetings dedicated to providing a clear view of the company's performance, future strategies and growth objectives.

Cembre did not adopt specific policies on diversity with regard to the composition of the management and administrative bodies, with regard to issues such as age, gender, training and professional background, both because the legal provisions and the By-laws in force already ensure a balanced composition of the administrative body, and because, historically, the lists submitted by the shareholders for the appointment of directors were always characterised by the diversity of candidates' profiles. In this regard, it should be noted that there are four female directors on the Board of Directors, corresponding to 50% of the total, as indicated in Table 1.

Cembre has a corporate risk control and management system, understood as a set of processes aimed at monitoring the efficiency of corporate operations, the reliability of financial information, compliance with laws and regulations, and the protection of corporate assets.

To this end, the Board set up a Control and Risks Committee consisting of two non-executive and independent Directors with experience in accounting and finance and risk management; it also established an Internal Audit function.

In order to update its risk map, a risk assessment activity is carried out every two years, taking into account the identification and assessment of the main business risks (financial, strategic, governance, operational, digital, compliance, environmental and social) perceived by company management.

The Board defines the nature and level of risk that is compatible with the strategic objectives, including in its assessments the main risks that may be material in view of sustainability in the medium to long term, and takes care of defining the guidelines of the system itself.

To such end, the Board, having received the opinion of the Control and Risks Committee:

• defines the guidelines of the control and risk management system;
• verifies periodically, and in any case at least annually, the adequacy, efficacy and effective functioning of the internal control and risk management system.
• approves, at least annually, the plan prepared by the manager responsible for Internal Audit, having heard the Board of Statutory Auditors and the Chief Executive Officer;
• evaluates, after consulting with the Board of Statutory Auditors, the comments of the Independent Auditing firm in the letter of suggestions, where issued, and in the auditing letter issued by the legal audit.

Furthermore, the Board, upon proposal of the Chief Executive Officer and with the prior favourable opinion of the Control and Risks Committee, as well as having consulted the Board of Statutory Auditors:

• appoints and revokes the responsible for Internal Audit;
• ensures that the same has adequate resources to carry out their task.

The Organisation, Management and Control Model describes the roles and responsibilities of persons involved to various degrees in the drafting and/or control of financial reporting of the Cembre Group. As indicated in the Report on Corporate Governance and Ownership Structure, the main managers identified to ensure the proper functioning of the system are:

• Board of Directors;
• CEO, responsible for establishing and maintaining the internal control and risk management system system;
• Financial Reporting Officer;
• Internal Audit function;
• Heads of Functions and Subsidiaries.

In particular, the Control and Risks Committee assists the Board of Directors through the following functions: a) evaluates, having consulted the Manager responsible for the preparation of the Company's accounts, the Independent Auditor and the control body, the correct application of accounting standards and their consistency for the preparation of the Consolidated Financial Statements; b) assesses the suitability of periodic financial and non-financial information to correctly represent the company's business model, strategies, the impact of its activities and the performance achieved; c) examines the content of the periodic non-financial disclosure, which is relevant for the purposes of the internal control and risk management system; d) expresses opinions on specific aspects regarding the identification of the main corporate risks and supports the evaluations and decisions of the administration body relating to the management of risks deriving from prejudicial facts that have come to the knowledge of the latter; e) examines the periodic reports and those of particular relevance prepared by the Internal Audit department; f) monitors the autonomy, adequacy, efficiency and effectiveness of the Internal Audit department; g) may entrust the performance of specific checks on operating areas to the Internal Audit department, simultaneously notifying the Chair of the Statutory Auditors of this; h) reports to the Board of Directors, at least at the time of approval of the annual and half-year financial report, on the activities carried out and on the adequacy of the internal control and risk management system.

During the 2024 financial year, the Board of Statutory Auditors, consisting of one woman and two men, carried out the supervisory activities required by law, also taking into account the principles of conduct recommended by the National Council of Chartered Accountants and Accounting Experts and Consob communications on corporate controls and the activities of the Board of Statutory Auditors.

In particular, with regard to Sustainability Reporting, it should be noted that the Board of Auditors monitored and verified how the company was organised and structured to adequately fulfil the preparation of the Sustainability Report.

The corporate structure also benefits from the consulting support of professionals qualified in ESG issues and, in particular, experts in CSRD regulations.

The Board of Statutory Auditors, in addition to verifying the organisation and processes adopted by the company, is constantly informed on the progress of activities concerning the preparation of sustainability reporting, through specific meetings with those involved in the preparation of the document, as well as by the CEO at board meetings.

There are currently no formalised specific procedures concerning the management of sustainability-relevant risks, impacts and opportunities, although these are integrated within the procedures underlying the company's business management.

In order to control corporate risks so as to reduce their exposure within acceptable levels and oversee the achievement of corporate objectives, the Board of Directors, through the 'appointed functions', performs control activities through administrative-accounting control procedures and corporate procedures for the prevention and monitoring of operational risks.

In the area of sustainability competencies, the Board of Directors approves the results of the Dual Materiality Analysis and the relevant documentation integrating them.

From an operational point of view, starting with the 2020 financial year, Cembre chose to appoint a Sustainability Manager to improve its ability to effectively manage issues related to sustainability and to spread the culture of social, environmental, and economic responsibility in all the Group's locations. In addition, Cembre has adopted a dedicated procedure for sustainability reporting, approved by the Board of Directors. Concerning material impacts, risks, opportunities and their interaction with the strategy and business model, please refer to the specific section within this report.

The administration, management and control bodies are informed about sustainability issues assessed as material and, in particular, the impacts, risks and opportunities encountered, through special meetings held with the Sustainability Manager, both during and after the definition phases of dual materiality. In fact, the Group has an internal procedure for the preparation of Sustainability Reporting, according to which the analysis of Dual Materiality can be subjected to an annual internal review process.

Furthermore, the procedure, approved by the Board of Directors, defines roles, responsibilities, activities and control steps.

The Group's corporate strategies and business plans are influenced by the outcomes of the biennial Risk Assessment, the Dual Materiality Analysis and specific circumstances that may generate opportunities, helping to guide strategic choices.

The Dual Materiality analysis also takes into account the issues assessed when defining the corporate Risk Assessment and the corporate risk management and control system. During the reporting year, the impacts, risks and opportunities (IRO) identified through the dual materiality analysis were submitted to the Board of Directors for approval and detailed in Tables 5, 6 and 7 of this document. The initiatives and policies adopted in response to the IRO that emerged are described in the respective chapters.

The medium to long-term incentive scheme of the CEO also considers certain non-financial objectives.

the calculation system takes into account the achievement of results linked to process innovation and energy efficiency (the "LTI Non-Financial Objective"), with an on/off mechanism, as specified from time to time by the Board of Directors, at the proposal of the Appointments and Remuneration Committee. The maximum limit is set at 100% of the LTI Non-Financial Objective and envisages the payment of the maximum bonus that can be disbursed, equal to 15% of the overall LTI bonus, which constitutes the cap (i.e. maximum limit) for the component linked to non-financial objectives.

On 14 November 2024, the Board, at the proposal of the Appointments and Remuneration Committee, approved the new medium-long term monetary incentive plan for the Company's Chair and Chief Executive Officer, setting the maximum bonus payable for the period 2024-2026 at 180,000 euro, establishing as a performance target (i.e. Economic-Financial Objective LTI) the cumulative consolidated EBITDA of the period 2024-2026, with a minimum guarantee clause represented by the growth of the cumulative consolidated sales revenue of the three-year period 2024-2026, as well as Non-Financial Objectives LTI, the increase of self-produced energy through the installation of photovoltaic panels, the introduction of process innovations with the reduction of repetitive manual movements of operators and the implementation of a new production line.

This Report describes the methodologies and due diligence processes adopted with regard to managing ESG impacts, risks and opportunities (IRO). For further details, please refer to the individual chapters of the document dedicated to the specific issues, all measured through specific indicators.

The Group is progressively integrating ESG principles and sustainability reporting guidelines into its risk management and control system, incorporating them into its biannual risk assessment, preparatory to the definition of the dual materiality analysis, with a specific focus on financial materiality.

Cembre has established a reporting procedure to ensure that the data underlying the values displayed are complete, accurate and available over time.

The sales network

Cembre pursues its growth by establishing itself on international markets, seeking to replicate its industrial model and values in all the countries in which it operates, with due consideration for local culture.

Consistently with its values and mission, the Group operates in full respect of human rights and the environment.

In Italy, Cembre S.p.A. operates through a capillary distribution network, with its own offices and warehouses in Brescia, Turin, Milan, Padua, Bologna, Florence and Palermo; in the other regions, it operates through agents, organised for technical-commercial assistance and with warehouses for rapid deliveries. Cembre is also present in the main countries across the globe, thanks to a network of representatives or correspondents, who can guarantee immediate, qualified technical-commercial assistance and rapid deliveries of products from their warehouses.

The Cembre sales force worldwide numbers more than 150 functionaries dedicated to daily visits to customers.

The Group intends to further consolidate its relationships with customers and distributors in order to strengthen its position as the main supplier of a comprehensive range of products, also thanks to its ability to adapt production processes to the specific needs of customers and to provide an increasingly wide range of products.

The Dutch office is excluded from the reporting scope, as it was inactive as at 31 December 2024.

Cembre offers different product ranges, designed specifically for industrial, railway and power & utilities applications, aggregated into five main macro-categories:

• Electrical connectors;
• Tools:
• Sealing;
• Cable glands:
• Wiring accessories.

For a breakdown of total revenues by geographic area and Group companies, please refer to the section 'Operating Performance and Analysis of Group Results' in the Annual Financial Report 2024.

In addition, Cembre has set some targets to improve the sustainability of its products. These include the conversion of some heat-powered tools to electric versions and the calculation of the carbon footprint of its products, divided into the five macro-categories to be analysed progressively over time. To date, a number of Cembre screwdrivers, drills and boring machines have already been converted to electrical, and the macro-categories of electrical connectors and signalling have been examined in terms of LCA2.

For an overview of its value chain, please refer to the section 'General Criteria for drafting Sustainability Statements'.

The Cembre Group's Sustainability Report focuses on assessing the impacts, both positive and negative, that the Group's activities may have on the entire value chain, both actual and potential. For a better understanding of the value chain in which Cembre operates, the main stakeholders were considered, as indicated in Table 4.

Cembre has already established an active and constant dialogue over the years, both at individual level (visits, dedicated events at the company) and collective level (publications on website and social media, participation and organization of conferences). This dialogue is based on values of transparency and trust and allows the Group to maintain an open dialogue with stakeholders, periodically check alignment with the issues raised and identify any new impacts.

The table below summarises the listening and engagement tools and expectations of all Cembre stakeholders. The results of stakeholder engagement activities are communicated to and taken into account by the administrative and management bodies in managing the impacts the Group generates towards them.

For the impacts, risks and opportunities assessed as material, please refer to Table 5, Table 6 and Table 7 of this section and in more detail to the individual chapters in this document.

Also with regard to the specific actions and resources implemented to deal with the material themes in relation to the current and expected effects of IRO, as well as the related impacts identified, please refer to the individual chapters of the document.

Risks and opportunities in financial terms were assessed as part of the financial materiality analysis. To date, a specific analysis of the resilience of their business with respect to the identified IRO has not been developed.

Below is a list of the sustainability issues that emerged as material for each of the three ESG macro-pillars (environmental, social, governance) as part of the dual materiality analysis. The analysis identified the company's external impacts (impact materiality) and related risks and opportunities (financial materiality), then clustered them into themes and sub-themes.

This approach makes it possible to identify the most appropriate ways to effectively manage each theme.

Material environmental themes:

Material social themes:

Material governance themes:

IRO assessed as significant may have an impact on the Group's business model and strategy. In particular, the company has implemented specific management systems that provide a structured and systematic approach to streamlining processes, resources and activities.

The following have therefore been implemented:

• Quality Management System in accordance with ISO 9001;
• Environmental Management System in accordance with ISO 14001;
• Management System for the Prevention of Corruption according to ISO 37001;
• Occupational Health and Safety Management System according to ISO 45001.

For specific policies, resources, implemented actions and related metrics, please refer to the individual chapters of the document. In relation to specific targets, the Group has not yet publicly defined targets for the management of identified impacts, risks and opportunities, but is committed to setting them for future years. Again, detailed information will be provided in the following chapters.

To identify the impacts, risks and opportunities related to the Group's sustainability issues, and thus assess their relevance, a Dual Materiality Analysis was conducted. This analysis was carried out considering both the historical company and sectoral context. In detail, the main industry trends and the sustainability performance of the Group's peers and competitors were analysed, as well as the results of the latest materiality analysis conducted. In this way, it was possible to obtain a preliminary list of potential impacts, risks and opportunities relevant to Cembre. The analysis covered all three sustainability macro-pillars: environmental, social and governance.

As far as the Materiality of Impact is concerned, an in-depth assessment of the identified impacts was carried out in cooperation with the various company contact persons. These company representatives were able, in view of their knowledge and experience, to contribute to the analysis by also taking into account the views of any external stakeholders not actively involved in this initial analysis. The analysis, conducted according to an inside-out approach, included both positive and negative impacts, actual and potential, that the company's activities and along the identified value chain may generate on the outside world, in particular on the environment and society. A detailed analysis was carried out with respect to direct impacts, resulting from the company's internal activities - core activities- and indirect impacts, related to operations along the value chain. In both cases, the analysis process was conducted following the same methodology.

For each impact, specific parameters of severity and probability were defined and assessed.

Severity is the sum of the following three sub-parameters:

• Scales: rated in levels from minimum to absolute;
• Scope: rated in levels from limited to global;
• Irreparable character: rated in levels from easily remediable to irreversible.

The sum of these values makes it possible to determine a severity level that can range from minimal to critical. Next, the level of severity was multiplied by the probability, the latter graded on a scale ranging from very likely to unlikely.

It is emphasised that the positive impacts were not considered to be irremediable. Taking a precautionary approach, however, the actual impacts were associated with the two highest probability levels.

In order to understand the relevance of each impact, a graphical representation was drawn up in the form of a matrix cross-referencing the severity and probability parameters and in which the analysed impacts were positioned according to the score assigned. The matrix is divided into three areas corresponding to low, medium and high relevance respectively: impacts falling in the medium and high relevance areas were therefore material. The significance of the impact determined its reporting in the document against the relevant ESRS standard.

With regard to Financial Materiality, an assessment was also conducted in cooperation with the corporate functions.

In this case, financial risks and opportunities related to sustainability issues that have or may have an impact on the company were assessed, thus adopting an outside-in approach. These were identified by also considering the impacts generated by the Group or along its value chain and the Group's main dependencies from which risks or opportunities might arise. Also considered as input for the identification of risks and opportunities were any sustainability actions implemented by Cembre and what was already included in the Cembre Risk Assessment exercise conducted in 2024.

The scores obtained from this assessment were determined on the basis of two main parameters: • magnitude: assessed through a level from minimum to critical; • probability: assessed through a level from unlikely to very likely.

Direct and indirect events were taken into account and considered in the short-, medium- and long-term time horizons. In the short term, the elements in the company's Risk Assessment that could be related to sustainability were assessed and found not to be materially significant; in the medium to long term, on the other hand, both the elements in the Risk Assessment and those arising from impact assessments and dependencies were analysed. Finally, the results of the analyses were represented in three matrices: one relating to the short term, one to the medium to long term, and one integrating the overall results and shared with all top management, including the Control Body.

At the end of the Dual Materiality analysis, the results that emerged were grouped in a single table, allowing the themes to be examined from both the impact and financial perspectives. A theme was considered material and thus subject to reporting if it is so in at least one of the two Dual Materiality analyses. The final results were shared with the company management.

Minimum reporting requirements on policies, actions, targets and metrics

Information on the policies, actions, objectives and metrics adopted and reported by the Group regarding the material impacts, risks and opportunities identified are included within the following chapters of this document.

The following is the content index and table summarising the disclosure obligations and application requirements under ESRS relevant to the Group and therefore included in this document that derive from other European legislation.

Transition plan for climate change mitigation

Status of transition plan

To date, the Cembre Group has not developed a transition plan for climate change mitigation, which would ensure the compatibility of the Group's business model with the Paris Agreement objectives of keeping the global temperature increase below 1.5°C, nor does it plan to adopt such a plan in the short term.

Incentive systems

To date, the Cembre Group's incentive system does not include any schemes linked to the climate performance of executive directors or the Chief Executive Officer.

Key decarbonization actions

The Cembre Group's commitment to energy efficiency and the sourcing of energy from renewable sources is reflected in a series of initiatives that testify to its focus on environmental sustainability, to date not yet supported by a specific decarbonisation plan. Below are some examples of the targeted actions undertaken by the Group and broken down by decarbonisation lever.

1. Energy efficiency

Replacement of lighting installations with LED systems: The replacement of more than 900 conventional lighting fixtures with LED technology by 2026 will achieve an estimated 40% energy saving related to lighting, with a reduction in annual CO2 emissions of more than 100 tCO2eq. In 2024, the replacement process covered 68 lamps, achieving a reduction in energy consumption of more than 50%. The expenses incurred for the realisation of the project amounted to 38,115 euro.

Installation of monitoring systems: During 2024, new energy and gas consumption monitoring systems were installed at Cembre S.p.A. headquarters. These systems make it possible to accurately quantify the energy consumption of the oven and the gas consumption of the washing machines, which will be replaced with new equipment when production is transferred to the new industrial buildings. It is estimated that the adoption of these solutions will allow a reduction in greenhouse gas (GHG) emissions of approximately 21% (6 kgCO₂eq per tonne produced) for the oven and 100% (32,600 kgCO2eq per year) for the washing machines compared to current values because they will switch to power supply with renewable electricity certified through guarantees of origin. The expenses incurred in the implementation of the project amounted to 12,261 euro.

2. Use of energy from renewable sources

Installation of new photovoltaic systems: In December 2024, the installation of a new photovoltaic system was completed at the Group's sales office in Madrid, Spain, with a capacity of approximately 89 kW. The estimated annual output of the latter plant exceeds 135 MWh, enabling it to fully cover the site's energy needs and enabling a 100% reduction in GHG emissions generated by the purchase of electricity calculated according to the market-based method. The expenses incurred in the implementation of the project amounted to 57,130 euro.

Procurement of electricity from 100% renewable sources: In 2024, the Cembre SLU Spanish site and, from July 2024, the Cembre SpA Brescia site signed contracts for the procurement of 100% renewable energy, ensuring that all operations are powered exclusively by renewable sources. The purchase of electricity through Guarantees of Origin will enable the Spanish and Italian headquarters to reduce their Scope 2 GHG emissions calculated according to the market-based method by 100%.

3. Sustainable mobility

Definition of the Home-Work Commute Plan: Cembre S.p.A.'s Home-Work Commute Plan (PSCL), active since 2022, is contributing to a gradual change in employees' home-work commuting habits with economic, environmental and social benefits. The document identifies a number of alternative measures to the use of private cars for home-work-home transfers of company personnel.

Policies related to climate change mitigation and adaptation

Cembre currently does not have a formalised, public policy specifically dedicated to managing climate change mitigation and adaptation, energy efficiency, or renewable energy implementation.

However, the Group has adopted the following policy that addresses environmental protection principles:

Cembre Group Corporate Policy

• Approval and oversight: Approved by the CEO in 2023; responsibility lies with Company Management
• Scope: All company personnel and external stakeholders
• Key content: Addresses principles that inspire Cembre, including environmental protection
• Public availability: Published on the Group's website
• Dissemination: Illustrated to all company personnel and made known to external stakeholders

Related management systems

While not formal climate policies, the Group has implemented:

• ISO 14001 Environmental Management System: Implemented at manufacturing units in Italy (Cembre S.p.A.) and England (Cembre Ltd.); incorporates climate change regulations; audited annually by independent third parties
• ISO 9001 Quality Management System: Integrates climate change risks in line with standard provisions

Monitoring mechanisms

The Group monitors environmental data through:

• Monthly monitoring of energy consumption for each production department, with performance indicators distributed to Management and Department Managers
• Annual checks of refrigeration systems for F-GAS leakage
• Annual Carbon Footprint calculation
• Periodic energy diagnosis updates (Cembre S.p.A. as a large company)

Commitment statement

Cembre states that "energy efficiency and supply from renewable sources are key building blocks for building a more sustainable future" and commits to investing in innovative technologies and promoting environmental sustainability culture within its workforce. However, the company acknowledges that its policy does not explicitly include references to promoting climate change adaptation measures.

Actions and resources in relation to climate change policies

The Cembre Group's commitment to energy efficiency and the sourcing of energy from renewable sources is reflected in a series of initiatives, to date not yet supported by a specific decarbonisation plan.

Actions are broken down by decarbonisation lever:

1. Energy efficiency

Replacement of lighting installations with LED systems

• Scope: Own operations (Cembre S.p.A. headquarters)
• Time horizon: By 2026 (in 2024, 68 lamps replaced)
• Expected outcomes:
  • Estimated 40% energy saving related to lighting
  • Reduction in annual CO₂ emissions of more than 100 tCO₂eq
  • In 2024: reduction in energy consumption of more than 50%
• Target: Replacement of more than 900 conventional lighting fixtures with LED technology
• Resources allocated: €38,115 (expenses incurred in 2024)

Installation of monitoring systems

• Scope: Own operations (Cembre S.p.A. headquarters)
• Time horizon: 2024 (implemented)
• Description: New energy and gas consumption monitoring systems installed to accurately quantify energy consumption of the oven and gas consumption of washing machines
• Expected outcomes:
  • Estimated GHG emissions reduction of approximately 21% (6 kgCO₂eq per tonne produced) for the oven
  • 100% reduction (32,600 kgCO₂eq per year) for washing machines compared to current values (when replaced with new equipment powered by renewable electricity certified through guarantees of origin)
• Resources allocated: €12,261 (expenses incurred in 2024)

2. Use of energy from renewable sources

Installation of new photovoltaic systems

• Scope: Own operations (Group's sales office)
• Time horizon: Completed December 2024
• Resources allocated: Not disclosed in excerpt

Targets related to climate change mitigation and adaptation

Outside the internal objectives set by the Environmental Management System adopted by the Group, there are no measurable, public objectives related to climate change. However, the definition and monitoring of its Corporate Management System has allowed the Cembre Group to define specific internal objectives and KPIs for the periodic monitoring of its environmental performance, with a particular focus on climate change mitigation in the medium term. These targets include both general targets related to the development of the plants, in order to assess the benefit brought by each project, and specific targets for each production department, updated monthly and modulated according to the results obtained in previous periods.

No quantified public targets disclosed.

Energy consumption and mix

Total energy consumption and energy mix (2024)

Methodology: The energy mix for electricity supply is determined using residual mix data from the Association of Issuing Bodies (AIB). Following a precautionary approach, the residual share of renewable energy on the market, net of shares covered by guarantees of origin, was attributed to natural gas as a fossil source in the absence of precise details on its actual use.

Data have been disaggregated by fuel type as the Group operates in high climate impact sectors (NACE code 27.90.09, category C manufacturing activities).

Conversion factors used:

• Diesel: 11.91 MWh/t
• Petrol: 11.98 MWh/t
• Natural Gas: 0.0098 MWh/m³
• LPG: 12.74 MWh/t

Energy intensity

Energy intensity is calculated as total energy consumption divided by net consolidated revenue in thousands of euro.

Gross Scopes 1, 2, 3 and Total GHG emissions

Cembre calculated greenhouse gas (GHG) emissions for 2024 in accordance with the GHG Protocol Framework. The analysis covers Scope 1 (direct emissions), Scope 2 (indirect emissions from purchased energy), and Scope 3 (indirect emissions along the value chain).

Greenhouse gas emissions (tCO2eq)

GHG emission intensity

GHG emission intensity is calculated as the ratio of total GHG emissions to consolidated net revenue in thousands of euro.

Methodology and scope notes

Scope 1: Emission coefficients for direct emissions are from the national standard parameters table of the UNFCCC national inventory (ISPRA 2023 data). For refrigerating gases, global warming potentials (GWP) are from the Sixth Assessment Report of the IPCC.

Scope 2: Location-based emission factors from Terna 2019 (UK and US) and European Environment Agency (EEA) 2023 (other countries). Market-based emission factors from Residual Mixes 2023 published by the Association of Issuing Bodies (AIB) for European countries and eGRID of the U.S. EPA for the USA. Where location-based factors are higher than market-based (France and USA), the same value of the location-based factor is used for both approaches as required by the GHG Protocol.

Scope 3: The Group conducted a materiality analysis to assess applicable and material categories. Seven categories were calculated (1, 2, 3, 4, 5, 10, 12). Emissions from category 1 (purchase of goods) were calculated using SimaPro software based on the Ecoinvent database. Emissions from categories 1 (services), 2, 4, 10, and 12 were estimated by multiplying direct costs by emission factors from the UK Government Conversion Factors for Company Reporting (SIC_multipliers_2021). Emissions from category 3 and 5 were calculated using DEFRA greenhouse gas conversion factors. Categories 6 (Business travel), 7 (Employee commuting), 8 (Upstream leased assets), 9 (Downstream transportation), 11 (Use of sold products), 13 (Downstream leased assets), 14 (Franchises), and 15 (Investments) were either not applicable or not material and therefore not included.

Exclusions: The Group is not included in any regulated GHG emissions trading scheme. No radioactive waste. The calculation methodologies for Scope 3 are subject to greater inherent limitations than those for Scope 1 and 2, due to limited availability and relative accuracy of information relating to the value chain.

Baseline year: 2024 was adopted as the reference and base year. No comparisons with previous years were made and no significant errors relating to earlier reporting periods were reported.

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

Use of phase-in exemption

With regard to information on the types and quantification of the anticipated financial effects of physical and transitional climate risks assessed as material according to the Financial Materiality Analysis, the Group makes use of the transition period provided for in Appendix C of ESRS 1.

Policies related to pollution

Corporate Policy

Cembre Group has a Corporate Policy that addresses pollution prevention and reduction.

• Approval and oversight: Approved by the CEO
• Scope: Applicable to all persons in the Company; does not cover indirect operations and has not involved external stakeholders
• Key content and principles:
  • Prevention and reduction of air, water and soil pollution
  • Monthly monitoring for each production department of chemicals used and waste produced, with data related to production hours and/or quantity of materials processed to obtain performance indicators
  • Distribution of monitoring information via special charts to Management and each Department Manager, ensuring dissemination to all operators concerned
  • Annual analyses to monitor concentration of pollutants emitted into the atmosphere, ensuring compliance with regulatory limits, and periodic checks on proper functioning of plants
  • Bi-annual analyses to monitor concentration of pollutants emitted into water, ensuring compliance with regulatory limits
  • Periodic verification of integrity of containers and containment tanks used for temporary storage of waste, ensuring compliance with environmental protection standards
• Link to international standards: The policy does not refer to external standards or initiatives
• Public availability: Not disclosed

Actions and resources related to pollution

Cembre is committed to mitigating environmental pollution through constant monitoring of its plants and their periodic maintenance. The storage, handling, use and disposal of hazardous and chemical substances are carried out by following rigorous procedures that are checked periodically and updated, when necessary.

Ongoing management activities

• Polluting substances segregation: Polluting substances are kept in dedicated areas, segregated with respect to the other materials needed for the production process
• Personnel training: Personnel involved in the management are specifically trained and instructed
• Plant conformity monitoring: Guaranteed through the continuous update and application of the management system, which requires frequent, scheduled emissions monitoring, including with the support of specialised consultancy firms
• Production line renewal: Continuous renewal of the production lines prevents the risk of obsolescence and wear and tear of machinery

Scope: Own operations

Resources allocated: Not quantified. External consultancy firms are engaged for emissions monitoring.

Explicit statement: "In addition to the traditional management approach adopted by Cembre, no additional actions are reported for 2024."

Targets related to pollution

To date, the Cembre Group has no public targets for air, water and soil pollutant emissions.

However, as part of its Environmental Management System according to ISO 14001, Cembre tracks its performance on this issue through the introduction of specific KPIs, such as:

• KPI related to the reduction of the amount of effluent discharged into the sewerage system after the purification process for the new galvanic plant, in relation to the volume of water withdrawn

The Group also monitors the values of released pollutants with reference to legal limits.

Note: No quantified target values, baseline years, target years, or scope details are provided for the KPI mentioned.

Pollution of air, water and soil

A review of emissions to air and water was carried out, assessing the quantities of substances released as indicated in the AUA (single environmental authorisation) management deed no.1971/22. The values measured were below the thresholds set out in Annex 2 of Regulation (EC) No. 166/2006.

Emissions to air: No quantified emissions disclosed. The company states that measured values were below the thresholds set out in Annex 2 of Regulation (EC) No. 166/2006 for pollutants listed in E-PRTR (European Pollutant Release and Transfer Register).

Emissions to water: No quantified emissions disclosed. The company states that measured values were below the thresholds set out in Annex 2 of Regulation (EC) No. 166/2006.

Emissions to soil: No quantified emissions disclosed. The company states that no specific micro-plastics are used in the production processes. Activities are managed to prevent accidental release of substances into the soil, with risk mitigation through regular audits conducted as part of the Environmental Management System.

Regulatory reference: AUA (single environmental authorisation) management deed no.1971/22 and Regulation (EC) No. 166/2006.

Monitoring approach:

• Annual analyses to monitor the concentration of pollutants emitted into the atmosphere
• Bi-annual analyses to monitor the concentration of pollutants emitted into the water
• Periodic verification of the integrity of containers and containment tanks used for temporary storage of waste
• Monthly monitoring for each production department of chemicals used and waste produced

Anticipated financial effects from pollution-related impacts, risks and opportunities

Cembre has applied the three-year phase-in exemption for this disclosure requirement and has not provided information on anticipated financial effects from pollution-related impacts, risks and opportunities in this reporting period.

Policies related to water and marine resources

Cembre does not currently have a formalised, public policy specifically dedicated to the management of water and marine resources.

However, the company references one policy that includes water-related principles:

Cembre Group Corporate Policy

• Approval and oversight: Approved and formalised by the CEO in 2023
• Scope: All company personnel and external stakeholders
• Key content: Deals with the principles inspiring Cembre, including the monitoring of the consumption of environmental resources used
• Public availability: Published on the Group's website
• Implementation monitoring: The company monitors water management performance through its Environmental Management System in accordance with ISO 14001, using specific internal KPIs including:
  • Supplying the cutting department's washing machines with purified water instead of well water
  • Reducing the consumption of well water for washing connectors or for production and watering

Actions and resources related to water

Optimisation of water system at Cembre headquarters (2024)

Description: Intervention implemented in 2024 to optimise the water system at the Cembre headquarters, which is the most significant in terms of water consumption and located in a water-stressed area. A section of the aqueduct was decommissioned, allowing the elimination of a section subject to significant leakage over the years.

Scope: Own operations (Cembre headquarters)

Time horizon: Implemented in 2024

Expected outcomes:

• Reduction in water consumption
• Improved efficiency of water resource management

Resources allocated: Not quantified

---

Note: While the company monitors water performance through ISO 14001 Environmental Management System and references internal KPIs (including supplying cutting department washing machines with purified water instead of well water), these are presented as monitoring activities rather than discrete actions under E3-2.

Targets related to water

At present, the Group has no measurable public objectives related to water resource management.

However, through its Environmental Management System in accordance with ISO 14001, Cembre monitors its performance related to water management through reference to specific internal KPIs, including:

• Supplying the cutting department's washing machines with purified water instead of well water
• Reducing the consumption of well water for washing connectors or for production and watering

Note: These are qualitative monitoring activities rather than quantified targets with specific target values or target years.

Water consumption

Water withdrawal, consumption and discharge

Methodology note: The Group's Chinese headquarters was not considered, as it is not reported for environmental information. Data were calculated based on estimates taken from the bills for each of the Group's locations.

Water intensity

Water intensity is calculated as the ratio of total water consumption to consolidated turnover in thousands of euro:

Water intensity = Water consumption / Net revenue in thousands of €

Water-stressed areas

The identification of the water-related impact took place following a mapping of the Group's sites within the Aqueduct tool (https://www.wri.org/aqueduct), which showed that the Brescia plant and the sales companies in Spain, Germany and America are classified as water stress areas, according to a 'high' or 'extremely high' range.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

Cembre applies the three-year phase-in exemption for ESRS E3-5 (Expected financial effects from impacts, risks and opportunities related to water and marine resources).

Policies related to resource use and circular economy

Corporate Policy

Policy name: Corporate Policy

Approval and oversight:

• Approved and formalised in 2023 by the Chief Executive Officer

Scope:

• Applies to all Group companies, including production sites

Key content and principles:

• Addresses the principles by which Cembre is inspired, including the management of material used by incentivising its recycling as opposed to the use of virgin material

Public availability:

• Disseminated and explained to all company personnel
• Made known to external stakeholders through publication on the Group's website

Monitoring and implementation:

• The production sites, which are responsible for generating the most significant quantities of waste, are responsible for implementation

Limitations:

• There is no reference in the document to the purchase or procurement of renewable resources

Actions and resources related to circular economy

Waste management instructions and employee awareness

Cembre has drawn up instructions to ensure proper waste management, from collection to disposal. In addition, the company raises awareness among its employees on a daily basis, providing them with containers for the separate collection of paper/cardboard, plastic, dry, glass/can and organic waste, as well as bins for toner and alkaline batteries.

Scope: Own operations

Resources allocated: Not quantified (non-financial: employee awareness programmes, waste collection infrastructure)

Expected outcomes/KPIs: The company monitors performance through its Environmental Management System according to ISO 14001, with specific KPIs concerning:

• Reduction of waste production through the removal of the softener in the cutting department and from the cleaning of the washing machines
• Reduction of the consumption of whole oil for the production of connectors in relation to the material processed through the recovery of part of the oil residues removed from the connectors during the washing process

Link to policy: Environmental Management System according to ISO 14001

Time horizon: Not specified

---

Note: The disclosure states that by 2024, 80% of the waste generated is recycled. No public targets have been set for waste management to date.

Targets related to circular economy

To date, the group has no public targets for the management of waste produced.

However, through its Environmental Management System according to ISO 14001, Cembre has defined specific KPIs through which it monitors its performance with regard to waste management. In particular, these concern:

• The reduction of waste production through the removal of the softener in the cutting department and from the cleaning of the washing machines
• The reduction of the consumption of whole oil for the production of connectors in relation to the material processed through the recovery of part of the oil residues removed from the connectors during the washing process

Note: No quantified targets, target years, baseline years, or baseline values have been disclosed.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Phase-in exemption applied

With regard to information on the types and quantification of the expected financial effects of risks assessed as material according to the Financial Materiality Analysis on circular economy and resource use, the Group makes use of the transition period provided for in Appendix C of ESRS 1.

Waste

Waste generation and composition (2024)

The table below shows the waste produced by the Cembre Group in 2024. There is no radioactive waste, and 80% of waste generated was recycled.

Waste composition details

Non-hazardous waste comes mainly from cutting and moulding processes of connectors and mechanical processing for tool components and cable glands:

• 70% metal and plastic scrap, including:
  • EER 120103: Brass, aluminium and copper scrap
  • EER 120101: Iron/iron+aluminium turnings
  • EER 120105: Polycarbonate scrap, waste and residues
• 20% wood packaging (EER 150103), mainly from packaging waste for delivery of ferrous and non-ferrous materials
• 10% different types of waste of lesser incidence

Hazardous waste comes mainly from tinning and purification processes, mechanical processing and washing operations:

• 42% from tinning and purification processes:
  • EER 110105*: Acid eluate
  • EER 060502*: Filter press sludge
• 43% from mechanical processing and connector washing:
  • EER 120109*: Oily sludge
• 6% from softeners:
  • EER 060313*: Salts and their solutions containing metals
• 9% different types of waste with lower incidence

Waste management approach

Data are derived from point measurements of waste quantities delivered, declared in the Single Environmental Declaration Form (MUD).

Cembre has drawn up instructions to ensure proper waste management, from collection to disposal. The company raises awareness among employees through:

• Containers for separate collection of paper/cardboard, plastic, dry waste, glass/cans, and organic waste
• Bins for toner and alkaline batteries

Monitoring and compliance:

• Monthly monitoring for each production department of chemicals used and waste produced
• Data related to production hours and/or quantity of materials processed to obtain performance indicators
• Charts distributed to Management and Department Managers
• Periodic verification of integrity of containers and containment tanks for temporary waste storage
• Compliance with environmental protection standards according to current legislation

Soil pollution prevention:

Activities are managed to prevent accidental release of substances into soil. Risk of contamination is mitigated through regular audits as part of the Environmental Management System (ISO 14001).

Targets

The Group has no public targets for waste management. However, through its ISO 14001 Environmental Management System, Cembre tracks performance via specific KPIs, including reduction of waste production through removal of the softener in the cutting department and from washing machine cleaning.

Policies related to own workforce

Cembre does not have a specifically named standalone policy for own workforce management. However, the company manages workforce-related impacts through several interconnected governance instruments and management systems:

Corporate Policy

• Governance: The responsibility for the Corporate Policy lies with the Company Management
• Scope: The policy applies to the Cembre Group
• Key content: The Corporate Policy promotes the empowerment, involvement, participation and listening of employees, as well as strengthening awareness on occupational health and safety issues. The company adopts an integrated approach involving all organisational levels through targeted training activities, systematic risk analysis and reduction, and the provision of safe and healthy working environments
• Public availability: Principles and guidelines discussed in the 'Environmental Information' chapter under 'Policies related to climate change mitigation and adaptation'

Company Management System

• Certifications: ISO 9001 (adopted at Group level) and ISO 45001 (for production units only)
• Scope: Harmonised across the company
• Key content: A structured system of operating procedures and instructions aimed at preventing accidents and injuries, including systematic risk analysis and reduction
• Monitoring: The system is constantly monitored through internal and external audits, periodic reviews of targets by management and a continuous personnel training programme

Code of Ethics

• Governance: Updated by the Board of Directors' resolution of 14 November 2024
• Scope: The Group's employees and collaborators are among the addressees of the Code
• Key content: Sets out fundamental principles and values that guide corporate conduct, with emphasis on:
  • Respect for personal dignity, privacy and the rights of every individual
  • Promotion of a working environment where men and women of different nationalities, cultures, religions and ethnicities cooperate in an atmosphere of mutual respect
  • Respect for the principle of equality, prohibiting any form of discrimination or harassment
  • Active upholding of internationally recognised human rights
  • Firm rejection of all forms of child or forced labour as understood by the ILO Minimum Age Convention No. 138/1973
  • Prohibition of discrimination or unfair treatment based on gender, race, disability, ethnic or cultural origin, religion or belief, age or sexual orientation
  • Protection of human and fundamental rights, including privacy of all employees
• International standards alignment: The document is inspired by the UN Guiding Principles on Business and Human Rights
• Public availability: Made publicly available on the company website (www.cembre.it)

Collective Bargaining Agreements

• Scope: Employees of Group companies located in Italy (Cembre S.p.A.), Spain (Cembre SLU), France (Cembre Sarl) and Germany (Cembre GmbH) are covered by national collective bargaining agreements or agreements with trade associations
• Key content: Aimed at protecting a level of remuneration deemed adequate with respect to international benchmarks or applicable national regulations

Social Protection Programmes

• Scope: All Cembre Group companies cover their employees through appropriate social protection instruments
• Key content: Coverage for:
  • Illness
  • Unemployment from the moment the worker works for the enterprise
  • Occupational injury and acquired disability
  • Parental leave
  • Retirement
• Implementation: For Cembre SpA, specific public programmes are provided by INPS, INAIL, METASALUTE and FASI. Other Group companies follow legislation in force in their specific countries, public programmes, trade association directives and corporate policies

Taking action on material impacts on own workforce

In accordance with the principles defined in its Corporate Policy and Code of Ethics, Cembre has implemented various actions to mitigate as far as possible the negative impacts generated or that could occur on its workforce.

The initiatives are divided into three macro-themes: training, welfare and health and safety in the workplace. These initiatives are implemented with full respect for human rights and workers' rights, ensuring equal opportunities for all without any gender distinction.

Note: The actions described represent activities already implemented in 2024 and, at present, do not include structured planning with specific objectives and dedicated budgets for future years.

Training

Cembre is committed to providing employees with comprehensive and customised training in line with their duties and seniority level in accordance with the internal procedures of the Integrated Company System and without making gender distinctions.

Scope: Own workforce

Training stages:

• Upon recruitment: new employees are trained on their specific tasks and company protocols
• In the event of a change in assignments: employees receive specific training for their new role
• When updating or changing procedures, processes, machinery or technology: training ensures employees are always up-to-date with latest developments

Implementation approach:

• The Personnel Department coordinates the training of employees
• Recording participation in courses
• Verifying effectiveness through evaluation
• Individual progress is measured and areas for improvement are identified
• Customised development paths are outlined
• The company defines minimum requirements for experience, preparation and training for different tasks

Link to impacts: This training plan makes it possible to avoid contributing to or minimise any negative impact on Group employees related to a potential lack of technical and professional development activities.

Welfare

[Note: Welfare mentioned as a macro-theme but specific actions not detailed in the excerpt]

Health and Safety in the Workplace

Cembre has implemented a harmonised Company Management System, compliant with:

• ISO 9001 (adopted at Group level)
• ISO 45001 (for production units only)

Specific measures:

• Structured system of operating procedures and instructions aimed at preventing accidents and injuries
• Constant monitoring through internal and external audits
• Periodic reviews of targets by management
• Continuous personnel training programme

Expected outcomes: Continuous improvement in occupational health and safety performance

Resources allocated: Not quantified

Targets related to own workforce

To date, Cembre has neither quantitative nor qualitative targets related to the management and monitoring of the impacts generated on the Group's people. However, the company recognises the importance of these aspects and is committed to developing appropriate strategies and tools in the near future to ensure a more structured approach to managing its employees.

Characteristics of the undertaking's employees

Total headcount and FTE

2024 headcount: 818 2023 headcount: Not disclosed

The average number of employees in 2024 was 903. For more details, please refer to section 24 'Personnel Costs' of the Group's Annual Report 2024.

Headcount by company and gender

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

Headcount by contract term (permanent/temporary)

Employee turnover

The turnover rate is calculated as the ratio of the number of dismissals in the year 2024 to the total number of employees as at 31/12/2024.

Headcount by age group

Methodology notes

The figures refer to the number of registered employees as at 31.12.2024 and are expressed in headcount. The metrics were obtained from the managers of the Group companies and validated by the Parent Company.

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

Number of non-employee workers

Below is information on the number of non-employee workers registered in the Group in 2024. The figures are expressed in headcount and refer to the number of workers within Cembre as at 31.12.2024.

Methodology

In the calculation of non-employees of the Cembre Group, temporary workers and trainees, including students in work-school alternation present as at 31 December 2024, were taken into account. Temporary workers, in particular, are generally hired on contracts of varying lengths (6, 8 or 12 months), which ensures their continuous presence for much of the year.

The figures are expressed in headcount (not FTE).

Collective bargaining coverage and social dialogue

The employment contracts applied to all Cembre SpA employees are the Italian National Collective Bargaining Agreements "CCNL Industria metalmeccanica e della installazione di impianti" and "CCNL Dirigenti Industria". In accordance with the provisions of the national bargaining agreement, the company provides for a minimum notice period of two weeks for its employees, if moved from one place to another.

The employment contracts of the European subsidiaries Cembre Sarl (France), Cembre GmbH (Germany) and Cembre España SLU (Spain) are drawn up in accordance with the collective agreements of the sector and the regulations in force in the various countries. In France, the minimum notice period is set at four weeks, while in Spain it is two weeks. In Germany, the minimum notice period is stated in the contract with the employee as it is an individual agreement. If the employment contract contains no rules or refers to the law, the statutory notice period of four weeks applies. Furthermore, for Cembre GmbH, only the general manager and the COO are not covered by the works council with which the management agrees on new hirings, dismissals and in general matters of common interest to the company.

The non-European subsidiaries Cembre Ltd. (UK) and Cembre Inc. (USA) enter into employment contracts with their employees on an individual basis. In the UK, the minimum notice period is usually 4 weeks and can be extended to 12-24 weeks for personnel with a significant length of service. In the United States, on the other hand, four weeks' notice is given whenever possible. However, since there are no applicable collective bargaining agreements or contracts, there is no obligation.

European locations

In all four European locations, 100% of employees are covered by collective bargaining, while the percentage of employees represented by union representatives varies according to location. It should be noted that there are no representation agreements by the European Works Council (EWC), the European Company (SE) Works Council or the European Cooperative Society (SCE) Works Council.

Non-European locations

Diversity metrics

Top Management Definition

The definition of top management in the Corporate Governance Code is as follows: "senior managers who are not members of the board of directors and have the power and responsibility for planning, directing and controlling the activities of the company and the group they head".

Based on this definition, the company considers that there are currently no top managers in the organisation chart as defined in the Corporate Governance Code 2020. Individuals with the aforementioned powers and responsibilities sit on the Board of Directors.

Top Management Gender Split

Table 24 - Top Management

Board Members by Gender

The Cembre Group's Board of Directors is composed of eight members equally divided between women and men, representing 50% of the total respectively.

Table 25 - Board members by gender and age group

Personnel by Age Group

Table 26 - Personnel by age group

Adequate wages

S1-10

Employees of Group companies located in Italy (Cembre S.p.A.), in Spain (Cembre SLU), in France (Cembre Sarl) and in Germany (Cembre GmbH) are covered by national collective bargaining agreements or agreements with trade associations aimed at protecting a level of remuneration deemed adequate with respect to international benchmarks or applicable national regulations.

With regard to the Group's production site in the UK and the sales site in the US, the official government and labour sites set a minimum hourly wage that is considered adequate. In particular, in the US, the average wage is about twice the minimum wage. The new Chinese business site also provides for a collective bargaining system for the registered employee, which safeguards obtaining a fair wage.

It should also be noted that the average hourly remuneration analysed also in relation to the Gender Pay Gap indicator and detailed in the paragraph "Remuneration metrics (pay gap and total remuneration)", is higher than the minimums established by national regulations for all Group companies.

Benchmark

No specific living wage benchmark disclosed. The company references:

• National collective bargaining agreements (Italy, Spain, France, Germany)
• Minimum hourly wage set by government and labour sites (UK, US)
• Collective bargaining system (China)
• National minimum wage regulations (all Group companies)

Coverage

All Group companies are stated to pay above minimum wage established by national regulations, but no specific percentage of workforce assessed against a living wage benchmark is provided.

Geographic scope

Global coverage across all operating countries: Italy, Spain, France, Germany, UK, US, China.

Targets

No forward-looking targets or commitments disclosed.

Methodology

No living wage calculation methodology disclosed. Assessment is based on compliance with national minimum wage regulations and collective bargaining agreements.

Social protection

All Cembre Group companies cover their employees through the appropriate social protection instruments against loss of income due to major life events.

Cembre SpA coverage

Cembre SpA, through specific public programmes (provided by INPS, INAIL, METASALUTE and FASI) covers workers for all the following events:

• Illness
• Unemployment from the moment the own worker works for the enterprise
• Occupational injury and acquired disability
• Parental leave
• Retirement

Group coverage

The aforementioned macro-categories of events are also covered by all other Group companies according to:

• The legislation in force in the specific countries of reference
• Public programmes
• The directives of the trade associations to which they belong
• The corporate policies implemented by the individual company

Coverage percentage: Not disclosed (qualitative statement indicates all employees are covered)

Scheme type: Public programmes (INPS, INAIL, METASALUTE, FASI for Cembre SpA; country-specific public programmes and corporate policies for other Group companies)

Country breakdown: Not disclosed beyond Italy (Cembre SpA)

Exclusions: None stated

Persons with disabilities

As at 31 December 2024, the Cembre Group had 24 workers with disabilities, corresponding to approximately 3% of its total workforce.

Methodology note: For methodological purposes, in the calculation carried out for Cembre SpA, only persons with disabilities were considered, not including the two protected categories present at the headquarters.

Training and skills development metrics

Average training hours by gender

Performance and career development reviews

Health and safety metrics

Coverage of health and safety management system

77.3% of the Group's employees are covered by the Health and Safety Management System according to ISO 45001 certification.

Occupational accidents and injuries (2024)

Occupational disease and lost days (2024)

Methodology notes

Data on safety in the workplace were provided by the management software used by human resources, the company doctor's report and the files used for accident management.

Work-life balance metrics

All Cembre Group employees are entitled to family leave in accordance with the specific national laws in force in their countries.

Family leave uptake in 2024

Entitlement: 100% of employees are entitled to family leave in accordance with specific national laws in their countries of operation.

Return-to-work rates: Not disclosed.

Compensation metrics (ESRS S1-16)

Pay gap

The weighted average of the gender pay gap in the Cembre Group, calculated as the percentage between women's and men's average gross hourly earnings, is 21.18%.

Remuneration ratio

The Cembre Group's average remuneration ratio between the highest paid person and the average annual remuneration of all employees excluding the highest paid is 4.06.

In the calculation, the numerator includes the remuneration and bonuses received by the executive who is also a member of the Board of Directors, while the denominator takes into account the figures for all employees employed by Cembre in the reference year.

Methodology

For the calculation of the weighted average hourly wages, each company of the Cembre Group was given a weight in proportion to the number of female and male employees. This method allows the impact of each company on the overall average figure to be more accurately reflected, taking into account its size in terms of workforce.

An approximate rate of 1.21 was used to convert the amount from GBP to euro (for Cembre Ltd.) while an approximate rate of 0.9702 was used to convert USD to euro (for Cembre Inc.).

It should be noted that the Chinese site was not included in the calculation of the indicators because only one employee was registered as at 31.12.2024.

Policies related to value chain workers

Cembre does not have a dedicated Supplier Code of Conduct. However, the company applies two primary instruments to address value chain worker policies:

Code of Ethics

• Scope: All those who work for or are linked to the Group, including value chain partners
• Governance: Approved by the Board of Directors
• Public availability: Available on the company website
• Key content and principles:
  • Active commitment to promote and protect internationally recognised human rights
  • Elimination of all forms of discrimination
  • Categorical rejection of child and forced labour
  • Prohibition of commercial relationships with organisations that practice child or forced labour or whose products come from areas where human rights are not adequately respected
  • Zero tolerance for discrimination or unfair treatment based on gender, race, disability, ethnic or cultural origin, religion, personal beliefs, age or sexual orientation
• Link to international standards: The Code pursues the principles of:
  • United Nations (UN) Global Compact
  • Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises
  • International Labour Organisation (ILO) Conventions
  • International Chamber of Commerce (ICC) Charter for Sustainable Development

Supplier specifications (Chapter 1050)

• Scope: Applicable to all supplies to Cembre Group companies
• Key content and principles:
  • Quality, environmental and health and safety management prescriptions
  • Social responsibility requirements for suppliers of products and services
  • Suppliers must respect the fundamental principles of the Code of Ethics
  • Suppliers must ensure activities and product development comply with requirements concerning human rights, working conditions, and health and safety of workers
  • Formal acceptance required from each supplier
• Monitoring and implementation:
  • Suppliers must allow access to their plants and offices (including sub-suppliers) for verification of requirements implementation
  • In case of serious and/or repeated non-compliance, Cembre reserves the right to suspend or terminate business relations
  • Preference given to suppliers with certified Quality, Environmental and Occupational Health and Safety Management Systems from independent, internationally recognised third-party bodies
• Link to international standards: The specifications pursue the principles of:
  • United Nations (UN) Global Compact
  • Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises
  • International Labour Organisation (ILO) Conventions
  • International Chamber of Commerce (ICC) Charter for Sustainable Development

Additional policy commitment

• Conflict Minerals: Cembre adheres to the Conflict Minerals Rules to avoid purchase and use of minerals whose trade could finance or favour armed groups in Conflict Regions (Democratic Republic of Congo and neighbouring countries) or not certified as Conflict-Free

Performance

In 2024, there were no instances of non-compliance by Group suppliers with human rights requirements according to the UN Global Compact, OECD Guidelines, ILO Conventions or ICC Charter for Sustainable Development.

Taking action on material impacts on value chain workers

Supplier Adherence to Specification 1050

Action: Require all suppliers to adhere to the principles of social protection defined in Specification 1050, through the completion of a specific checklist.

• Scope: Upstream value chain (suppliers)
• Link to policy: Code of Ethics and Specification 1050
• Time horizon: Not specified
• Resources allocated: Not specified

Procurement and Supplier Approval Procedure

Action: Implementation of a Procurement and Supplier Approval Procedure to regulate the purchase of materials, products and services and define criteria for evaluating and monitoring suppliers.

• Scope: Upstream value chain (suppliers)
• Purpose: Ensure compliance with contractual requirements, including those set forth in the Integrated Management System
• Link to policy: Code of Ethics and Specification 1050
• Time horizon: Not specified
• Resources allocated: Not specified
• Process:
  • Procurement Department defines at annual Management Review whether suppliers include companies with production cycles with high environmental or worker health and safety impact
  • Suppliers not meeting security requirements classified as 'Not Qualified'

Annual Supplier Health and Safety Audits

Action: Annual specific audit of the health and safety risk of workers and the presence of procedures to mitigate these risks for suppliers with high impact production cycles.

• Scope: Upstream value chain (suppliers with high environmental or worker health and safety impact)
• Time horizon: Annual
• Resources allocated: Not specified
• Verification method: Audits, questionnaires or interviews conducted by Procurement Department in cooperation with relevant functions
• Expected outcomes: Results documented and brought to attention of management and functions involved
• KPIs: Not specified

On-site Quality Audits

Action: On-site audits at suppliers conducted if deemed necessary, with exclusive focus on quality, prior to the start of a business relationship.

• Scope: Upstream value chain (new suppliers)
• Time horizon: Prior to business relationship commencement
• Resources allocated: Not specified
• Current limitation: Focused exclusively on quality

Gaps Acknowledged

The company explicitly states:

• A structured disclosure process to monitor possible human rights violations along the value chain has not yet been implemented
• Systematic action for the mitigation of labour relations risks is not planned
• No specific objectives have been formalized for the management of significant negative impacts related to workers along the value chain (S2-5)

Policies related to affected communities

Cembre does not disclose any specific named policy dedicated to affected communities under ESRS S3-1.

The company states that it adopts a "structured approach based on its Corporate Policy" to manage material impacts, risks and opportunities related to the protection of local communities. However, this Corporate Policy is not named or described in detail in the S3-1 disclosure.

Corporate Policy (referenced but not detailed)

• Governance: Responsibility lies with Company Management
• Linkages: The company refers to principles and guidelines discussed in other sections:
  • Chapter 'General Information', paragraph 'Stakeholders' Interests and Opinions'
  • Chapter 'Environmental Information', paragraph 'Policies related to climate change mitigation and adaptation policies'
• Remediation mechanisms: Cembre provides a whistleblowing system that allows affected communities to raise concerns regarding negative impacts in terms of human rights

The disclosure directs readers to other sections of the report for detailed policy content rather than providing a standalone description of policies related to affected communities.

Taking action on material impacts on affected communities

Overview

The Cembre Group maintains a strong relationship with the territory where it is based, supporting the prosperity of the territory by maintaining employment levels, promoting relations with local communities and creating shared value, thus contributing to the socio-economic development of the area.

Training and youth development initiatives

Scope: Own operations (local communities)

Action 1: Career guidance and student engagement

Cembre S.p.A. actively invests in the training and growth of young people in the area, collaborating with Professional Institutes and Universities. In 2024, initiatives included:

• Company visits dedicated to students from Brescia universities and technical institutes
• Participation in orientation fairs: 'SMART FUTURE BRESCIA 24' and 'DOMANI LAVORO', meeting over 700 students and more than 150 professionals

Action 2: Internship and school-to-work programmes

In 2024, Cembre S.p.A. welcomed:

• 10 university students for curricular internships and thesis development
• 16 students from various Technical and Vocational Institutes in the province
• 1 ITS Lombardy Mechatronics student for alternation school-to-work periods

Resources allocated: Donation of supplies to educational laboratories for a total value of over €2,000

Action 3: Customer training

The Cembre Group invests annually in training of end customers, with a main focus on technical skills.

Resources allocated: More than 250 hours of training provided in 2024

Social and charitable initiatives

Scope: Own operations (local communities)

Cembre S.p.A. is actively engaged in the promotion of social, medical, educational and territorial enhancement initiatives.

Resources allocated (2024): €56,500 in donations to:

• Save the Children
• Telefono Azzurro Rosa
• Medicus Mundi
• AIRC Foundation
• San Vincenzo De Paoli Dormitory Association
• MUSEKE Foundation

Trade association membership

Cembre is a member of different trade associations, to contribute to the creation of a more sustainable economic and social system, in the general interest.

Policies related to consumers and end-users

Cembre does not disclose a specific named policy dedicated to consumers and end-users under ESRS S4-1. Instead, the company states that it manages material impacts, risks and opportunities related to consumers and end users through its Corporate Policy.

Corporate Policy

• Governance: The responsibility for this policy lies with the Company Management
• Scope: The policy addresses product quality control to safeguard the health and safety of employees and users of products sold. It aims to involve all levels of the organisation through training, analysis and systematic risk reduction
• Key content:
  • Product quality control focused on health and safety
  • Continuous improvement of the Corporate Management System
  • Implementation of ISO 9001 to improve customer satisfaction and efficiency of business processes
  • Stakeholder engagement to understand needs and expectations of consumers and end users
  • Whistleblowing system available for customers to express concerns regarding negative impacts in terms of human rights
• Public availability: Not disclosed
• Link to international standards: The policy references the UN Guiding Principles on Business and Human Rights and OECD Guidelines (mentioned in the reference index)
• Monitoring: Not disclosed

The company notes that the principles and guidelines of the Corporate Policy are discussed in more detail in the 'Environmental Information' chapter under 'Policies related to climate change mitigation and adaptation', suggesting this is a broad corporate-level policy rather than a specific consumer-focused policy.

Taking action on material impacts on consumers

Cembre has made the protection of Safety a distinctive element of its business and corporate approach, guaranteeing products of the highest quality and turning its attention to health and safety issues, reflected in the production of safe products.

Company Management System monitoring

Scope: Own operations

Actions:

• Continuous monitoring through internal and external audits
• Verification of objectives by Management
• Continuous personnel training

Product health and safety controls

Scope: Own operations (design phase)

Actions:

• Strict controls, checks and validations from the design phase ensuring:
  • Products meet customer requirements in terms of fitness for purpose, user-friendliness, ergonomics and safety
  • Products comply with applicable legal requirements and standards (electromagnetic compatibility, noise and vibration)
• Materials compliance checking against international directives (Reach, RoHS directives, etc.)

Customer satisfaction and complaints management

Scope: Own operations

Actions:

• Annual Management Review for Company Management System documenting:
  • Actions implemented and state of completion
  • Objectives set and achievement status
• Complaints handling process:
  • Opening of Non-Compliance
  • Analysis with technical department involvement
  • Definition of treatment actions to contain problems and corrective actions for permanent resolution
  • Filing sent to management and other departments
• Quality meetings for recurring component problems
• KPIs and targets defined to monitor effectiveness
• Customer satisfaction and loyalty results collection

Expected outcomes: Monitoring through KPIs on customer satisfaction and loyalty

Time horizon: Annual review cycle

Links to policy/target: Objectives set in Management Review as explained in S4-5

Performance (2024)

• Zero cases of non-compliance with laws/regulations related to products and services
• Zero cases of non-compliance in relation to information and labelling
• No corrective actions required

Targets related to consumers

At present, the Group has no measurable public objectives related to the management of risks and opportunities for consumers and end users.

However, through its Safety Management System according to ISO 45001, Cembre monitors its performance related to consumers and end users through specific internal KPIs, including:

• Number of complaints
• Reports of non-compliance

No quantified targets, target years, baseline years, or baseline values are disclosed for these KPIs.

Business conduct policies and corporate culture

Cembre has established several policies related to business conduct and corporate culture, approved by the Board of Directors and communicated to all stakeholders.

Code of Ethics

Policy name: Code of Ethics

Scope: All internal stakeholders (shareholders, directors, auditors, employees) and external stakeholders (consultants, suppliers, business partners). Adopted at Group level, containing values and principles that all Group companies must be inspired by in carrying out their activities.

Governance: Last updated and approved by the Board of Directors in November 2024. Directors and Executives must behave in line with corporate principles, encouraging the application and interpretation of the Code and communicating its validity to all addressees.

Key content/principles:

• Standard of conduct aimed at preventing the commission of offences connected with the activities of the Cembre Group
• Rules of conduct pursuing principles of good business conduct (principle of legality, dignity and equality, integrity, fairness and transparency)
• Prevention of conflict of interest and corruption
• Management of information systems and intellectual and industrial property
• Relations with employees, suppliers, customers, collaborators and other material communities
• Management of corporate information
• Health and safety at work and environmental protection
• Recognition and respect for personal dignity, privacy and personality rights of any individual
• No discrimination, harassment or sexual, personal or other offences tolerated
• Refusal of all types of child or forced labour
• Respect for internationally recognised human rights

Public availability: Publicly available on the company website www.cembre.it

Links to international standards:

• Principles of the UN Global Compact
• OECD Guidelines for Multinational Enterprises
• ILO Conventions
• ICC Charter for Sustainable Development
• United Nations Convention against Corruption

Monitoring implementation:

• Addressees subject to sanctions in the event of violation of provisions
• Presence of whistleblowing reporting system
• Communication at time of recruitment; updates communicated by publication in workplace, company network and website
• Training provided through mandatory classroom or online course sessions every five years, updated in event of regulatory or procedural changes

Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001 (Model 231)

Policy name: Organisation, Management and Control Model pursuant to Legislative Decree No. 231/2001

Scope: All Cembre personnel and activities

Governance:

• Adopted and deliberated by the Board of Directors
• Supervisory Board (SB) composed of three members with proven professional skills, responsible for monitoring effectiveness, application and updating of the Model
• SB receives dedicated fund or autonomous spending powers
• SB reports periodically to the Chair, CEO, Board of Directors and Board of Auditors

Key content/principles:

• Suitable for preventing administrative offences introduced by Legislative Decree 231/2001
• Principle of segregation of duties
• Control activities protected by the Board of Directors

Monitoring implementation:

• SB receives regular information flows from various corporate functions
• SB addresses material issues during meetings with other corporate control bodies
• Ongoing updates to Chair and CEO, half-yearly reports to Board of Directors and Board of Auditors
• Annual action plan prepared by SB
• Training provided to personnel through mandatory sessions, updated when internal regulatory or procedural changes occur
• Training every five years, adapted to qualification of recipients, risk level and presence of representative powers
• Presence communicated at time of recruitment; updates via workplace publication, company network and website

Anti-Corruption Policy

Policy name: Anti-Corruption Policy

Scope: Cembre S.p.A. has adopted an anti-corruption policy and an anti-corruption system pursuant to ISO 37001

Governance:

• Compliance Function for the Prevention of Corruption set up as part of the Management System for Prevention of Corruption adopted pursuant to ISO 37001
• In charge of implementing audits, analyses and investigations in event of violations by employees, collaborators or business partners

Key content/principles:

• Prevention of corruption throughout business activities
• Anti-corruption system pursuant to ISO 37001

Links to international standards:

• ISO 37001 Anti-Bribery Management Systems
• United Nations Convention against Corruption

Monitoring implementation:

• Anti-corruption training aimed at personnel exposed to medium-high level of risk
• Training updated when internal regulatory or procedural changes occur
• In 2024, 38.2% of Cembre personnel (313 out of 818 employees) considered medium to high risk received training
• 100% of figures considered medium-high risk for Cembre S.p.A. headquarters trained
• Country managers and department heads for Group subsidiaries trained
• Personnel classified into three risk categories based on role and functions
• Administrative, management and supervisory bodies included in high risk class and required to observe Conflict of Interest Management Procedure

Whistleblowing System

Policy name: Whistleblowing Procedure

Scope: Employees, managers, members of corporate bodies, collaborators, consultants and third parties bound by contractual or professional ties with the Company

Governance:

• Reporting Manager prepares annual report summarising reports received, analyses performed and outcome
• Report sent to Chair of Board of Directors
• Chair of Board of Directors decides whether to initiate disciplinary proceedings against persons reported

Key content/principles:

• Management of reporting of unlawful conduct or conduct in conflict with Legislative Decree 231/2001, Code of Ethics and Anti-Corruption Policy
• Three reporting channels: internal, external and public disclosure, used in progressive and subsidiary manner
• Dedicated IT platform for internal reports, compliant with current legislation and ANAC guidelines
• Reports can be made anonymously
• Protection of confidentiality of reporting persons and information transmitted
• Protection from retaliation or discrimination pursuant to Regulation (EU) 2016/679 and Directive (EU) 2019/1937
• Specific protection measures (prohibition of dismissal or demotion, non-conversion of contract or personal injury)

Public availability: Information on channels displayed in workplace and on company website

Links to international standards:

• Regulation (EU) 2016/679 (GDPR)
• Directive (EU) 2019/1937 (Whistleblower Protection Directive)

Monitoring implementation:

• Annual report by Reporting Manager summarising reports received during year, analysis performed and outcome
• Presence communicated to all employees at time of hiring
• Information displayed in workplace and on company website
• Training on whistleblowing provided every five years as part of Model 231 training
• Training updated in event of regulatory or procedural changes

Supplier Specifications (Chapter 1050)

Policy name: Supplier specifications (Chapter 1050)

Scope: All suppliers of products and services to Cembre Group companies

Key content/principles:

• Specific prescriptions for quality, environmental and health and safety management, as well as social responsibility
• Suppliers required to respect fundamental principles of Code of Ethics
• Activities and product development must comply with requirements concerning human rights, working conditions, and health and safety of workers
• Adherence to Conflict Minerals Rules to avoid purchase and use of minerals whose trade could finance or favour armed groups in Conflict Regions
• Policy to favour suppliers with Quality, Environmental and Occupational Health and Safety Management Systems certified by independent and internationally recognised third-party bodies

Links to international standards:

• Principles of UN Global Compact
• OECD Guidelines for Multinational Enterprises
• ILO Conventions
• ICC Charter for Sustainable Development

Monitoring implementation:

• Suppliers must allow access to plant and offices (own and sub-suppliers) for verification of correct implementation
• In event of serious and/or repeated non-compliance, Cembre reserves right to suspend or terminate business relations
• In 2024, no instances of non-compliance by Group suppliers with human rights requirements

Corporate Policy

Policy name: Corporate Policy

Scope: All employees and operations

Governance: Responsibility lies with Company Management

Key content/principles:

• Promotes empowerment, involvement, participation and listening of employees
• Strengthens awareness on occupational health and safety issues
• Promotes working environment where men and women of different nationalities, cultures, religions and ethnicities cooperate in atmosphere of mutual respect
• Defines relationship with employees based on respect, trust and enhancement of skills
• Promotes professional development through targeted training programmes
• Recognises individual merits and capabilities

Monitoring implementation:

• Harmonised Company Management System compliant with ISO 9001 (adopted at Group level) and ISO 45001 (for production units only)
• System of operating procedures and instructions
• Constantly monitored through internal and external audits
• Periodic reviews of targets by management
• Continuous personnel training programme

Prevention and detection of corruption and bribery

Cembre states that G1-3 (Prevention and detection of active and passive corruption) is not material to its operations.

Despite the non-materiality assessment, the company has disclosed the following policies and systems:

Code of Ethics

• Scope: Adopted at Group level, containing values and principles that all Group companies must be inspired by in carrying out their activities
• Key content: Establishes corporate principles and rules of conduct; violations are subject to sanctions
• Public availability: Published in the workplace, on the company network and on the website
• Monitoring: Directors and Executives must behave in line with corporate principles, encouraging application and interpretation of the Code

Anti-Corruption Policy

• Scope: Group-wide policy
• Approval and oversight: The Compliance Function for the Prevention of Corruption is in charge of implementing audits, analyses and investigations in the event of violations by employees, collaborators or business partners
• Key content: Defines rules of conduct related to anti-corruption; integrated with Model 231 and ISO 37001 framework
• Public availability: Communicated to all personnel at recruitment; updates communicated through publication in the workplace, on the company network and on the website
• International standards: Anti-corruption system adopted pursuant to ISO 37001
• Monitoring and implementation:
  • Training provided to personnel exposed to medium-high risk levels (38.2% of Cembre personnel - 313 out of 818 employees in 2024)
  • Training provided to 100% of medium-high risk figures for Cembre S.p.A. headquarters and to country managers and department heads for Group subsidiaries
  • Anti-corruption training updated when internal regulatory or procedural changes occur
  • Personnel classified into three risk categories based on role and functions
  • Administrative, management and supervisory bodies included in high risk class and required to observe the Conflict of Interest Management Procedure
  • Whistleblowing system in place with internal IT platform compliant with current legislation and ANAC guidelines
  • Annual reporting by the Reporting Manager to the Chair of the Board of Directors on reports received, analyses performed and outcomes

Model 231 (Organizational, Management and Control Model)

• Scope: Applies to all addressees within the company
• Approval and oversight: Supervisory Board oversees implementation
• Key content: Updated whenever changes to Legislative Decree 231/2001 or company structure are identified; integrated with Code of Ethics and Anti-Corruption Policy
• Public availability: Communicated to all personnel at recruitment; updates communicated through publication in the workplace, on company network and on website
• Links to standards: Pursuant to Legislative Decree 231/2001
• Monitoring: Training provided every five years, updated in event of regulatory or procedural changes; contents adapted to qualification of recipients, risk level of operational areas and presence of representative powers

Whistleblowing System

• Scope: Covers employees, managers, members of corporate bodies, collaborators, consultants and third parties bound by contractual or professional ties with the Company
• Key content: Manages reporting of unlawful conduct or conduct in conflict with Legislative Decree 231/2001, Code of Ethics and Anti-Corruption Policy; reports can be made anonymously through three channels: internal, external and public disclosure
• Governance: Dedicated IT platform compliant with current legislation and ANAC guidelines; Reporting Manager prepares annual report sent to Chair of Board of Directors
• Links to standards: Compliant with Regulation (EU) 2016/679, Article 2-quaterdecies of Personal Data Protection Code (Legislative Decree 196/2003) and Directive (EU) 2019/1937
• Implementation: Guarantees confidentiality and protection from retaliation or discrimination; specific protection and liability limitation measures provided

Incidents of corruption or bribery

Disclosure status

Cembre classified ESRS G1-4 (Established cases of active or passive corruption) as not material in its ESRS content index (Table 8).

The company states in its Reference Index (Table 9):

ESRS G1-4: Fines imposed for violations of laws against active and passive corruption, paragraph 24(a) – Not material

ESRS G1-4: Rules for combating active and passive corruption, paragraph 24(b) – Not material

Investigation and speak-up mechanisms

Cembre has adopted:

• An anti-corruption policy and anti-corruption system pursuant to ISO 37001
• A whistleblowing reporting system allowing employees, collaborators, consultants and third parties to report unlawful conduct or violations of Legislative Decree 231/2001, the Code of Ethics and the Anti-Corruption Policy
• Three reporting channels: internal (dedicated IT platform), external, and public disclosure
• A Compliance Function for the Prevention of Corruption responsible for implementing audits, analyses and investigations in the event of violations

The whistleblowing system ensures confidentiality and protection from retaliation. The Reporting Manager prepares annual reports summarizing reports received, analyses performed and outcomes.

Anti-corruption training

In 2024:

• 38.2% of Cembre personnel (313 out of 818 employees) are considered medium to high risk for corruption
• 100% of figures considered medium-high risk for Cembre S.p.A. headquarters receive anti-corruption training
• Country managers and department heads for Group subsidiaries receive training
• Training is updated when internal regulatory or procedural changes occur

Quantitative metrics

No specific numbers of confirmed incidents, convictions, fines paid, employees disciplined, or contracts terminated were disclosed in the 2024 sustainability report, consistent with the company's assessment that G1-4 is not material to its operations.

Political influence and lobbying activities

Materiality assessment

Cembre has assessed ESRS G1-5 (Political influence and lobbying activities) as not material to its operations and sustainability strategy.

Trade association memberships

Cembre is a member of different trade associations, contributing to the creation of a more sustainable economic and social system in the general interest. The company participates in work and thematic committees of trade associations as part of its engagement with companies in the sector.

No quantitative disclosure of membership fees or contributions paid to trade associations is provided.

Stakeholder engagement

With regard to engagement with institutions, Cembre maintains attention to awareness-raising campaigns by environmental associations and analyses by the scientific community. The company engages in discussion and dialogue tables with Public Administration, particularly in relation to local communities.

The company does not disclose:

• Political contributions made
• Lobbying expenditure
• Names of specific trade associations
• Registration in the EU Transparency Register or equivalent
• Formal political engagement approach or ethical standards for political activities

Payment practices

G1-6 Payment Practices is assessed as not material by Cembre.

No quantitative disclosures are provided for:

• Average time to pay invoices
• Standard contractual payment terms
• Number or value of legal proceedings for late payment
• Compliance with prompt payment code