Clariane

The role of the administrative, management and supervisory bodies

Board of Directors

The Clariane Board of Directors comprises 16 Directors including:

• Independent Directors: 57% (9 Directors)
• Women: 43% (7 Directors)
• Average age: 56
• International experience: 73%
• 6 nationalities represented
• 15 meetings in 2024 with 92% attendance rate

Key Board Members:

• Jean-Pierre Duprieu: Chairman of the Board of Directors (not seeking reappointment due to statutory age limit)
• Sylvia Metayer: Incoming Chair of the Board (Independent Director, to succeed Duprieu at General Meeting on 14 May 2025)
• Sophie Boissard: Chief Executive Officer

Institutional Directors:

• Predica (represented by Florence Barjou)
• HLD Europe (represented by Julie Le Goff)
• Leima Valeurs (represented by Ondřej Novák)
• Jean-Bernard Lafonta

Employee Directors:

• Marie-Christine Leroux
• Gilberto Nieddu

Independent Directors:

• Guillaume Bouhours
• Dr Jean-François Brin
• Patricia Damerval
• Anne Lalou
• Philippe Lévêque
• Dr Markus Müschenich
• Sylvia Metayer

Four Specialised Committees

1. Audit Committee - chaired by Guillaume Bouhours
2. Compensation and Appointments Committee - chaired by Anne Lalou
3. Ethics, Quality and CSR Committee - chaired by Philippe Lévêque
4. Investment Committee - chaired by Predica (Florence Barjou, permanent representative)

Executive Committee

7 members including:

• Sophie Boissard: Chief Executive Officer

• Rémi Boyer: Deputy Chief Executive Officer and Managing Director of Korian Germany

• Anne-Charlotte Dymny: Group Chief Information Technology Officer and Chair of Clariane Spain

• Sébastien Legrand: Director of the Better Support programme

• Grégory Lovichi: Group Chief Financial Officer

• Charles-Antoine Pinel: Group Chief Revenue and Development Officer

• Nadège Plou: Group Chief Human Resources Officer

• Guillaume Appéré: Executive Secretary

• 43% women

• 1 nationality

• Average age: 49

• Weekly meetings to implement Better Support programme and prepare governance body meetings

Group Management Board

14 members with:

• 51 average age
• 3 nationalities
• 29% women
• 26 meetings in 2024
• Participation in Board's specialised Committees and strategic seminars

Country and Business Line Management:

• Dominiek Beelen: Managing Director of Korian Benelux
• Marion Cardon: Managing Director of Korian France
• Federico Guidoni: Managing Director of Korian Italy
• Nicolas Mérigot: Managing Director of Clariane France
• Charles-Antoine Pinel: Group Chief Revenue and Development Officer

Group Functions:

• Frédéric Durousseau: Chief Executive Officer of Clariane Immobilier
• Anne-Charlotte Dymny: Group Chief Information Technology Officer and Chair of Clariane Spain
• Grégory Lovichi: Group Chief Financial Officer
• Nicolas Pécourt: Group Chief Communications Officer
• Antoine Piau: Group Chief Medical, Ethics and Health Innovation Officer
• Nadège Plou: Group Chief Human Resources Officer
• Guillaume Appéré: General Secretary

Mission Committee

14 members including:

• Nicolas Truelle: Chair of the Mission Committee (former Chairman of Apprentis d'Auteuil Foundation)
• 62 average age
• 4 nationalities
• 29% women
• 4 plenary sessions and working group meetings in 2024

Stakeholder Council Chairs:

• Chairman of Clariane Germany Stakeholder Council
• Chair of Clariane France Stakeholder Council
• Chairman of Clariane Italy Stakeholder Council
• Chairman of Clariane Netherlands Stakeholder Council

Internal Members:

• Martina Nickel: Social worker at Haus der Betreuung und Pflege Vienenburg nursing facility, Germany
• Chair of the Clariane Women's Club
• Bo Swolfs: Director of De Muze care home, Belgium
• Rehabilitation manager in day hospital of post-acute and rehabilitation care clinic

External Experts:

• Moira Allan: Co-founder and international coordinator of non-profit Pass It On
• Jean-Marie Bockel: Former Minister and Mayor of Mulhouse
• Former Chairman of Mutualité française
• Director of impactful private debt management at Eiffel Investment Group
• Chairman of non-profit Les Papillons Blancs de la Colline and Sustainable Development Senior VP at Veolia

Skills represented:

• Knowledge of the healthcare sector
• Knowledge of stakeholders
• Field experience
• Fairness, sustainability, locality and innovation expertise

Integration of sustainability-related performance in incentive schemes

Overview

Clariane has integrated sustainability performance into its incentive schemes since 2020, with carbon emissions reduction criteria included in variable remuneration targets for senior executives.

Two main incentive and variable compensation schemes are implemented within the Clariane Group, directly linked to the structure of the Group Chief Executive Officer's variable compensation:

• Annual variable compensation (Short-term incentive)
• Long-term performance share plan (Long-term incentive)

Roles covered

The incentive schemes apply to:

• Annual variable compensation: Executives, directors and all managers in each country of operation
• Long-term performance share plan: Members of top management, certain functions considered key to the Company, and certain high-potential employees
• Identical criteria are applied throughout the Group for the long-term plan

Structure of incentive schemes

Annual variable compensation (STI)

• Calculated as a percentage of annual fixed salary
• Contingent on the achievement of financial and sustainability criteria, in line with the Group's main material matters
• Depending on the country, certain sustainability criteria and allocation percentages may be adjusted to give as accurate a picture as possible of the country's priorities

Long-term performance share plan (LTI)

• Allocation of a number of free performance shares with a vesting period of three years, subject to a continued service condition
• Contingent on the achievement of financial and sustainability criteria, in line with the Group's main material matters

Sustainability KPIs and weighting for 2024

For the Group Management Board and top management, sustainability criteria represent 30% of variable compensation in 2024:

Additional criteria linked to stakeholders are also embedded in the compensation structure:

Financial criteria (subject to a financial multiplier of 0.8 to 1.2):

• EBITDA
• Financial leverage (Wholeco ratio)
• Organic growth
• Revenue
• Operating cash flow

Additional sustainability criteria mentioned:

• 25% Energy intensity
• 25% Reduction in energy-related carbon emissions (Scopes 1.1, 2 & 3.3)
• 25% Employee engagement
• 25% Facility Director and Deputy Director posts filled internally
• 20% Qualitative criteria including execution of the disposal plan and strategic financing roadmap, and contribution to the public debate to promote fair and sustainable regulation of care activities

Performance period and target structure

• Annual variable compensation: Annual performance period
• Long-term performance share plan: Three-year vesting period

Link to transition plan

Carbon impact criteria are embedded within the Group's real estate and asset management strategy, investment process and purchasing strategy, thereby supporting the implementation of the transition plan.

The inclusion of energy consumption and carbon footprint performance criteria in the Group's short- and long-term variable compensation reflects the Group's focus on its mitigation objectives.

Integration since 2020

The Group has included carbon emissions reduction criteria as part of its variable remuneration targets for senior executives since 2020.

Governance integration

More than 12 of the Group's FTEs are responsible for implementing the actions of the energy transition plan within different functions (management, technical, real estate, maintenance, processes and tools, etc.).

Risk management and internal controls over sustainability reporting

Control Environment

Definition and objectives of internal control

The Group's internal control system is designed to provide reasonable assurance that:

• operations are effective and efficient;
• financial information is reliable;
• laws and regulations are complied with.

Internal control cannot provide an absolute guarantee that the Group's objectives will be achieved, that all risks will be eliminated, or that fraud will be prevented.

Internal control stakeholders

The internal control system involves all Group employees at their own level.

The Board of Directors approves the main strategic, economic, financial and technological orientations of the Group's business and monitors their implementation. It also ensures the quality of information provided to shareholders and to the market, through the financial statements and when major transactions are announced.

The Audit Committee of the Board of Directors is notably responsible for:

• monitoring the financial reporting process;
• monitoring the effectiveness of internal control, internal audit and, where applicable, risk management systems;
• monitoring the statutory audit of the annual and consolidated financial statements by the Statutory Auditors;
• monitoring the independence of the Statutory Auditors.

The Chief Executive Officer is responsible for the internal control system.

Group General Management (Chief Executive Officer, Deputy Chief Executive Officer and Group Management Board) defines the Group's strategic policy and supervises its implementation. It ensures the proper operation of the Group's internal bodies and the accuracy of the accounts. It ensures that the acts and operations it authorises comply with the corporate purpose, legal and regulatory provisions and the Company's internal procedures.

The Risk, Ethics and Compliance Committee, chaired by the Chief Executive Officer, defines and monitors the implementation of risk management policy and ensures the Group's compliance with applicable laws and regulations as well as with its ethical rules. The Committee meets quarterly.

Internal control systems for sustainability information

The collection of non-financial data follows a structured process:

• Collection perimeter: Data is collected from all entities included in the financial consolidation perimeter, except for entities held for less than 12 months or with limited activity.
• Reporting tool: A dedicated digital platform standardises data collection across all countries
• Data validation: A multi-level validation process involving facility managers, country teams, and Group level review
• External verification: Independent third-party verification of key sustainability indicators
• Quarterly reporting: Non-financial KPIs are monitored quarterly alongside financial metrics

The Group has implemented specific controls for ESG data including:

• Automated validation rules in the reporting system
• Regular training for data contributors
• Documentation of calculation methods and data sources
• Reconciliation procedures between operational and reported data
• Independent third-party assurance on material ESG indicators

Internal control systems for financial and accounting information

The internal control system for accounting and financial information aims to prevent and control risks of errors or fraud susceptible to affect the accuracy of the accounts, financial information and accounting data.

Key components include:

• Segregation of duties between operational functions and control functions
• Monthly closing procedures with variance analysis
• Quarterly business reviews at country and Group level
• Annual budget process with regular reforecasting
• Treasury controls and cash management procedures
• IT general controls and application controls for financial systems

Quality Assurance and operational risk management

Quality management system:

• ISO 9001 certification for 98% of long-term care homes and 64% of other activities
• Annual 360° quality audits conducted by quality department teams
• Standardised procedures across all facilities
• Continuous monitoring of quality indicators
• Regular training programmes on quality standards

Risk management framework:

• Comprehensive risk library updated annually
• Digital risk monitoring tool for risk owners
• Quarterly Risk, Ethics and Compliance Committee meetings
• Action plans for priority risks monitored at Group level
• Risk governance with designated owners at Group Management Board level

Operational controls:

• Anonymous whistleblowing platform for reporting issues
• Incident reporting and investigation procedures
• Regular internal audits and assessments
• External regulatory inspections and certifications

Insurance policy

The Group has implemented a comprehensive insurance programme covering:

• Professional liability and medical malpractice
• General liability
• Property damage and business interruption
• Cyber security and data breach coverage
• Directors and officers liability
• Employment practices liability

Insurance coverage is regularly reviewed and updated to ensure adequate protection against identified risks.

Strategy, business model and value chain

European Presence

Clariane is Europe's leading care service community, with three complementary business segments: long-term care, specialty care, and home and community care. The Group operates in six countries with a network of more than 1,200 facilities and recognised expertise in care, health and support services.

Geographic Presence:

*Note: UK revenue was €17 million at 9 April 2024, when all UK assets and activities were disposed of.

Activities and Key Figures

A community of professionals dedicated to caring for and supporting people in times of vulnerability

Founded in France more than 20 years ago, Clariane became a purpose-driven company in 2023 with the purpose: "Take care of each person's humanity in times of vulnerability". The Group is present in some 700 towns and local regions and brings together a community of 63,000 committed employees (FTE) guided by the "At Your Side" corporate project.

Key Metrics 2024:

• Revenue: €5.282 billion (6.6% organic growth)
• Facilities: 1,220
• Employees: 63,000 FTE
• People supported: More than 1,000,000 people in 2024
• Operating in: Nearly 700 towns and local communities

Three Business Segments:

1. Long-term Care

• 666 homes
• 62,546 beds
• 98,729 residents in care
• Services: long-term care, respite stays for carers, respite after hospitalisation, day care
• Brands: Korian (France, Germany, Belgium, Italy), Seniors Residencias (Spain), Hestia Zorg, Het Gouden Hart and Stepping Stones (Netherlands)

2. Specialty Care

• 277 facilities
• 14,224 beds
• 707,500 patients cared for
• Services: medical, post-acute and rehabilitation care, mental healthcare, medicine, surgery and obstetrics, outpatient hospitalisation, consultation and associated diagnosis, home hospitalisation and domiciliary care
• Brands: Grupo 5, Cian, Ita Salud (Spain), Korian (Italy), Inicea (France), Dores Herstelzorg (Netherlands), Orthoshop (Belgium), Lebenswert (Germany)

3. Community Care

• 277 facilities
• 13,730 beds
• 80,456 residents and customers
• Services: shared living solutions, assisted living facilities, personal services agencies, health and social care services (Spain)
• Brands: Korian (Germany, Italy), Grupo 5 (Spain), Âges & Vie and Petit-fils (France), Rosorum and Het Gouden Hart (Netherlands), Korian Home Care and Cura (Belgium)

Strategy

Corporate Purpose and Status

In 2023, Clariane adopted the legal status of purpose-driven company, enshrining its purpose – "Taking care of each person's humanity in times of vulnerability" – in its Articles of Association and opening up its governance structure to stakeholders via the Mission Committee.

At Your Side Corporate Project

The "At Your Side" corporate project was developed with a threefold ambition:

1. Meet growing demand for personalised care as close to home as possible with the shift to outpatient models
2. Build on core strengths across all business segments, from medical expertise in geroscience and talent development to digital transformation
3. Consolidate the pact of trust with stakeholders at all levels – local, national and European

Five Core Commitments

1. Commitment to Consideration: Show respect and consideration to every person we care for and their loved ones, as well as to each of our employees and stakeholders, while fighting all forms of discrimination.

2. Commitment to Fairness: Develop a fair and sustainable business operating model that benefits our patients, residents and their families, our employees and other stakeholders for all our business lines and investment decisions.

3. Commitment to Sustainability: Harness our geographic footprint and diverse network of facilities to improve access to care, build a resilient local ecosystem and contribute to economic momentum in the regions in which we operate.

4. Commitment to Locality: Protect our communities' life environment through the adaptation of our processes and behaviours to fight climate change and preserve biodiversity.

5. Commitment to Innovation: Encourage and enhance innovation to help better prevent illnesses, increase the effectiveness of treatments and enhance the quality of life and satisfaction of patients, residents, families and employees.

Ten Operational Initiatives

These five commitments are broken down into ten operational initiatives:

• Positive Care
• Advice and guidance for care seekers
• Social and psychological support for employees
• Employee health and safety
• Training and career development
• Value-sharing
• Energy-related carbon footprint
• Local and inclusive purchasing
• Medical research
• Innovation in health and care

Plan to Strengthen Financial Structure

In November 2023, Clariane launched a refinancing plan to overcome difficulties in accessing private debt markets. The plan includes:

• Capital increases totalling €329 million completed in 2024
• Asset disposals (€504 million finalised in 2024)
• Targeted disposals of non-core assets to complete the plan by year-end 2025
• Net debt reduction of €409 million in 2024

Business Model

Resources

Financial:

• €5.3 billion in revenue
• €183 million in free operating cash flow before capital expenditure and excluding IFRS 16
• €3.45 billion in net debt
• Financial leverage: 3.8x (Opco) and 5.8x (Wholeco)

Care Infrastructure:

• 1,220 facilities
• 90,500 care places
• 24% of the network directly owned (€2.6 billion in real estate assets)

Employees:

• 63,086 FTEs (50,256 permanent and 12,829 temporary employees)
• Average age: 45 (permanent workforce)
• 80% women, of which 53% in top management positions
• 4 main job families: clinical and care staff (67%), catering, hospitality, maintenance, cleaning (21%), site administration and operations management (9%), head office and support functions (3%)
• Clariane University: training in care, rehabilitation, hospitality, catering, technical services, administration and management

Environment:

• 720,697 kWh energy consumption
• 614 ktCO2e (Scopes 1, 2 & 3)
• 5,359,117 cu.m. water consumption (of which more than 90% discharged into wastewater systems)
• 457 kg of waste per bed per year

Our Professions

• Medical care and rehabilitation: Specialised medical care, prevention and diagnosis, rehabilitation
• Catering and personal services: Personal services, accommodation, cleaning, laundry, catering, events, leisure activities
• Training: Through our universities and training centres
• Real estate development: Networks of facilities and service agencies, real estate development, asset management
• Consultation and use of information systems

Value Created/Preserved

For Residents and Patients:

• 886,685 patients and residents cared for
• +44: NPS for residents, patients and families
• 8.3/10: consideration score

For Employees:

• 79% engagement rate
• Top Employer Europe certification
• 819,670 hours of training
• 12.1% of employees on qualifying training paths

Economic Impact:

• €2,254 million spent on salaries and training
• Revenue of €5.3 billion
• €294 million invested in real estate and the existing network
• Economic footprint in France: €5.41 billion (equivalent to revenue)

Regional Roots:

• 700 local communities served
• 800 local partnerships
• 78% of purchases made/sourced locally
• 17% of food purchases sourced regionally in France

Societal Impact:

• Contribution to 105 medical publications
• 5 research partnerships (institutions/countries)
• 3 Clariane corporate foundations (France, Germany, Spain)
• €2 million in philanthropic outreach

Environmental Footprint:

• 11% reduction in energy volume (kWh) vs 2021
• 15% ktCO2e reduction from energy vs 2021
• 2031 transition plan aligned with WB2°C
• 87% of waste recovered, of which 44% reused/recycled

Industry Trends

Chronic Diseases

Chronic diseases such as cancer, chronic respiratory problems and diabetes are the leading cause of death in OECD countries. More than a third of adults report living with a long-term illness or health problem. In Clariane's operating countries, the proportion ranges from 19% in Italy to 43% in Germany. Nearly 7% of the adult population in OECD countries were living with diabetes in 2021.

Ageing Population

According to the OECD, the ageing of Europe's population will increase the proportion of people aged 65 and over from 20.7% in 2020 to 24.2% in 2030. In France, according to the General Inspectorate of Social Affairs (IGAS), the number of dependent elderly people will increase by approximately 16% between 2020 and 2030, from 2.7 million to nearly 3.1 million. By 2040, the increase will be 36%, bringing the total to some 4 million dependent elderly people.

Ageing at Home

More than 80% of seniors want to age at home, even if their health deteriorates. However, 38% of over 75s say they would consider moving into adapted accommodation to receive greater support. This creates demand for complementary solutions in home help, shared living and care homes.

Digitalisation

Digital transformation is central to Clariane's corporate project. Digital technologies offer opportunities to improve:

• Quality of care through digitalisation of patient records and connected medical devices
• Employee experience through automation of administrative tasks
• Resident and patient experience through enhanced comfort, safety and access to care including telemedicine

Challenges Facing the Sector

Recruitment and Training

Europe's healthcare sector faces challenges in recruiting and retaining talent. People aged 60 and over use nursing care 20 times more than those under 35. By 2030, several hundred thousand additional healthcare professionals will be required. The number of newly qualified nurses per capita is below the OECD average in France, Spain and Italy.

Financing of Healthcare Expenditure

The industry in France requires €66 billion in investment by 2040 to renovate and adapt long-term care. Over the past three years, healthcare providers have faced unprecedented inflation in energy, food and renovation costs, as well as wages for caregivers.

Towards Personalised Care

Personalised care reflects patients' legitimate aspirations to be involved in managing their care pathways. Healthcare systems must evolve to embrace this participatory dimension. In France, 12 million patients were living with a chronic disease recognised as a long-term illness in 2021, with prevalence rising from 14.6% in 2008 to 17.8% in 2021.

Prevention and Preservation of Physical Capacity

The WHO advocates a shift from a curative system to one that is more proactive and preventive. Clariane has partnered with the Toulouse University Hospital Institute (IHU) to support the WHO's ICOPE programme, facilitating access to early, high-quality care for vulnerable people and the over-60s.

Local Presence

Mapping Our Networks

All facilities play a key role in their local community, contributing to the local health and care ecosystem, economic development and social life. The 1,220 facilities are located in the heart of cities and rural areas, in priority urban areas as well as in poorly served regions.

Geographic Distribution:

• France: 25,257 employees, 558 facilities, 33,872 beds, 1,823 new hires
• Germany: 17,495 employees, 233 facilities, 26,853 beds, 3,109 new hires
• Benelux: 9,170 employees, 172 facilities, 14,268 beds, 1,582 new hires
  • Belgium: 8,065 employees, 117 facilities, 12,596 beds, 1,508 new hires
  • Netherlands: 1,105 employees, 55 facilities, 1,672 beds, 74 new hires
• Italy: 5,715 employees, 102 facilities, 8,995 beds, 283 new hires
• Spain: 5,448 employees, 155 facilities, 6,512 beds, 573 new hires

Local Partnerships

On average, each facility has six partnerships with local organisations or volunteers, formalised by partnership agreements. 97% of facilities report having at least one local partnership. These aim to conduct regular joint activities that benefit residents/patients and their families, as well as the local community.

Interests and views of stakeholders

Overview of stakeholder engagement

Regular engagement with local stakeholders in each community or healthcare region is key to ensuring quality support. Stakeholders fall into ten categories. The interaction channels between them are described in section 3.1.3.2 of this document.

Clariane's stakeholder groups:

1. Ecosystems, climate, natural resources, biodiversity
2. Property investors and financial partners - Property investors, developers, landlords, real estate companies
3. Investors and financial partners - Shareholders and holders of other equity and financial instruments issued or guaranteed by Clariane or any of its subsidiaries, banks and other financial institutions, as well as analysts and rating agencies
4. Residents, patients, families, carers and their representatives on Social Life Committees and User Commissions (or equivalent)
5. Employees and their representatives - Permanent and temporary employees, including trainees, employee representatives and unions
6. Healthcare, academic and training organisations - Universities and hospitals, medical research organisations and training facilities and bodies that deliver qualifications or continuous education
7. Communities of internal and external carers, and their representative bodies
8. Local residents and stakeholders with links to the facilities
9. Regulators - Supervisory authorities, national and local authorities
10. Business partners - Companies, suppliers and subcontractors
11. Civil society associations and NGOs - Foundations supported by Clariane, industry bodies and civil society

Stakeholder engagement channels and frequency

Vulnerable people, their relatives and representatives

Definition and scope:

• Residents, patients, beneficiaries of services – in particular elderly and vulnerable people – as well as their families, relatives and caregivers

Dialogue channels:

• Ongoing communication at facility level (local/permanent)
• Customer services (national/permanent)
• Facility Stakeholder Councils (e.g., Conseil de vie sociale and Commission des Usagers in France, Heimbeiräte in Germany) (local/at least two to three per year depending on the type of meeting)
• National Stakeholder Councils (national/at least four meetings per year)
• Satisfaction surveys (Group, rolled down to facility level/variable frequency depending on type of survey, at least annual)

Topics addressed and taken into account:

• Results of satisfaction surveys, activities and social life, catering, communication, care, living environment, staff, complaints, offer and prices, other facility projects, environmental practices
• Depending on the level of dialogue, the information is passed on to the departments responsible for the improvement initiatives so that it can be taken into account. Large-scale priority initiatives are presented to the relevant administrative, management and supervisory bodies

Employees and their representatives

Definition and scope:

• Employees, interns, apprentices and any person in training, as well as employee representatives and trade unions

Dialogue channels:

• Management and HR managers (all levels/permanent)
• Onboarding programme, training (local or regional, once or several times a year)
• Performance and development review (local, at least once a year)
• Community Pulse satisfaction surveys (national and Group/annual)
• Internal communication: intranet, newsletter, staff/manager briefings, staff events (all levels/permanent)
• Social dialogue with social partners (e.g., Works Councils, exchange meetings) (all levels/at least monthly and as needed)
• Mission Committee (Group/at least quarterly)
• Internal or external social service or helpline for social and psychological support (national/on request)

Topics addressed and taken into account:

• Satisfaction survey results, workplan and workload, recruitment, health and well-being at work, compensation and benefits, training, internal mobility, diversity and inclusion, employer-employee dialogue, overall business strategy, financial and sustainability performance
• Depending on the level of dialogue, the information is taken directly into account by the managerial lines responsible. It is also collected or forwarded to the departments responsible for the improvement actions so that it can be taken into account. Priority initiatives at national and Group level are presented to the relevant administrative, management and supervisory bodies

Supervisory authorities, national and local authorities, and regulators

Definition and scope:

• National, regional and local authorities linked to the Group's activities, elected officials and their representatives: for example, the Ministry of Health, French regional health agencies, and departmental councils in France
• Regulators of the healthcare and nursing sector: for example Haute Autorité de Santé, French regional health agencies

Dialogue channels:

• Local Stakeholder Councils (when able to invite representatives from the authorities to attend) (local/at least two to three per year depending on the type of meeting)
• Participation in various local, regional and national consultation bodies, depending on the characteristics of the country, on a two-party or multi-party basis, or through professional federations or organisations (all levels/several times a year)
• Audit and certification of facilities by accredited agencies (local and regional/variable depending on the country, once every three to six years)
• Presentation or revision of facility projects (local and regional/each new project, then revisable over a variable period, often annually)

Topics addressed and taken into account:

• Offer and services proposed, facility capacity, patient dependency levels, pricing, quality of care and services, patient/resident satisfaction, local/regional employment, local projects, partnerships, access to public services and infrastructure
• The comments and requirements of regulatory authorities and agencies are taken into account by management at the relevant level – primarily local and regional – in order to comply with applicable regulations and improve quality of care

Integration of stakeholder views into strategy and business model

The Group's facilities are in close contact with various categories of stakeholders, including residents and patients, as well as their relatives and caregivers, employees, healthcare professionals (prescribers and partners), public and local authorities and economic partners. At facility, regional, national and even Group level, various channels for dialogue (including regulatory channels) are used to inform and consult employees on sustainability topics.

Local-level dialogue is a priority, as it enables the greatest possible responsiveness and is based on the most accurate knowledge of the facts.

Stakeholder consultation processes

Own workforce

Stakeholder views on material impacts are collected through:

• Ongoing dialogue within facilities
• Dialogue with employee representatives
• The annual C-Pulse survey
• Occasional stakeholder consultations

Ongoing dialogue within facilities: Management teams maintain ongoing dialogue with employees to promptly follow up on and address team feedback, both in day-to-day operations and during team meetings. Management practices, such as daily team briefings, are integral to good management dialogue (as highlighted in the guide to preventing absenteeism developed with the European Company Works Council in 2024) and provide a regular communication channel on key matters for employees.

Dialogue with employee representatives:

Dialogue with employee representatives takes place at all levels of the Group: European, national, regional and local. The principles underpinning this dialogue with employees and their representatives are defined in the European Charter on Fundamental Principles of Social Dialogue.

At European level, social dialogue is structured around the European Works Council. The working groups established by agreement in 2019 are making progress on their specific topics:

• A working group dedicated to preventing workplace accidents and reducing absenteeism (since 2019, meeting at least twice a year):

  • The work undertaken within the working groups in 2021 led to the signing of the European Protocol on Occupational Health & Safety and Workplace Accident Prevention for a three-year period
  • On absenteeism and the enhancement of the Clariane social contract. The meetings of this working group resulted in the adoption of the Joint Declaration on Social Commitment and the Reduction of Absenteeism by a majority of the European Works Council in 2022. This work continued in 2024 and resulted in the creation of a Guide to Good Managerial Practice to Reduce Absenteeism

• A working group dedicated to CSR strategy and training (since 2023, meeting at least twice a year):

  • The CSR and Training working group meets twice a year, with the participation of the Group CSR Director and the Training Director, allowing members to monitor the progress of initiatives aligned with Clariane's objectives as a purpose-driven company, as well as developments at Clariane University. In 2024, the requirements of the CSRD regarding the publication of sustainability information, the results of the double materiality assessment and the preparation of the sustainability statement were the subject of briefings and discussions, both within this working group and in plenary sessions

• An ad hoc working group dedicated to internal communications with employees

In addition to the European Works Council, employee representatives sit on the following administrative, management and supervisory bodies involved in sustainability governance:

• Board of Directors (two employee representatives out of a total of 16 members)
• One of the employee representatives also sits on the Board of Directors' Ethics, Quality and CSR Committee, which is tasked with monitoring sustainability matters and the implementation of the CSR strategy
• The Mission Committee (four employee representatives out of a total of 14 members)

The annual C-Pulse survey:

A process for direct dialogue with employees has also been in place since 2015 through the employee satisfaction survey conducted among all employees in Europe. The survey, previously conducted every two years, has been carried out annually since 2021. It is managed centrally by the Group Human Resources Department in partnership with Ipsos and cascaded to the countries by the local HR teams.

In 2024, the participation rate in the C-Pulse survey was 70%, representing a steady increase since 2021 and a 5-point increase compared with 2023.

The survey measures employees' overall appreciation of Clariane as an employer and their job satisfaction, as well as their views on key material matters such as occupational health and safety (including work-life balance), training and skills development, social dialogue, and diversity and inclusion. It also assesses employees' knowledge and understanding of the company's social and environmental commitments as a purpose-driven company, in relation to material sustainability matters, their sense of consideration (respect and protection of individuals in their uniqueness), and their trust in the company's management.

For example, regarding training, a material matter identified for Clariane, 71% of employees agreed with the statement, "I think I can grow within the company". This item has featured in the survey every year for the past four years to better address the material risk related to training at Clariane.

On the material matter of occupational health and safety, 81% of employees who responded to the survey agreed with the statement "I work in a safe environment", and 78% agreed with the statement "I have a good work-life balance".

All of these results give rise to a detailed analysis at Group, country, regional and facility level to identify and understand from a ground-level perspective the points of satisfaction and need for improvement. The results are communicated via a dedicated platform to all regional and departmental directors, and to facility directors, who share the findings with their teams.

The analysis of the quantitative results and comments from each facility director have inspired initiatives adapted to these expectations, leading to immediate improvements in employees' working conditions (e.g., refurnishing of a break room, creation of informal opportunities for celebration and discussion, etc.).

Occasional stakeholder consultations:

In addition to the dialogue procedures described above, the company regularly organises consultations with all its employees to gather their opinions on sustainability matters.

Consultations were held in 2021 as part of the simple materiality assessment and in 2022 to prepare for the transition to purpose-driven company status and to define social and environmental commitments.

These consultations will be renewed in accordance with the process described in section 3.1.4.1.1.

Local communities

As part of Clariane's transformation into a purpose-driven company, a stakeholder consultation was conducted in 2022 to identify the expectations and priorities of each stakeholder. Among local communities, mayors in France, Belgium, Italy and Germany were asked for their views, as were elected officials and regulators at regional and/or national level, depending on the country.

Priority expectations emerging from the questionnaires and interviews:

• Create jobs and contribute to the employability of local workers
• Provide quality employee training and compensation
• Ensure involvement in local life
• Guarantee transparency with regulators
• Contribute to the local and circular economy

At the level of each facility, platforms for dialogue with residents, patients and families are set up in order to involve them in the life and running of the facility. Other stakeholders, such as employees, non-profit organisations and volunteers working in the facility, and even local authorities, are often represented on or invited to these forums.

Patients and residents

Dialogue with patients, residents and families is organised primarily through local Stakeholder Councils. The most common practices include the establishment of committees composed of elected representatives of the people we care for and the organisation of meetings open to all.

Affected stakeholders: The primary objective of these bodies is to promote the participation (direct or indirect, through representatives) of patients, residents and families. The participation of other stakeholders (e.g., employees, non-profit organisations and volunteers working in the facility, and local authorities) varies according to local regulations and practices, as well as the ecosystem of each facility. The Group encourages the involvement of all stakeholders in this dialogue, in line with the core principle of inclusive governance formalised within the purpose-driven company framework, which is aimed not only at patients, residents and families, but also at all local stakeholders.

Functioning, powers and topics covered:

In the Group's facilities, the most common forums for dialogue are the Councils, made up of representatives elected by the stakeholders represented, and participatory meetings, which are open to everyone. These two forms of dialogue are complementary and can coexist within the same facility. Elected council meetings can also be open to all residents and families. Where regulations do not mandate a minimum meeting frequency, the Group considers a facility to have active stakeholder dialogue if it holds at least two meetings per year, or three meetings if a committee of elected representatives is in place.

These bodies are consultative: they issue opinions and recommendations for management but do not have decision-making power.

Country-specific arrangements:

The establishment of a council of elected representatives of residents is a legal requirement in the following countries:

• In France: Social Life Committee
• In Germany: House Council (Heimbeirat)
• In Belgium: residents' councils or users' councils (Gebruikersraad)
• In the Netherlands: Customer Council (Cliëntenraad)

In Germany, when an elected representative council cannot be established – typically due to a lack of candidates – a House Spokesperson (Heimfürsprecher) is appointed. This person, often chosen from among families or volunteers working in the facility, is tasked with collecting concerns and requests from residents and families, and bringing them to the attention of the management. The Clariane Germany Stakeholder Council annually reviews House Council report summaries to provide management with recommendations on how to better address residents' wishes for improvement.

In the Netherlands, regulations require the Cliëntenraad, representing residents and families, to approve certain decisions directly affecting daily life.

For specialty care facilities in France, User Representatives, who are volunteers from accredited non-profit organisations, are appointed by the Regional Health Agency (ARS – Agence régionale de santé) to ensure that users' rights are upheld and to contribute to efforts to improve the quality of patient care, family support and healthcare services. They serve on the facility's Users' Commission, which is responsible for handling issues related to hospitalisation conditions, admission, treatment and discharge, with a particular focus on managing complaints and grievances filed by users.

For community care facilities (assisted living facilities and shared housing), participation bodies are set up on a voluntary basis, in line with the commitment made by the Group.

In Italy and Spain, regulations governing dialogue in the Group's various activities vary by region and by sector. Where local regulations do not impose such requirements, stakeholder bodies are set up on a voluntary basis, in line with the Group's commitment.

Metric and target:

The key performance indicator monitored at the Group level is the percentage of facilities that engage in active dialogue with their stakeholders. This metric tracks the percentage of facilities that have implemented at least one of the following forms of dialogue:

• A council composed of elected representatives or a house delegate (at least three meetings per year, or more if required by local regulations)
• Open stakeholder meetings (at least two per year)

The participation of patients, residents and their families or representatives in this dialogue is mandatory, while other local stakeholders must be actively encouraged to take part.

Under its 2024-2026 CSR roadmap, the Group has set a target of at least 95% of facilities engaged in active dialogue with their stakeholders, with an interim target of 90% in 2025.

Distinction between affected stakeholders and users of sustainability information

The stakeholder ecosystem includes both affected stakeholders (those impacted by the business, such as vulnerable people receiving care, employees, local communities) and users of sustainability information (such as investors and financial partners, shareholders and holders of other equity and financial instruments, banks and other financial institutions, analysts and rating agencies).

The Group's approach to sustainability reporting recognizes the primary users of the sustainability statements (including the primary users of the financial statements) as distinct from stakeholders who may be affected by the entity's activities and business relationships.

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

Overview

Based on the double materiality assessment, material sustainability matters can be grouped into four categories according to their outcomes on the double materiality assessment axes:

• Critical: matters with high impact materiality AND high financial materiality
• High: matters with fairly high impact materiality AND fairly high financial materiality
• Moderate impact: matters with fairly high impact materiality
• Moderate risk(s)/opportunity(ies): matters with fairly high financial materiality

All material IROs and the policies and actions implemented to minimise or maximise them (in the case of positive impacts and opportunities) are covered by the disclosure requirements presented in the sections of the sustainability statement.

Material IROs by stakeholder group

Clariane has formally mapped its value chain, identifying the position of its main stakeholders and the main material impacts, risks and opportunities concerning them.

Environment:

• GHG emissions
• Availability of water resources
• Global warming
• Pollution from hazardous or non-recovered waste

Regulators:

• National, regional, local
• Authorisation to set up and operate
• Planning permission
• Certification, accreditation and audit of health and care activities
• Reimbursement of medical care and expenses by health insurance schemes
• 87% of facilities audited and certified A or B

Investors and other financial partners:

• Debt/equity investors, Banks, Private shareholders
• 44% of share capital held by investment funds
• 1% of share capital held by employees
• 30% free float
• €3.45bn in net debt
• Financial leverage: 3.8x (Opco), 5.8x (Wholeco)

Real estate partners and investors:

• 24% of sites directly owned, property assets held valued at €2.6bn
• 76% of sites under lease or management contracts
• €549m in annual external rent (= 11.7% of total operating costs)
• €166m in annual internal rental income

Suppliers:

• 39,000 suppliers, of which around 1,200 referenced

• 78% national suppliers, <1.5% from outside Europe
• Costs of purchased goods and services = 21% of total operating costs
• Breakdown of procurement expenditure: Catering 14%, Building management and maintenance 13%, Renovations/furniture 12%, Energy 12%, Medical products/consumables 8%, Entertainment/services for residents 6%, IT/telecoms 6%, Laundry/linen 5%

Internal and external staff:

• Staff costs = 67% of total operating costs
• 63,000 employees (FTE), of which 80% on permanent contracts
• Non-employee workers: private practitioners, home help in franchised networks, temporary staff
• Breakdown of employees (FTE): Medical and nursing 67%, Catering/entertainment/maintenance/cleaning 21%, Operational and administrative site management 9%, Head offices and support functions 3%

Healthcare professionals and organisations:

• Partner/prescriber organisations and healthcare professionals
• Academic and research bodies
• Patient/resident referral rate (e.g., FR) = [15%-20%] community care/home care, [25%-30%] long-term care
• 100% medical, post-acute and rehabilitation and mental healthcare
• 10 (out of 31) indexed articles co-authored with academic or research bodies

People in vulnerable situations, families, carers:

• Long-term care: Isolation, dependency +++
• Specialty care: Medical, post-acute and rehabilitation, and long-term illness
• Community care: Isolation, dependency ++
• Mental healthcare: Addiction, psychiatric disorders, mental disability
• Social services: Marginalisation, social exclusion
• Home care: Isolation, dependency +
• Revenue breakdown: 62% long-term care, 25% specialty care, 12% community care

Waste management:

• More than 10 categories of on-site waste
• More than 250 waste collection service providers
• 50% to 100% of waste is collected by public services, depending on the country
• Recovered waste 87%, including 44% of waste reused/recycled
• Hazardous medical waste 2.2%

List of material impacts, risks and opportunities

Environmental Matters

Social Matters - Own Workforce (S1)

Social Matters - Local Communities (S3)

Social Matters - Patients and Residents (S4)

Governance - Business Conduct (G1)

Interaction with strategy and business model

Clariane's material IROs are directly integrated into its corporate purpose adopted in June 2023:

"Take care of each person's humanity in times of vulnerability."

This corporate purpose is supported by five social and environmental objectives:

1. Consideration: show respect and consideration to every individual for whom we care and their loved ones, as well as every one of our employees and stakeholders while also fighting all forms of discrimination
2. Fairness: develop a fair and sustainable business operating model that benefits our patients, residents and their families, our employees and other stakeholders for all our business lines and investment decisions
3. Sustainability: protect our communities' life environment through the adaptation of our processes and behaviours to fight climate change and preserve biodiversity
4. Locality: harness our geographic footprint and diverse network of facilities to improve access to care, build a resilient local ecosystem and contribute to economic momentum in the regions in which we operate
5. Innovation: encourage and enhance innovation to help better prevent illnesses, increase the effectiveness of treatments and enhance the quality of life and satisfaction of patients, residents, families, employees and other stakeholders

These five objectives cover the Group's material sustainability matters. A CSR strategy for 2024-2028 was defined, directly aligned with these five objectives, encapsulating the policies implemented to address the Group's material impacts, risks and opportunities.

Link between material matters and corporate purpose commitments

2024-2026 CSR Scorecard

Comprehensive sustainability indicators are monitored by Group- and country-level functional departments. The most important are presented in the 2024-2026 CSR scorecard, organized by commitment:

Resilience to material IROs

Clariane has assessed its business model resilience for each material IRO, as presented in the tables above. Key resilience considerations include:

Critical matters requiring continuous mobilisation:

• Staff shortages and workload: mobilises all functional departments and businesses
• Employee health and safety: mobilises all functional departments and businesses
• Ethics and quality of care: mobilises all functional departments and businesses
• Compensation and benefits: priority for the business model
• Financial affordability and transparency: priority for maintaining relations with public authorities

Energy and climate:

• The shift to a business model less exposed to rising energy costs is both realistic and necessary
• Climate adaptation is a medium-term priority through to end of 2026, involving vulnerability assessment and adaptation plan quantification
• The Group monitors government and insurer work on financing climate adaptation in the healthcare sector

Water resources:

• The Group's model is fairly resilient due to limited consumption and priority status in water shortage scenarios

Waste management:

• Main sorting channels are generally accessible in countries of operation, limiting business model impact

Local presence:

• Local footprint, cooperation and dialogue are key levers for business model resilience and facility attractiveness

Diversification of offers and services:

• Priority for long-term business model sustainability

Anticipated financial effects

In accordance with the one-year phase-in provision, quantitative disclosure of anticipated financial effects from material risks and opportunities will be published from 2026 for the 2025 reporting period. Qualitative information on financial effects is provided in the IRO tables above.

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

General methodology for assessing double materiality (ESRS 2 IRO-1)

Clariane conducted its first double materiality assessment in 2024 for its CSRD sustainability statement. The assessment drew on previous materiality analyses, risk mapping and Duty of Care Plan. Previous stakeholder consultations from 2022 (conversion to purpose-driven company) were integrated into the 2024-2028 CSR strategy.

Scope of the assessment:

• All significant activities and markets in 2024: nursing homes, specialty care (post-acute and rehabilitation care, mental health), shared housing and home care services
• Six countries: France, Germany, Belgium, Netherlands, Italy and Spain (UK business sold April 2024)
• Main stakeholders and their positions in the value chain

Assessment covered 94 impacts, risks and opportunities across 22 sustainability matters:

Environment: Climate, Energy management, Pollution, Water resource management, Natural resources and biodiversity, Circularity and waste management

Social: Compensation and benefits, Recruitment and workload, Employee health and safety, Employability and talent development, Social dialogue, Diversity equity and inclusion, Labour and human rights in the value chain, Local presence and local communities, Affordability of the offer and transparency of information, Offers and services, Ethics and quality of care, Medical research, Personal data protection

Governance: Inclusive governance, Business ethics, Cybersecurity

Sources of information

The assessment used:

• Sector benchmarks (SASB, MSCI, Moody's, S&P, Sustainalytics, ISS, sustainability reports of competitors/peers)
• Stakeholder consultations (2021 and 2022 for transition to purpose-driven company, 2023 materiality matrix)
• Topical internal and external studies (carbon footprint, waste management study, Asterès socio-economic impact study, patient/resident and employee satisfaction surveys)

Key studies incorporated:

Assessment methodology

Internal expert workshops:

Workshops were held with various internal experts to assess related impacts, risks and opportunities. Functional departments involved:

For impact materiality:

• Environment: Real estate and Energy, Quality, Medical Ethics and Health Innovation Department, Operations, Ethics and Security, Human resources
• Patients/Residents: Quality, Medical Ethics and Health Innovation Department, Operations, Ethics and Security, Human resources
• Employees: Human resources, Operations, Ethics and Security
• Suppliers/service providers: Procurement
• Investors: Supplier relations, Public affairs
• Regulators: Legal, Medical Ethics and Health Innovation Department
• Medical organisations: Medical Ethics and Health Innovation Department

For financial materiality:

• Internal audit, Finance, Legal, Group CSR

Scoring criteria for impact materiality

Impacts were assessed using a three-step methodology:

1. Assessment of impact severity:

• Scale of impact: rated 1 (low) to 4 (high). Depends on type of impact (e.g., on people, buildings or equipment, local communities, business partners or environment). Considered human rights incidents, frequency and severity of accidents, fatalities, environmental damage, improvements in living and working conditions, personal and professional development, socio-economic impacts
• Scope of impact: rated 1 (localised impact in one facility) to 4 (general impact on all countries where Group operates)
• Long-term variability: rated on two-level scale, from stable impact to impact likely to increase

2. Assessment of irremediable character:

• Rated 1 (impact easily and fully remedied) to 4 (irremediable, impossible to return to prior state)

3. Assessment of likelihood:

• Rated 1 (very unlikely) to 5 (virtually certain or actual, proven)

Scoring criteria for financial materiality

Risks and opportunities relating to financial effects were assessed on a gross basis according to whether they affect or could reasonably be expected to affect current and future cash flows over short, medium or long term.

Three-step methodology:

1. Assessment of scale of current and/or past risk or opportunity: based on existing scale defined by Internal Audit and Internal Control Department for annual risk mapping update. Four-step scale in millions of euros covers possible financial effects in terms of revenue, expenses and/or EBITDA, and possible effects in terms of assets, liabilities or shareholders' equity
2. Assessment of potential scale of long-term risk or opportunity: using same four-step scale
3. Estimate of likelihood of materialising in long term: rated 1 (very unlikely) to 4 (almost certain)

Threshold for materiality

Following impact materiality and financial materiality assessments, results were consolidated and materiality thresholds defined for proposal to and approval by administrative, management and supervisory bodies:

1. CSR Steering Committee (chaired by Chief Executive Officer)
2. Group Management Board
3. Audit Committee (for validation)
4. Mission Committee (for information/consultation)
5. European Works Council and Economic and Social Committee (for information/consultation)

Materiality thresholds validated on basis of:

• Materiality of information for stakeholders, including users of non-financial information
• Consistency with previous materiality engagements
• Continuity in terms of strategic CSR commitments

Validated materiality thresholds:

• Impact materiality: 2 out of maximum of 4
• Financial materiality: 2 out of maximum of 4

Material sustainability matters grouped into four categories:

• Critical: matters with high impact materiality AND high financial materiality
• High: matters with fairly high impact materiality AND fairly high financial materiality
• Moderate impact: matters with fairly high impact materiality
• Moderate risk(s)/opportunity(ies): matters with fairly high financial materiality

Frequency and when last reviewed

This was the first double materiality assessment conducted in 2024 for CSRD compliance.

Process for updating:

• Annual update of impact assessment as part of Duty of Care Plan review by internal stakeholders in event of changes in impacts or new matters
• Annual update of risk assessments by internal stakeholders based on risk mapping
• Three-yearly update of assessment of IROs by external stakeholders

Use of value chain mapping

Value chain mapping was used in the process. The assessment considered:

• Views and matters relating to main stakeholders and their positions and roles in value chain (described in section 3.1.3.1)
• Impacts generated directly by the Company or to which it contributed, including through upstream and downstream value chain
• Dependencies and financial effects across value chain

For climate-related IROs specifically:

• Carbon footprint assessment using GHG Protocol methodology covering entire value chain (Scopes 1, 2 and 3)
• Scope 3 accounts for 80% of Group's carbon footprint, with energy and catering biggest emitters
• Transition risk assessment considered impact on Group's own operations and value chain

For other environmental matters:

• Water risk assessment covered operations and discharge into wastewater networks
• Waste management study examined circularity across value chain
• Supplier requirements integrated through Sustainable Procurement Charter

Specific processes for identifying and assessing climate-related IROs

Climate change mitigation:

• Carbon footprint assessments with independent technical expert using GHG Protocol methodology
• Since 2024, new carbon footprint assessment tool deployed
• Covers entire value chain (Scopes 1, 2 and 3)
• Impact magnitude assessed based on absolute volume of greenhouse gas emissions (tCO2e) and economic intensity (tCO2e/€m)

Physical climate-related risks:

• Analysis of exposure to climate hazards using R4RE tool developed by OID
• Covers all Group facilities and activities as of end of reporting period
• Uses Business-as-Usual scenario (SSP5-8.5)
• Considers four main hazards: heat waves, heavy rainfall and flooding, drought, extreme cold
• Forest fire risk modelled for main market (France)
• By end of 2026: building-by-building vulnerability assessment and identification of adaptation solutions

Transition risks:

• Qualitative assessment conducted
• Scenario used: proactive climate action scenario (SSP1-1.9)
• Considered impact on Group's own operations and value chain
• Key areas assessed: policy and regulations, technology, market and consumer trends, reputation
• Main material transition risk identified: cost of procuring fossil fuels due to potentially high volatility

Continuous improvement

As this is first year of CSRD application, Clariane acknowledges:

• Certain estimates may be fine-tuned in future reporting periods when more relevant information becomes available
• Certain estimation methods may be modified or adapted in line with changes in generally accepted practices
• Impact assessments more specific to certain Group activities (e.g., mental health, social services) may be carried out in greater depth to confirm correspondence with general framework

Integration with existing processes

The double materiality assessment integrated with:

• Annual risk mapping exercise
• Duty of Care Plan (identification and evaluation of negative impacts)
• Evaluation of opportunities
• Existing materiality assessments and stakeholder consultations

Transition plan for climate change mitigation

Scope of the plan

The transition plan covers all Group activities and countries of operation (France, Germany, Belgium, Netherlands, Italy, Spain), excluding facilities under management contracts in Spain.

The plan covers own operations and upstream and downstream value chain segments. In 2024, Scope 3 accounts for 80% of the Group's carbon footprint.

Target year(s) for net zero / carbon neutral

The Group has focused on working towards a 2030 reduction target. The plan includes a 2031 transition plan aligned with WB2°C (Well Below 2°C).

Reduction targets beyond 2030 and for five-year periods up to 2050 will be set in the medium term on the basis of initial feedback from actions taken to reduce greenhouse gas (GHG) emissions, particularly for Scope 3.

Scope 1, 2, 3 reduction milestones with baseline years

Baseline year: 2021

Reduction targets:

2024 results: The 2024 market-based footprint is 3% higher than the Group's 2021 footprint. Scopes 1 and 2 reported a downward trend (down 17%) as a result of initiatives begun in 2022 to reduce energy consumption volumes and diversify the mix.

Energy-specific targets for 2026 vs 2021:

• Reduce total energy consumption by 30% based on 2021 consumption volumes
• Reduce the share of fossil fuels in the energy mix to less than 50%

Alignment with 1.5°C / SBTi validation status

In May 2024, the Science Based Targets initiative (SBTi) validated the Group's targets based on its 2021 carbon footprint:

• Scopes 1 and 2: according to a "1.5°C trajectory"
• Scope 3: covering 73% of Scope 3 according to a "well-below 2°C" trajectory

Scope 3 items whose reduction targets have been validated by SBTi:

• 3-1: Purchased goods and services
• 3-5: Waste generated in operations
• 3-6: Business travel
• 3-7: Employee commuting

The Group used Shared Socio-Economic Pathways SSP1-1.6 and 2.9 scenarios set out by the IPCC in its sixth assessment report for limiting global warming to well below 2°C by 2100.

Key levers / decarbonization pillars

The main items of the Group's 2024 carbon footprint, accounting for 66% of emissions, are:

1. Energy (categories 1-1, 2-1, 2-2, 3-3 of the GHG Protocol): Energy consumed by facilities for lighting, heating, ventilation, air conditioning, hot water, and operating equipment
2. Catering (category 3-1): Food raw materials for over 80 million meals served annually
3. Construction (category 3-2): Resources for materials, construction work, and building lifetime use
4. Commuting (category 3-7): Travel for more than 63,000 employees (FTEs)

Detailed decarbonisation levers with 2030 reduction potential (tCO2e):

Energy-specific actions:

Preventive and corrective maintenance:

• Installation of thermostatic heads on radiators, network balancing, flushing

Equipment replacement:

• Installing high-efficiency boilers
• Installing heat pumps
• Connecting to heating networks

Thermal renovation:

• Large-scale energy refurbishment projects (exterior insulation, replacement of windows/doors) in partnership with site owners

Low-carbon energy:

• Installing photovoltaic systems
• Purchasing renewable energy certificates in Spain and the Netherlands

Performance monitoring:

• Conducting energy audits
• Installing ambient temperature sensors and LoRa (Long Range) data reporting systems (deployed in France, Germany and Italy in 2024)
• Implementing building management systems (BMS)
• Digital tools to track, report and flag variations in consumption/temperatures
• Common platform to monitor and consolidate energy and water consumption

Catering actions:

• Favouring plant-based proteins over animal proteins
• Favouring white meat over red meat
• Favouring supply of local origin (82% of catering purchases in France were national in 2024)
• Reducing food waste

Company vehicles:

• Commitment to convert fleet to fully-electric by 2026 (France and Germany first)
• Flexible sustainable mobility offer in France (employees can choose electric vehicle or sustainable mobility credit)

Construction:

• 100% of new construction projects certified with Environmental Design (LEED), BREEAM (Italy/Belgium), or DGNB (Germany) by end of 2023

CapEx / investment commitments

2024 actual: An estimated €18.7 million was invested in the energy transition for France, Germany and Italy, including:

• France: maintenance and replacement of HVAC equipment, energy retrofit investments in buildings, replacement of equipment, improved insulation
• Germany: LED equipment installation, connections to heating networks and biomass energy sources
• Italy: installation of heat pumps, solar panels and building management systems (BMS)
• Group-wide: installation of long-range radio sensors (LoRa) for France, Germany, Italy and Spain

2025 planned: Investments estimated at between €23 million and €31 million for the Group as a whole.

This amount cannot be reconciled with CapEx published under the European Taxonomy due to:

• Application of materiality exemption for OpEx
• Level of granularity of Taxonomy analysis (only includes investments over €0.8 million)

Financing sources:

• Direct investments by the Group and countries (CapEx plan)
• Energy efficiency contracts with specialised companies (guaranteed energy savings over long period)
• Partnerships with property owners for structural measures
• Power Purchase Agreements (PPA) for on-site or virtual solar power
• Third-party financing or purchase of assets for specific projects (LED systems)
• Grants and subsidies (e.g., energy saving certificates in France)

Material CapEx/OpEx assessment:

More than 12 FTEs are responsible for implementing the actions of the energy transition plan within different functions.

Locked-in emissions and stranded asset analysis

The Group has no significant locked-in emissions as a result of owning and using infrastructures or assets with high emissions that could threaten the achievement of its carbon emission reduction targets. Clariane provides care in medico-social and healthcare facilities and does not market or manufacture products based on industrial processes.

The Group owns 24% of the facilities it operates, with the remaining 76% either leased or operated under public service concession agreements.

In 2024, the average energy intensity for assets operated by the Group:

• 148.67 kWh/sq.m./year
• 29.32 kgCO2e/sq.m. (market-based methodology)
• 30.9 kgCO2e/sq.m. (location-based methodology)

The energy and environmental performance barometer (OID, France) shows that the energy intensity of Clariane's assets per square metre is 5% better than the panel average.

Work to define the Group's climate adaptation plan by the end of 2026 will include targets for adapting the real estate portfolio based on resilience assessments.

Use of carbon credits / removals

The Group does not capture or sequester greenhouse gases as part of its activities.

The Group did not finance any carbon offset or sequestration projects in 2024, either directly or through the purchase of carbon credits. The Group does not use carbon offsetting as a means of achieving its reduction targets.

In line with IPCC recommendations, Clariane considers that carbon offsetting would be justified once the implementation of the reduction actions identified and the measurement of their effectiveness are well advanced, in order to address residual emissions that could not otherwise be reduced.

Internal carbon pricing

In 2024, the Group decided to introduce an internal guide price as a first step. The scope and basis of applying the guide price in 2025 have yet to be defined, but the aim is to add to the criteria regarding energy intensity and exposure to climate hazards already applied by the Investment Committee to acquisitions and new real estate developments.

Governance

The transition plan is embedded within the Group's strategy and implementation is overseen by:

• Board of Directors, specifically its Ethics, Quality and CSR Committee
• CSR Steering Committee chaired by the Deputy Chief Executive Officer
• Mission Committee for energy transition objectives and initiatives
• Climate Committee (created beginning of 2024): brings together Group functions responsible for decarbonisation in their respective areas to manage and monitor reduction efforts; meets quarterly
• Energy Committee: implements the Group's energy transition objectives

The Group's environmental strategy and objectives were presented at the June 2024 Annual General Meeting, while the transition plan was presented to the CSR Steering Committee and the Board's Ethics, Quality and CSR Committee in early 2025.

Carbon impact criteria are embedded within:

• Real estate and asset management strategy
• Investment process
• Purchasing strategy

Variable compensation: Carbon emission reduction criteria have been included in variable remuneration targets for senior executives since 2020.

Climate expertise development:

• Training for Board of Directors and General Management in planetary boundaries and new business models
• Climate Fresk workshops in each regional office in France (130 participants, 10 internal facilitators trained)
• Dedicated online training modules (Clariane Sustainability School) for functional communities and CSR ambassadors
• Module in manager onboarding programme
• Sustainable development week events (Climate Pitch, webinar, themed events, photo competition)

Alignment with European Taxonomy

The Group has not set a target for aligning its turnover (revenue), OpEx and CapEx with the environmental taxonomy because:

• The taxonomy only allows recognition of revenue from property rentals and sales under Activity 12.1 "Residential care activities"
• The Group expects its CapEx alignment to increase going forward, in line with internal work on granularity of analysis by type of CapEx

2024 Taxonomy alignment:

• CapEx of environmentally sustainable activities (Taxonomy-aligned): €90.8m (10% of total CapEx)
  • Climate change mitigation: 6%
  • Climate change adaptation: 4%
• CapEx of Taxonomy-eligible activities (A.1+A.2): €575.9m (63% of total CapEx)

Policies related to climate change mitigation and adaptation

Clariane has formalized its commitment to reducing its carbon footprint and adapting its facilities and operational processes through its environmental and energy policy stemming from the 2024-2028 CSR strategy. This policy represents a direct application of one of the five objectives underlying its corporate purpose: the sustainability and protection of the living environment of its communities.

Environmental and Energy Policy

Scope:

• Applies to all the Group's countries of operation and activities
• Set out in contracts between the Group and its commercial partners
• Referenced in the Sustainable Procurement Charter, a contractual document listing the Group's requirements of its suppliers regarding the use of natural resources including water

Governance and oversight:

• The functions represented in the Group's Climate Committee are specifically responsible for implementing the climate change mitigation and adaptation targets set out in this policy
• Implementation is monitored together with other sustainability matters by:
  • The Board of Directors' Ethics, Quality and CSR Committee
  • The CSR Steering Committee chaired by the Deputy Chief Executive Officer
• The policy is implemented by Group and local management teams in the respective strategies of each functional community, based on their ownership of the targets

Key content and principles:

• Commitment to reducing carbon footprint through:
  • Measuring carbon footprint regularly across entire scope (Scopes 1 to 3)
  • Transition plan for 2030 targeting 26% reduction in total emissions vs 2021
  • Reducing energy consumption by 30% by 2026 (vs 2021)
  • Reducing share of fossil fuels in energy mix to less than 50% by 2026
• Commitment to climate adaptation through:
  • Operational measures to prevent, anticipate and manage business continuity risks from climate hazards
  • Assessing level of climate risk for each facility
  • Defining and implementing adaptation plans for the real estate portfolio
• Reducing use of water and other natural resources

Link to international standards:

• The Group has joined the Science Based Targets initiative (SBTi), which validated its reduction targets according to a "1.5°C" scenario for Scopes 1 and 2 emissions and a "well below 2°C" scenario for Scope 3 emissions
• Reduction targets based on Shared Socio-Economic Pathways SSP1-1.6 and 2.9 scenarios set out by the IPCC in its sixth assessment report for limiting global warming to well below 2°C by 2100
• Targets align with the Paris Agreement on limiting global warming

Public availability:

• The policy and related commitments are disclosed in the 2024 Universal Registration Document, chapter 3, sections 3.2.2 (Climate change) and 3.2.3 (Water management)
• The Group's environmental strategy and objectives were presented at the June 2024 Annual General Meeting
• The transition plan was presented to the CSR Steering Committee and the Board's Ethics, Quality and CSR Committee in early 2025

Monitoring and implementation:

• Progress monitored monthly using a centralized tool for consolidating energy consumption
• Climate Committee oversees implementation of climate change mitigation and adaptation targets
• Carbon emission reduction criteria included in variable remuneration targets for senior executives since 2020
• More than 12 FTEs responsible for implementing energy transition plan actions across different functions
• Tool set up in 2024 to measure and manage carbon trajectory
• Training and awareness initiatives for employees, including Climate Fresk workshops, online training modules, and dedicated events during sustainable development week

Integration into business processes:

• Carbon impact criteria embedded within the Group's real estate and asset management strategy, investment process and purchasing strategy
• Internal guide price for carbon introduced to be applied to investment decisions from 2025
• Energy consumption and carbon footprint performance criteria included in compensation (see ESRS 2-GOV-3)

Related procurement and supplier policies

The Sustainable Procurement Charter (referenced as a contractual document) requires suppliers to limit their use of natural resources including water in manufacturing goods and services sold to Clariane. This charter supports the implementation of the environmental and energy policy across the value chain.

Actions and resources in relation to climate change policies

Climate Change Mitigation Actions

The Group has implemented a climate change mitigation and adaptation plan, formally set out in its environmental and energy policy stemming from the 2024-2028 CSR strategy. Implementation is monitored by the Board of Directors' Ethics, Quality and CSR Committee and the CSR Steering Committee chaired by the Deputy Chief Executive Officer.

Targets for 2026:

• Reduce total energy consumption by 30% (baseline: 2021 consumption volumes)
• Reduce the share of fossil fuels in energy mix to less than 50%

Preventive and Corrective Maintenance

• Installation of thermostatic heads on radiators (controlled or uncontrolled)
• Network balancing and flushing
• New equipment and maintenance operations to reduce energy consumption

Replacement of Equipment and Selection of Local Supply Sources

Replacing heat production systems:

• Installing high-efficiency boilers
• Installing heat pumps
• Connecting to heating networks

Thermal Renovation

• Large-scale energy refurbishment projects in some facilities (exterior insulation, replacement of windows and doors) in partnership with site owners

Use of Low-Carbon Energy

• Installing photovoltaic systems for low-carbon electricity

Electrification of Company Vehicles

• Implementation of an electrification strategy for company vehicles already underway in France and Germany
• Installation of electric charging points at all facilities

Refrigerant Fluids

• Using less emissive fluids in equipment replacement and recharging
• Reducing the use and/or intensity of air conditioning

Resources Allocated

Financial Resources - 2024 and 2025:

For 2025, investments planned in the budgets and identified as contributing to the Group's energy transition, whether financed directly or by third parties (e.g., under energy efficiency contracts), are estimated at between €23 million and €31 million for the Group as a whole.

Non-Financial Resources:

• More than 12 FTEs responsible for implementing the actions of the energy transition plan within different functions (management, technical, real estate, maintenance, processes and tools, etc.)

Financing Models: The Group's preferred financing model is third-party financing:

• Signing energy efficiency contracts with specialised companies, where guaranteed energy savings over a long period ensure the financing of the investment and maintenance
• Partnerships with property owners to contribute financially to implementation of structural measures (insulation, replacing heating systems, etc.)
• Signing Power Purchase Agreements (PPA), particularly covering on-site or virtual solar power production systems
• Third-party financing or purchase of assets for specific projects (installing LED systems in particular)
• Grants and subsidies linked to energy savings (e.g., energy saving certificates in France)

Governance and Awareness-Raising Actions (2024)

• Training for the Board of Directors and General Management in planetary boundaries and new business models
• Organising Climate Fresk workshops in each of the Group's regional offices in France, and every month at Clariane's head office (130 participants and 10 people trained to become internal Climate Fresk facilitators)
• Dedicated awareness-raising sessions with the European Company Works Council
• Launching dedicated online training modules (Clariane Sustainability School) for certain functional communities and CSR ambassadors
• Including a dedicated module addressing these issues in the manager onboarding programme
• Staging specific events during sustainable development week, including Climate Pitch, webinar for sharing testimonies and initiatives, themed events run by facilities in France, and photo competition on climate change in facilities across all Group countries

Monitoring

• Monthly monitoring using a centralised tool for consolidating energy consumption
• Group and local management teams implement the policy in respective strategies of each functional community
• Climate Committee (quarterly) coordinates decarbonisation actions by each of the Group's functional departments

Targets related to climate change mitigation and adaptation

Science-Based Targets initiative (SBTi) validated targets

GHG emission reduction targets (SBTi-validated, May 2024)

Progress to date (2024)

• 2024 carbon footprint (Scopes 1, 2 & 3): 614,358 tCO2e
• Energy-related carbon intensity: 29.32 kgCO2e
• Energy-related GHG emissions reduction vs 2021: -15% (target was -17% by end 2024)
• Potential reduction in GHG emissions by 2030: 249,394 tCO2e

Energy consumption and mix targets

Progress to date (2024)

• Share of fossil fuels in energy mix: 15% (down 2 percentage points vs SBTi pathway)
• Total energy consumed: 720,697 kWh
• Energy intensity: 148.67 kWh/sq.m./year
• 100% of sites subject to climatic hazard exposure analysis

Operational targets for 2025

Medium-term targets (2026)

Included in executive compensation performance conditions:

• Rate of reduction of carbon emissions aligned with revised SBTi objectives for Scopes 1 & 2 by end of 2026
• Target embedded in executive variable compensation schemes

Climate adaptation

Qualitative target:

• Development of quantified climate adaptation plan by end of 2026, including targets for adapting the real estate portfolio
• Analysis of exposure to climate-related hazards completed for 100% of sites (2024)
• Technical assessment of asset resilience levers to be completed in 2025

Additional context

Reduction levers identified for 2030 transition plan:

• Energy: -96,895 tCO2e potential reduction (from building efficiency, renewable energy, heat pumps)
• Company vehicle fleet fuel: -3,391 tCO2e (conversion to fully-electric fleet by 2026)
• Purchased goods and services: -54,107 tCO2e (sustainable procurement, catering footprint reduction)
• Waste: -748 tCO2e (reduction, sorting, recovery)
• Commuting: -25,903 tCO2e (journey optimization, soft mobility, low-carbon vehicles)
• Business travel: -28,345 tCO2e
• Capital goods: -6,263 tCO2e
• Freight: -9,297 tCO2e
• Refrigerant fluids: -2,896 tCO2e

Investments in 2024: €18.7 million invested in transition plan implementation (energy efficiency equipment, renewable energy mix)

Energy consumption and mix

Total energy consumption and disaggregated energy mix

Scope: All Group activities in France, Germany, Belgium, Italy, Spain, Netherlands. Excludes facilities under management contracts (DSP) in Spain due to lack of operational control. Covers all operated facilities as owner or tenant (own operations).

Specific disaggregation by fossil fuel type: Not disclosed at the level required by ESRS E1-5 (coal, crude oil/petroleum products, natural gas, other fossil sources as separate line items). The report provides only an aggregated fossil fuel total.

Purchased or acquired electricity, heat, steam, and cooling: Not separately disclosed by fossil vs. renewable origin beyond the renewable portion already shown.

Energy consumption by country

Energy intensity

Energy intensity (per m²): 148.67 kWh/m²/year (2024) vs. 151.42 kWh/m²/year (2023).

Carbon intensity of energy (per m²):

• Market-based: 29.3 kgCO₂e/m² (2024) vs. 29.6 kgCO₂e/m² (2023)
• Location-based: 30.9 kgCO₂e/m² (2024) vs. 31.8 kgCO₂e/m² (2023)

Intensity calculation scope: Facilities that consumed energy throughout the year (continuous 12-month operation). Facilities that left the scope during 2024 are excluded from intensity metrics but included in absolute consumption for the period they operated.

Contractual instruments (Scope 2)

Guarantees of origin and Power Purchase Agreements: 5.37% of Scope 2 electricity consumption in 2024.

• Guarantees of origin (Spain, Netherlands): 5.16% of Scope 2 consumption
• Power Purchase Agreements (Spain): 0.21% of Scope 2 consumption

These contractual instruments are assigned a fossil fuel emission factor of 0 in the market-based carbon footprint.

Renewable energy production

Self-generated renewable energy: 4,936 MWh (2024), primarily photovoltaic installations. The Group tracks only the self-consumed portion; total production (including electricity sold back to the grid) is not disclosed for 2024. A tracking mechanism for total renewable production is planned for 2025.

Methodology notes

• Estimation for missing data: Where consumption data are unavailable for certain facilities or regions, estimates use ratios established from existing data for facilities in the same country and business, or from other Group countries if same-country data are unavailable.
• Changes in energy mix: Reflect (i) changes in each country's national energy mix, (ii) Group purchasing strategy (purchase of renewable electricity in carbon-intensive grids in Netherlands and Spain; purchase of biogas in France; deployment of on-site photovoltaic in Belgium, Spain, Italy).
• Acquisitions and disposals: Included in consumption proportionally to the time they were part of the Group. UK operations disposed in April 2024 are fully excluded from all 2024 data (immaterial: <0.5% of energy consumption).
• Facilities under management contracts (DSP) in Spain: Energy, water, waste excluded due to lack of operational control per GHG Protocol.
• Nuclear percentage calculation: Based on location-based grid factors for purchased electricity in each country.

High climate impact sector disclosure

Clariane states that none of its main activities belong to a high climate impact sector as defined by the Climate Delegated Act. Therefore, energy intensity per net revenue is not disclosed as a mandatory data point. However, the company voluntarily discloses energy intensity per m² as shown above.

Gross Scopes 1, 2, 3 and Total GHG emissions (ESRS E1-6)

Scope and methodology

The Group's 2024 carbon footprint was calculated based on actual data for the footprint linked to energy consumption, and based on extrapolations drawn from the Group's 2023 carbon footprint and changes in business data for other items. The carbon footprint is estimated at 77% using a market-based methodology and at 76% using a location-based methodology. Full details of the 2024 carbon footprint along with the methodology used to calculate estimates are disclosed in section 3.2.2.5.

The carbon footprint follows the GHG Protocol methodology and covers the Group's entire value chain (Scopes 1, 2 and 3). The carbon footprint covers all Group facilities operated by Clariane as owner or tenant, excluding facilities operated under management contracts for environmental data. Scope includes six countries (France, Germany, Belgium, the Netherlands, Italy and Spain). UK operations disposed in April 2024 are excluded. The Âges & Vie shared housing facilities and Petit-fils home care service data have only been partially reported. Environmental data relating to management agreements in Spain have not been reported due to the lack of operational control over these items.

A change in methodology was made when updating the Group's carbon footprint for the 2023 and 2024 reporting periods. The change concerns energy-related carbon emissions, which had been underestimated following a change in emission factors and the exclusion of the upstream (production) part of energy consumption. This change in methodology represents 15 ktCO2 in market-based emissions and 12 ktCO2 in location-based emissions compared with the data published in 2023, or 2% of the 2024 carbon footprint.

As actual data for 2024 could not be provided in time due to the publication date of the sustainability statement, the data have been extrapolated from the 2023 carbon footprint based on changes in revenue, FTEs or beds, depending on the data category. Where data are not available for certain facilities or regions, estimates are made using ratios established based on existing data for facilities in the same country and, if necessary, in the same business, or existing data for other countries in the Group.

For freight, a percentage estimate of carbon emissions relating to purchased goods and services has been used based on an average figure calculated by the external climate consultancy assisting the Group with the assessment of its carbon footprint. For employee commuting, average commuting distance and modal mix ratios were used.

Total GHG emissions by Scope

Note: The total GHG emissions figure (614,358 tCO2eq) is identical for both market-based and location-based methodologies in 2024, 2023 and 2021, as differences between market-based and location-based Scope 2 emissions are reflected within the respective Scope 2 and Scope 3 (category 3-3) allocations.

Scope 1 breakdown by source (2024)

Scope 2 emissions (2024)

Scope 3 emissions by GHG Protocol category (2024)

Note: Subcategories of Scope 3-1 Purchased goods and services include catering (126,919 tCO2eq in 2021 baseline) and laundry (18,609 tCO2eq in 2021 baseline). Subcategories of Scope 3-2 Capital goods include buildings (62,614 tCO2eq), furniture (10,916 tCO2eq), IT equipment (5,446 tCO2eq) and company vehicle fleet (4,524 tCO2eq) for 2021 baseline.

GHG intensity (2024)

Note: Energy intensity published in other sections (29.7 kgCO2e/sq.m.) includes upstream figures, with a resulting upward adjustment for year n-1 of 13% for the market-based outcome and 9% for the location-based outcome compared to previously published data.

Regulated emissions and biogenic CO2

EU ETS and other regulated emissions: Not disclosed separately.

Biogenic CO2 emissions: Not disclosed separately from Scope 1.

Reduction trajectory and targets

The Group's reduction targets have been validated by the Science Based Targets initiative (SBTi) in May 2024:

• Scopes 1 & 2: -46% by 2031 vs 2021 baseline (1.5°C trajectory)
• Scope 3 (categories 3-1, 3-5, 3-6, 3-7, representing 73% of Scope 3): -28% by 2031 vs 2021 baseline (well-below 2°C trajectory)
• Total GHG emissions (Scopes 1+2+3): -28% by 2031 vs 2021 baseline (SSP1-2.9 well-below 2°C scenario)

Intermediate targets:

• 2026: -15% total GHG emissions vs 2021; -27% Scopes 1 & 2 vs 2021
• 2030: -25% total GHG emissions vs 2021; -43% Scopes 1 & 2 vs 2021

Internal carbon pricing (ESRS E1-7)

Not disclosed.

Anticipated financial effects from climate-related risks and opportunities (ESRS E1-9)

One-year phase-in for quantitative data. Publication of qualitative data planned from 2026 for the 2025 reporting period.

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

Phase-in exemption applied

Clariane is using the one-year phase-in option for ESRS E1-9. The company states:

Qualitative information disclosed

The following qualitative statements are provided in relation to ESRS E1-9:

Exposure of the benchmark portfolio to climate-related physical risks: Included. Publication of qualitative information only.

Location of significant assets at material physical risk: Included. Publication of qualitative information only.

Breakdown of the carrying value of real estate assets by energy-efficiency classes: Not included. One year phase-in.

Degree of exposure of the portfolio to climate-related opportunities: Included. Publication of qualitative information only.

Disaggregation of monetary amounts by acute and chronic physical risk: Not included. One year phase-in.

Future assessment approach

Based on the analysis of exposure to climate hazards carried out in 2024, the Group will assess the resilience of all its real estate assets through to 2026, and define groupwide adaptation plans for each building, and the methods for financing them.

Internal carbon pricing

Based on a study to compare the various possibilities available, Clariane decided to introduce an internal guide price as a first step. The scope and basis of this pricing are being developed, building on the climate risk analysis and exposure to climate hazards already applied by the Investment Committee to acquisitions and new real estate developments.

Policies related to water and marine resources

Clariane does not disclose a specific standalone water and marine resources policy. However, water management is integrated into the Group's broader environmental policies and commitments:

Environment and Energy Policy

Scope:

• Applies to all the Group's countries of operation and activities
• Extended to commercial partners through the Sustainable Procurement Charter

Key content and principles:

• Reducing the use of water and other natural resources is a formal commitment
• Stems from the 2024-2028 CSR strategy
• Represents a direct application of one of the five objectives underlying its corporate purpose: the sustainability and protection of the living environment of its communities
• Reduction in water consumption is based on monitoring leaks, energy-efficient equipment and eco-friendly practices

Governance:

• Implementation monitored by the Board of Directors' Ethics, Quality and CSR Committee
• Monitored by the CSR Steering Committee chaired by the Deputy Chief Executive Officer

Supplier requirements:

• Set out in contracts with commercial partners through the Sustainable Procurement Charter
• Specifies that suppliers' use of natural resources (including water) to manufacture goods and services sold to Clariane must be limited as far as possible

Material impact

The Group has identified a positive material impact in terms of control of water consumed by its activities and the participation of all stakeholders in the responsible use of water. This impact was defined in the double materiality assessment carried out by the Group, with input from the Real Estate, Energy and CSR teams.

Marine resources

The Group does not design or manufacture specific products or services related to water or involving practices that could have an impact on marine resources. Clariane's water uses are similar to domestic uses, as its facilities are reception and living spaces with certain specific features (e.g., rehabilitation centres with balneotherapy facilities).

Actions and resources related to water

Policy and strategic context

Reducing the use of water and other natural resources is a formal commitment in the Group's environment and energy policy stemming from the 2024-2028 CSR strategy. It represents a direct application of one of the five objectives underlying its corporate purpose, namely the sustainability and protection of the living environment of its communities.

Scope: This policy applies to all the Group's countries of operation and activities. It is also set out in contracts between the Group and its commercial partners through the Sustainable Procurement Charter, a contractual document which lists the Group's requirements of its suppliers and specifies that their use of natural resources – including water – to manufacture the goods and services sold to Clariane, must be limited as far as possible.

Action approach

With regard to water management, the Group has identified a positive material impact in terms of control of the water consumed by its activities and hence the participation of all stakeholders in the responsible use of water. This reduction in consumption is based on:

• Monitoring leaks
• Energy-efficient equipment
• Eco-friendly practices

Governance and monitoring

The implementation of the Group's environment and energy policy is monitored together with other sustainability matters by:

• The Board of Directors' Ethics, Quality and CSR Committee
• The CSR Steering Committee chaired by the Deputy Chief Executive Officer

Water usage context

Clariane's water uses are similar to domestic uses, as its facilities are reception and living spaces with certain specific features, for example rehabilitation centres with balneotherapy facilities (20 in France). Total water consumed: 428,729 cu.m.

Water usage includes:

• Kitchen/washing up
• Showers/toilets
• Consumption in drinks
• Laundry
• Balneotherapy
• Watering
• Evaporation

Value chain integration

The Sustainable Procurement Charter extends water resource management requirements to upstream value chain (suppliers and commercial partners).

Water consumption

Total water withdrawals and consumption

Water intensity

Water consumption in water-stressed areas

2024 data:

Key findings:

• 39% of Clariane's facilities are currently exposed to high and extreme water stress
• 60% of facilities are exposed to medium to extreme water stress
• Highest risk in Belgium, Spain and Italy (over 60% of assets exposed)

Methodology notes

• 91% of water withdrawal data based on actual readings or invoices (92% in 2023)
• Water consumption calculated as 8% of water withdrawn (based on ADEME studies), representing evaporation and watering; 92% discharged to wastewater systems
• Estimates used conservative ratio of 5 cu.m. per bed per month for facilities without available data
• Water stress assessment conducted using World Resources Institute's Aqueduct tool v4.0, current timeframe and through 2050 under IPCC SSP3 RCP7.0 scenario
• No water recycling/reuse data disclosed for 2024 (planned for next reporting period in 2025)

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

Phase-in exemption applied

Clariane is applying the one-year phase-in exemption for ESRS E3-5. Quantitative data will be published from 2026 for the 2025 reporting period.

Disclosure timeline

As stated in the phase-in table:

Policies related to resource use and circular economy

Environment and Energy Policy

Policy commitment: Reducing the volume of waste generated and increasing the proportion of waste recycled is part of the commitment to the circular economy set out in the Group's environment and energy policy stemming from its 2024-2028 CSR strategy. It represents a direct application of one of the five objectives underlying its corporate purpose, namely the sustainability and protection of the living environment of its communities.

Scope: This policy applies to all the Group's countries of operation and activities.

Governance: The implementation of this policy is monitored together with other sustainability matters by the Board of Directors' Ethics, Quality and CSR Committee and by the CSR Steering Committee chaired by the Deputy Chief Executive Officer.

Implementation responsibility: The departments responsible for implementing this commitment to the circular economy are the Operations and Real Estate departments in the various countries, assisted by the Group's CSR and Real Estate teams in monitoring and developing operational practices.

Key content:

• Procedures for managing and sorting hazardous and non-hazardous waste are in place at each facility, with treatment depending on the type of waste
• These procedures comply with national or regional regulations and with the objectives set by the Group
• They cover sorting for each waste stream as well as storage and collection methods for each type of waste
• The management of infectious medical waste in particular is closely monitored by local Medical departments, and training is given to the teams responsible for handling such waste
• In accordance with applicable regulations, all hazardous waste is weighed, recorded and monitored in all countries where the Group operates

Specific waste management requirements:

For infectious medical waste:

• Must be collected in specific, rigid, watertight containers with a tight-fitting lid
• Containers must be colour-coded and labelled
• Waste must be transported by approved companies and disposed of at specialised sites

For non-hazardous waste:

• Must be sorted at source and placed in specific colour-coded containers
• Must be collected separately so that it can be recycled or otherwise recovered

Sustainable Procurement Charter

Policy commitment: The environment and energy policy is set out in the contracts between the Group and its commercial partners through the Sustainable Procurement Charter, a contractual document which lists the requirements to be met by the Group's suppliers.

Key content:

• Specifies that suppliers' use of natural resources should be limited as far as possible
• Requires that eco-design, reuse and recycling channels should be used in producing goods and services sold to Clariane

Targets:

• Previous target: reduce the volume of residual waste by 5% per bed by 2023 compared with 2019 (exceeded, achieving 16% reduction from 509 kg to 427 kg of residual waste per bed per year)
• 2024 target: reuse and recycle at least 30% of all waste generated (including hazardous and non-hazardous waste) by 2026
• This objective is aligned with the Do No Significant Harm (DNSH) criteria of the environmental taxonomy on the circular economy

Actions and resources related to circular economy

Overview

The Group has implemented policies and actions to reduce waste volume and increase recycling rates as part of its commitment to the circular economy under its 2024-2028 CSR strategy and environment and energy policy. The policy applies to all Group countries of operation and activities.

Governance and Implementation

Responsible departments:

• Operations and Real Estate departments in various countries (implementation)
• Group CSR and Real Estate teams (monitoring and developing operational practices)
• Board of Directors' Ethics, Quality and CSR Committee (monitoring)
• CSR Steering Committee chaired by Deputy Chief Executive Officer (monitoring)

Waste Management and Sorting Procedures

Scope: Own operations (all facilities)

Actions implemented:

• Procedures for managing and sorting hazardous and non-hazardous waste in place at each facility, complying with national/regional regulations and Group objectives
• Coverage includes:
  • Sorting for each waste stream
  • Storage and collection methods for each waste type
  • Close monitoring of infectious medical waste by local Medical departments
  • Training for teams handling hazardous waste
  • All hazardous waste weighed, recorded and monitored in all operating countries

Infectious medical waste management:

• Collection in specific, rigid, watertight containers with tight-fitting lids
• Colour-coded and labelled containers
• Transport by approved companies
• Disposal at specialised sites

Non-hazardous waste management:

• Sorting at source
• Placement in specific colour-coded containers
• Separate collection for recycling or recovery

Supplier Requirements

Scope: Upstream value chain

Action:

• Sustainable Procurement Charter includes contractual requirements for suppliers:
  • Limit use of natural resources
  • Use eco-design, reuse and recycling channels in goods and services sold to Clariane

Targets and Outcomes

Previous target (2019-2023):

• Target: Reduce residual waste volume by 5% per bed by 2023 vs. 2019
• Outcome: 16% reduction achieved (from 509 kg to 427 kg residual waste per bed per year)

Current target (2024-2026):

• Target: Reuse and recycle at least 30% of all waste generated (hazardous and non-hazardous) by 2026
• Time horizon: Medium-term (by 2026)
• Alignment: DNSH criteria of environmental taxonomy on circular economy

Resources Allocated

Non-financial resources:

• Technical studies and projects with independent technical expert (2019-2024)
• Dedicated departments: Operations, Real Estate, CSR teams across countries
• Training programmes for teams handling hazardous waste
• Governance oversight through Board committee and CSR Steering Committee

Financial resources: Not quantified in the excerpts provided.

Targets related to circular economy

Target 1: Residual waste reduction (2019-2023)

Metric: Volume of residual waste per bed

Target value: 5% reduction

Target year: 2023

Baseline year: 2019

Baseline value: 509 kg of residual waste per bed per year

Type: Intensity-based (per bed)

Scope: Group facilities

Status: Target exceeded

Progress (2023): 16% reduction achieved (from 509 kg to 427 kg of residual waste per bed per year)

Target 2: Waste reuse and recycling (2024-2026)

Metric: Percentage of all waste (hazardous and non-hazardous) reused and recycled

Target value: At least 30%

Target year: 2026

Baseline year: Not disclosed

Baseline value: Not disclosed

Type: Absolute percentage

Scope: All waste generated (hazardous and non-hazardous)

Alignment: Aligned with Do No Significant Harm (DNSH) criteria of the environmental taxonomy on the circular economy

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

Phase-in exemption applied

Clariane has applied a one-year phase-in for ESRS E5-5 (Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities).

Publication of qualitative data from 2026 for the 2025 reporting period.

Waste

Waste Management Approach

Clariane's waste management approach is described in section 3.2.4 under ESRS E5 (Waste management). The Group has implemented waste reduction, sorting and recovery initiatives across its facilities.

Key metrics disclosed:

• Waste sorted and recycled: 44% (2024 target in CSR scorecard)
• Waste recovered: 87% (of which 44% reused/recycled) as stated in business model value chain diagram
• Hazardous medical waste: 2.2% of total waste
• 457 kg of waste per bed per year (stated in environment section of business model)

Waste collection and reporting:

The Group works with more than 250 waste collection service providers. Between 50% to 100% of waste is collected by public services, depending on the country. Given the broad range of service providers and the significant proportion of information not available from public waste collecting entities, recovery methods for various waste streams have been defined according to national practices based on recommendations of an external technical expert and national and European studies, including Eurostat surveys.

Methodology notes:

Where waste collection data are not reported by the collection service provider (generally when collection is organised by the local authority), data for the facility were estimated on the basis of data available for equivalent facilities in the same country, or in other countries if data for the same country are not available. By the end of 2026, following a test run in the last quarter of 2024, the Group aims to have deployed a new reporting methodology for waste collected at facilities that is not measured by service providers.

Estimates of waste volumes and recovery methods are used where actual data are not available. The Group's medium-term objective is to reduce the proportion of estimated data as measurement methods and reporting tools improve.

More than 10 categories of on-site waste are managed across facilities. Detailed quantitative waste data are referenced as disclosed in section 3.2.4.2 (ESRS E5-5).

Policies related to own workforce

Clariane's human resources (HR) policies are set out in the Clariane Quality Management Standard for management and support functions, which is implemented in each country and at every site. Specific adaptations are made for the Âges & Vie and Petit-fils businesses.

Clariane Quality Management Standard - Human Resources Process

Scope: All countries and operations, with specific adaptations for shared living (Âges & Vie) and home care (Petit-fils) businesses in France.

Key content / principles: The Standard defines principles, rules and procedures for:

• Workforce planning and recruitment
• Onboarding and integration
• Administrative management of personnel and payroll
• Health, safety and well-being at work
• Social dialogue
• Training and skills development
• Talent management and career development
• Diversity, equity and inclusion

Governance: The Group Human Resources Department develops and implements HR policies. Implementation is monitored by:

• Ethics, Quality and CSR Committee (Board of Directors level)
• Group HR Committee (Executive Committee level)
• Mission Committee (through dedicated working groups)

Country HR directors implement policies locally, adapting to local regulations.

Link to standards: Policies aim to ensure alignment and compliance with:

• Core conventions of the International Labour Organization
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• Human Rights Policy Declaration (published on Group website)

Monitoring: Implementation monitored through governance committees and the Clariane Standard Human Resources process.

Clariane Policy on the Management System for the Prevention of Workplace Accidents, and Occupational Health and Safety

Key content / principles: Based on six pillars:

• Work with social partners
• Involve line managers
• Identify and limit risks
• Train employees and raise their awareness
• Draw on data analyses
• Maintain a culture of continuous improvement

Scope: 100% of the Group's employees and non-employee workers on its sites.

Governance: Group Human Resources Department coordinates network of health and safety managers in each country. Health and safety officer appointed at each site.

Monitoring: Results monitored monthly by Group Management Board and its Risks, Ethics and Compliance Committee. Implementation includes 360° audits conducted at least every other year.

Clariane Policy on Talent Management and Career Development

Key content: Supports training and internal mobility objectives.

European Charter on the Fundamental Principles of Social Dialogue

Adoption date: Signed 23 October 2023

Governance: Negotiated and signed by Clariane's General Management, the General Secretary of EPSU (European Public Service Union) and the Secretary of the European Works Council.

Key content / principles: Guarantees:

• Freedom of expression and association
• Collective bargaining
• Social dialogue at all levels (local, regional, national, European)
• Training for managers in social dialogue
• Time and material resources proportionate to needs
• Protected status for employee representatives

Link to standards: Based on:

• ILO Conventions numbers 87 and 98 concerning freedom of association and collective bargaining
• OECD Guidelines for Multinational Enterprises
• Community Charter of the Fundamental Social Rights of Workers
• French Act No. 2017-399 pertaining to corporate duty of care

Public availability: Referenced in company documentation and Charter.

Ethics Charter

Adoption date: Updated June 2023 to coincide with change of corporate name and transition to purpose-driven company status.

Scope: Binding on all employees. Given to each new hire.

Key content / principles: Defines values and ethical commitments expected of Group employees, including:

• Trust, Initiative and Responsibility as core values
• Professional conduct with integrity and transparency
• Prohibition of all forms of discrimination
• Respect for freedom of association
• Prohibition of illegal exploitation and/or child and forced labour

Public availability: Published on institutional websites of the Group and its subsidiaries.

Link to standards:

• Formally aligned with UN Global Compact (signatory since 2019)
• Aligned with Human Rights Policy Statement principles
• Based on International Bill of Human Rights
• Based on fundamental conventions of the International Labour Organisation

Monitoring: Presentation during onboarding process. Annual "Values Month" communication and training activities. "Let's Talk Values" card game and e-learning module introduced for employees.

Anti-corruption Code of Conduct

Scope: Applies to and is binding on all employees. Communicated to partners with contractual relationships.

Key content / principles: Covers:

• Gifts and hospitality
• Prevention of conflicts of interest
• Sponsorship and patronage
• Third-party due diligence
• Accounting controls

Governance: Monitored by Board of Directors' Ethics, Quality and CSR Committee (quarterly meetings) and Risk, Ethics and Compliance Committee (bi-monthly meetings).

Link to standards: Compliance with French Law No. 2016-1691 of 9 December 2016 on transparency, prevention of corruption and modernisation of the economy (Sapin II Law).

Monitoring:

• Corruption risk mapping updated annually
• Training plan including e-learning and specific workshops
• 86% of top management trained in anti-corruption in last two years
• Audit and Internal Control Department conducts level 3 controls

Human Rights Policy Statement

Public availability: Published on Group website.

Key content / principles: Commitments relating to:

• Fight against discrimination against employees and non-employee workers
• Respect for freedom of association
• Prohibition of illegal exploitation and/or child and forced labour

Link to standards:

• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• International Bill of Human Rights
• Fundamental ILO Conventions

Sustainable Procurement Charter

Public availability: Published on Group website.

Link to standards: Supports commitment to United Nations Global Compact (joined 2019).

Occupational Health and Safety Agreement (France)

Scope: France

Governance: Signed with all representative trade unions.

Key content: Supplements European Health and Safety Protocol.

Women Empowerment Principles (WEP) Commitment

Adoption date: CEO signed November 2020 at European Works Council meeting.

Link to standards: Women Empowerment Principles of UN Global Compact.

Key content / principles: Three priorities:

• Health, safety and well-being of employees, with focus on fight against violence against women
• Education, training and promotion, with focus on developing qualifying training paths and increasing proportion of women in top management
• Measurement and reporting on progress

Monitoring: Clariane Women's Club created in 2019, chaired by former director of operations of Clariane Italy. Mentoring programmes and awareness campaigns conducted.

Diversity, Equity and Inclusion (DE&I) Policy

Development: Comprehensive Europe DE&I action plan drawn up in 2024 and shared with countries.

Key content / principles: "4+1" plan focuses on:

• Inclusion
• Four areas of work: disability, gender identity and sexual orientation, culture and origin, age
• Equal opportunities regardless of differences
• Non-discrimination

Governance: In Italy, DE&I Committee formed with 10 members from HR and operations, chaired by Italy HR Director.

Monitoring: Assessing employees' feelings about discrimination through annual C-Pulse survey. Reviewing results in Diversity section of Top Employer certifications. Measuring representation of diversity.

Compensation Policy

Scope: All Group employees in Europe.

Key content / principles:

• Fixed basic wage set in accordance with national/local legislation
• Social protection (health, personal protection, benefits in kind)
• Access to employee share ownership
• Annual variable compensation for management (subject to objectives)
• Long-term performance-related compensation
• Collective compensation for employees in France

Monitoring: Wages reviewed annually through mandatory collective bargaining or individual pay review process. All employees paid at or above benchmark minimum wage in main European markets.

Training Policy

Implementation: Supported by Clariane University in each country.

Key content / principles: Four pathways:

• Initial training (including apprenticeships)
• Continuous professional training
• Validation of acquired experience
• Career conversion training path

Monitoring: Nearly 820,000 hours of training provided in 2024, with average of 11.8 hours per FTE. 7,780 employees on qualifying training path in 2024 (12.1% of FTEs).

Taking action on material impacts on own workforce

Clariane's S1-4 disclosure is integrated across multiple sections of the sustainability statement (3.3.1.3 to 3.3.1.9). The company describes policies, actions and programmes addressing its material workforce impacts through structured HR frameworks.

General HR Policy Framework

Clariane Quality Management Standard (human resources process) defines principles and procedures covering:

• Workforce planning and recruitment
• Onboarding and integration
• Administrative management of personnel and payroll
• Health, safety and well-being at work
• Social dialogue
• Training and skills development
• Talent management and career development
• Diversity, equity and inclusion

Scope: All Group activities, aligned with mission commitments and CSR strategy applicable to all countries (France, Germany, Belgium, Netherlands, Italy, Spain)

Formalised policies at Group level:

• Clariane policy on management system for prevention of workplace accidents and occupational health and safety
• Clariane policy on talent management and career development
• Social dialogue charter (European Charter on Fundamental Principles of Social Dialogue, signed 23 October 2023)

Actions by Material Impact Area

1. Training and Skills Development (ESRS S1-13)

Clariane University (operational in France since December 2023, Italy from January 2024, Germany from November 2024)

Four academies structure the training offer:

• Academy of Care
• Academy of Hospitality and Services
• Academy of Management
• Academy of Leadership

Qualifying training programmes:

• 2024 results: 7,780 employees (12.1% of FTEs) enrolled in qualifying training paths
• Target 2025: 7,000 employees
• Target 2026: 7,200 employees
• Average training hours: 11.8 hours/FTE in 2024 (total 819,670 hours)

Apprenticeship programmes:

• 2024: 3,116 apprentices (4.9% of FTEs), including 2,051 in Germany and 1,065 in France
• Focus professions: nurses and cooks (France), nurses (Germany)

WAYS programme (replacement of s.Keys launched 2020):

• European training for facility directors
• Service leadership model aligned with values (Trust, Responsibility, Initiative)
• First cohort of 26 facility directors started in France end-2024
• All facility directors to receive training by 2025-2026

MEOS Executive Master (France):

• Level 7 RNCP qualification (M2 equivalent)
• 55 graduating Group employees in France in 2024
• Enables employees without master's degree to qualify for facility director positions

Validation of Acquired Experience (VAE):

• Over 1,000 employees enrolled in VAE programme by 2024 in France
• Enables qualification without returning to school

CSR awareness and training:

• Climate Fresk workshops (130 participants at headquarters, 10 internal facilitators trained)
• Clariane Sustainability School (online modules for functional communities)
• Dedicated module in manager onboarding programme
• Target 2024: Minimum 2 awareness actions per country (achieved: 21 actions across all countries)
• Target 2026: Minimum 4 awareness actions per country

Social dialogue training:

• 2024 result: 42% of facility directors trained
• Target 2026: Over 95% of facility directors trained

2. Health, Safety and Well-being (ESRS S1-14, S1-15)

Health and Safety Protocol (European, signed with European Works Council 2021)

Six pillars of action:

• Work with social partners
• Involve line managers
• Identify and limit risks
• Train employees and raise awareness
• Draw on data analyses
• Maintain culture of continuous improvement

Coverage: 100% of employees and non-employee workers

Accident frequency rate targets:

• 2024 result: 31 (vs. 37 in 2023, 41 in 2022)
• Country-specific targets for 2026 (total accident frequency rate reduction)

Actions implemented in 2024:

• France: Continued increase in transfer rails to avoid heavy loads
• Italy: New training programme on aggressive behaviour
• Belgium: Workplace health and safety awareness days
• Germany: Health and safety visits by management
• Group-wide: Integration of safety footwear policy adapted to different professions
• Awareness campaigns featuring OSCAR (health and safety mascot) in all countries

Psychosocial support programmes:

• France: Anonymous Stimulus hotline (24/7), social worker services
• Italy: Stimulus hotline implemented 2024
• Belgium: Trained trustworthy persons at each site
• Germany: "Health Champions" designated
• Spain: "Therapyside" listening service (launched 2024)

France-specific mediation service (since 2021):

• Extended to staff in 2023
• 2024: 34 requests for internal mediation received
• 16 internal facilitators conduct mediations

Group therapy and coaching:

• Spain: 3 group therapy sessions in 2024 via Therapyside
• Germany: 28 team/individual coaching sessions, 82 professional supervision sessions in 2024

Solidarity fund:

• Operational in France
• Created in Germany in 2024
• To be launched in other countries 2025-2026

3. Compensation and Social Protection (ESRS S1-10, S1-11)

Fixed wage policy:

• All employees paid at or above benchmark minimum wage in main European markets
• Annual reviews through collective bargaining or individual pay review
• Wages aligned with national/local legislation and collective agreements

Social protection:

• Health and personal protection insurance: 100% coverage in accordance with rules in each country
• France: Profit-sharing scheme for value sharing

Employee share ownership:

• Capital increases reserved for employees
• First capital increase in 2024: 2,289 employees (3.6% of workforce) purchased 1,109,574 shares for total €7.4m
• Leveraged share purchase plan (France): 3.7% subscription rate
• Gradual rollout to other countries (Germany, Belgium, Italy)

Variable compensation schemes:

• Annual variable compensation: linked to financial and sustainability criteria
• Long-term performance share plan: 3-year vesting subject to financial and sustainability criteria
• Applied to executives, directors, all managers in each country

4. Social Dialogue (ESRS S1-8)

European Charter on Fundamental Principles of Social Dialogue (signed 23 October 2023)

Commitments:

• Freedom of expression and association
• Collective bargaining
• Social dialogue at all levels (local, regional, national, European)
• Protected status for employee representatives
• Regular training for managers on social dialogue

Employee representation:

• Works councils/employee representatives in all countries
• European Company Works Council
• Regular meetings and consultations

France-specific agreements:

• Fourth Disability Agreement signed in 2024
• Occupational Health and Safety Agreement (signed with all representative trade unions)
• Equality Agreements

Spain-specific:

• Equality Agreements signed in 2024 for three entities (Consulting, Ita, Senior)

Monitoring metric (C-Pulse 2024):

• 71.2% of respondents agreed/strongly agreed that social dialogue is of good quality

5. Gender Equality (ESRS S1-9)

Clariane Women's Club (created 2019, chaired by former director of operations Italy)

Country committees established in all countries

Two priorities:

• Women's leadership and empowerment
• Combating violence against women

Actions in 2024:

• Mentoring programmes for women created in Belgium, Italy, France
• Personal development workshops for female managers at Group headquarters
• Awareness campaigns: Stop gender stereotypes, Stop stereotypes of women in top management, "Humour or sexism" (launched January 2024)
• First European awareness campaign on LGBT+ issues (Pride month June 2024)
• Renewal of signature of L'Autre Cercle Charter (2023)
• Signatory of #StOpE initiative against casual sexism

"One in Three Women" network (co-founder with FACE Foundation)

• European campaign to raise awareness about violence against women
• Training and awareness modules

Italy gender equality certification:

• Afnor UNI/PdR 125:2022 standard
• All legal entities certified (all sites and headquarters)
• Gender Equality Officer appointed
• Diversity and Inclusion Committee established

France Gender Equality Index:

• Calculated annually for Clariane France Economic and Social Unit (ESU)
• Compliance with Law No. 2018-771 of 5 September 2018

Representation targets monitored:

• Proportion of women facility directors: 71% at 31 December 2024
• Proportion of women in top management: 53% at 31 December 2024
• Proportion of women on Group and Country management committees: 38% in 2024
• Target 2026: 45% women on Management Committees

Board of Directors gender equality:

• 43% women (6 women, 8 men) since 12 June 2024
• 45% women average in 2024

6. Diversity, Equity and Inclusion (ESRS S1-9, S1-12)

"4+1" Europe DE&I action plan (drawn up 2024)

Four priority areas:

• Disability
• Gender identity and sexual orientation
• Culture and origin
• Age

DE&I Committee:

• Established in Italy with 10 members (HR and operations)
• Chaired by Italy HR Director

Disability initiatives:

• France: Fourth agreement signed in 2024; awareness campaign on DYS disorders
• Germany: Partnership with dedicated recruitment platform
• European webinar 2024 with ADAPT experts
• Two videos with testimonies from France and Germany promoting employment of people with disabilities
• Belgium Brussels region: Diversity label

LGBT+ inclusion:

• Signature of Autre Cercle commitment charter (Clariane France and Clariane SE)
• LGBT makeover of Clariane logo during Pride month June 2024
• Brochure on stereotypes created

Partnerships:

• La Maison des Femmes (Saint-Denis and Tours, France)
• D.i.Re association for social reintegration (Italy)

Annual diversity celebrations:

• 25 November: International Day for Elimination of Violence against Women
• 8 March: International Women's Rights Day
• 17 May: International Day Against Homophobia, Biphobia and Transphobia
• 3 December: International Day of Persons with Disabilities

7. Career Development and Internal Promotion

C-Talents platform:

• Information system for employee and career development
• Based on professional reference framework (4 main sectors, 30 key professions)

Annual performance appraisal campaign:

• All employees invited to annual appraisal and professional development interview (first half of each year)
• Via C-Talents platform or paper
• Covers: objectives/achievements, training needs, internal mobility, professional development aspirations

Career Committees:

• Annual organisation in all countries after appraisal campaigns
• Bottom-up process led by HR function
• Prepares replacement/succession plans
• Identifies high potential and emerging talents

Internal promotion to facility director:

• 2024 result: 50% of vacancies filled by internal candidates
• Target 2026: 75%
• All internal candidates without master's degree automatically enrolled in MEOS training
• Then complete WAYS training when taking up position

Skills matrix:

• Hard skills: Professional skills (knowledge), Methodological skills (know-how)
• Soft skills: Know and take care of yourself (social skills), People skills, Leadership

Resources Allocated

Training investment:

• Total training hours 2024: 819,670 hours
• 7,780 employees on qualifying training paths (12.1% of FTEs)
• 3,116 apprentices (4.9% of FTEs)

Employee share ownership:

• 2024 capital increase: €7.4m from 2,289 employees

Compensation schemes:

• Variable compensation linked to sustainability criteria (20% weighting for Chief Executive Officer)
• Performance share plans with sustainability criteria

Human resources:

• Health and safety officers at each site (100% coverage)
• Country HR directors in each country
• Group HR Committee (monthly meetings)
• HR Leadership Management Committee (quarterly)
• CSR Ambassadors in each country
• Network of health and safety managers in each country
• 16 internal mediation facilitators (France)

Technology and tools:

• C-Talents platform for employee/career development
• Reporting tools for workplace accidents, absenteeism
• Care software integration for quality metrics
• Group reporting tool

Partnerships:

• Top Employer Institute (annual certification audits)
• ADAPT (disability integration)
• Therapyside (Spain psychosocial support)
• Universities: Complutense University of Madrid ("Against Stigma" chair), Pompeu Fabra University Barcelona (management training programme)
• EPSU (European Public Service Union)
• Autre Cercle (LGBT+ inclusion)
• FACE Foundation (violence against women)
• Onda (Italy, women's health)

Expected Outcomes and KPIs

Training:

• Qualifying training paths: 7,000 (2025), 7,200 (2026) employees
• Facility directors trained in social dialogue: 95% by 2026 (42% in 2024)
• CSR awareness actions: minimum 4 per country by 2026 (2 in 2024, 21 achieved)
• Internal promotion to facility director: 75% by 2026 (50% in 2024)

Health and safety:

• Country-specific accident frequency rate reduction targets for 2026
• 2024 result: frequency rate 31 (down from 37 in 2023)

Gender equality:

• 45% women on Group and Country Management Committees by 2026 (38% in 2024)
• Top management: 53% women at end 2024 (exceeded parity target)

Social dialogue quality:

• C-Pulse survey: 71.2% positive responses on social dialogue quality (2024)

Top Employer certification:

• Maintained in all 6 countries for 2025
• Europe-level certification achieved

Links to Policies and Targets

All actions are implemented under:

• Clariane Quality Management Standard (human resources process)
• HR policies addressing material impacts identified in double materiality assessment
• Mission commitments as purpose-driven company
• 2024-2028 CSR roadmap (approved by Board of Directors 28 February 2024)
• European Charter on Fundamental Principles of Social Dialogue (23 October 2023)
• Human Rights Policy Declaration (published on website)
• UN Global Compact (joined 2019)
• Women's Empowerment Principles (WEP) (signed 2020)
• ILO core conventions
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises

Actions monitored by:

• Ethics, Quality and CSR Committee (Board level)
• Group HR Committee (Executive Committee level, monthly)
• HR Leadership Management Committee (quarterly)
• Mission Committee (working groups on employee health/safety/wellbeing, training/mobility, value sharing)
• CSR Ambassadors Committee
• Country Management Boards

Targets related to own workforce

Clariane has disclosed the following targets related to managing material impacts, risks and opportunities associated with its own workforce:

Note: These metrics are identified as entity-specific quantitative indicators under ESRS S1-5 for tracking targets related to own workforce. However, the excerpts provided do not contain specific target values, target years, or baseline values for these metrics.

Characteristics of the undertaking's employees

Total headcount and FTE

2024:

• 63,086 FTEs (full-time equivalents)
• 50,256 permanent employees
• 12,829 temporary employees

Comparison:

• 2023: 63,000 employees (FTE) mentioned in introductory letter
• Prior year data referenced but not systematically disclosed for all metrics

Headcount by gender

• 80% women
• 20% men (implied)
• 53% of top management positions held by women

Headcount by country/region

By country (FTEs):

Total Group FTE: 63,086

Note: UK operations (690 employees) disposed April 2024 and excluded from reporting.

Headcount by employment contract type

• Permanent employees: 50,256 FTEs
• Temporary employees: 12,829 FTEs
• Total: 63,086 FTEs

Percentage breakdown:

• Permanent: ~80% of total workforce
• Temporary: ~20% of total workforce

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

Partial disclosure:

The breakdown of full-time and part-time employees is only published for France and Germany, representing 68% of total Group FTEs. Full Group-level breakdown not disclosed in 2024 reporting period.

New hires (permanent contracts)

By country:

Apprenticeships and work-study (France):

• 864 new apprentice hires in 2024
• 1,728 work-study students in 2024 (total enrolled)

Employee turnover

• Turnover rate: 22% (2024)
• Target: 18%
• Prior year data: not disclosed for comparison

Note: Turnover rate calculated on the basis of permanent employees.

Other workforce characteristics

Average age:

• 45 years (permanent workforce)

Average seniority:

• Referenced as tracked but specific figure not disclosed

Job family breakdown (% of workforce):

Non-employee workers:

The company also employs:

• Private practitioners
• Home help in franchised networks
• Temporary staff

Specific headcounts for these categories not disclosed.

Scope and methodology notes

• Reporting scope: Six countries (France, Germany, Belgium, Netherlands, Italy, Spain)
• Exclusions: UK operations disposed April 2024 excluded from all 2024 data
• Âges & Vie and Petit-Fils: Employee data for these shared housing and home care services only partially reported (representing ~1,700 FTEs, ~2.5% of total)
• Facilities under management contracts (DSP): HR information included in published data
• Methodology: FTE calculations and permanent/temporary classification follow Group standards; some indicators use different calculation bases (e.g., turnover based on permanent employees only)

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

Overview

In addition to employees, Clariane calls on several types of regular non-employee workers:

• Self-employed medical staff (e.g., doctors, physiotherapists, psychotherapists, etc.), who work in facilities in addition to the specialities present in-house. This is particularly common in specialised psychiatric clinics.

Transitional provisions applied

Clariane has activated the one-year phase-in provision for ESRS S1-7 data as stated in section 3.1.1.2 of the Universal Registration Document:

"With regard to these different categories of stakeholders, the Group will disclose quantitative information for 2025 during the next reporting year, in accordance with the transitional provisions."

This provision is also confirmed in the ESRS phase-in table presented in section 3.1.1.2:

Scope and methodology considerations

The preliminary note in section 3.3.1.2 clarifies the terminology:

"Throughout the section on the company's own workforce, the term 'employees', used mainly in relation to qualitative information, refers to Clariane employees, i.e., people bound to the company by an employment contract and employed by the Group. The term 'employees' is also used in relation to quantitative metrics. Self-employed people or people provided by companies primarily engaged in 'employment activities' are referred to as 'non-employee workers'."

The health and safety management system covers non-employee workers on Clariane premises, as stated in section 3.3.1.6:

"These provisions ensure that the Group's health and safety management system covers 100% of the Group's employees and non-employee workers on its sites."

Disclosure status

Quantitative data on the number and characteristics of non-employee workers will be disclosed in the 2025 sustainability statement for the 2025 reporting period.

Collective bargaining coverage and social dialogue

Policy and commitments

Clariane has formalised its commitments to social dialogue and respect for human rights through its European Charter on the Fundamental Principles of Social Dialogue, signed on 23 October 2023. The Charter was negotiated and signed by Clariane's General Management, the General Secretary of EPSU (European Public Service Union) and the Secretary of the European Works Council.

The preamble recalls that "This Charter is based on ILO Conventions numbers 87 and 98 concerning freedom of association and collective bargaining, as well as on the OECD Guidelines for Multinational Enterprises."

Through this Charter, Clariane commits itself to guaranteeing freedom of expression and association, collective bargaining, social dialogue at all levels and training for managers in social dialogue.

Key principles of the Charter:

• Freedom of expression
• Information and communication with employees
• Freedom of association and employee representation
• Social dialogue at all levels: local, regional, national and European
• Time and material resources proportionate to needs
• Protected status for representatives
• Respect for ideas and people, in line with the law in force and values
• Management roles as key social dialogue players
• Regular training regarding social dialogue
• Monitoring implementation through the European Works Council

Employee representation and collective bargaining coverage

100% of Clariane's employees have employee representatives, across all activities and geographies.

100% of employees are covered by industry or company-level collective bargaining agreements.

Industry and company-level collective agreements govern the terms and conditions of employment and compensation of Clariane employees in each country.

Coverage by country (2024)

Social dialogue structures

European Works Council: Created in 2019 and reformed in 2022, comprising 21 employee representatives (6 from France, 6 from Germany, 4 from Belgium, 2 from Italy, 2 from Spain, 1 from the Netherlands). The Council holds two plenary meetings per year, with a Bureau meeting at least four times per year.

Country-level representation:

• France: Central Social and Economic Committee (CSEC) and facility-level CSEs covering Korian, Inicea, Clariane support functions, Âges & Vie and Petit-fils businesses
• Germany: 40 local works councils, Curanum committee with 12 members, national Forum Betriebsrat with 20 representatives
• Belgium: Regional works councils and central committee with federation representatives
• Spain, Italy, Netherlands: Union delegates appointed by respective confederations

Training in social dialogue

Clariane has committed to training all site directors in social dialogue, with the goal of training more than 95% of them by 2026.

Site directors trained in social dialogue (%):

This metric covers site managers in all countries with more than one year's seniority and present on 31 December of each year.

Employee perception of social dialogue

In 2024, Clariane sought for the first time to measure employees' views of the quality of social dialogue through the C-Pulse survey.

71.2% of respondents indicated that they agreed or strongly agreed with the statement "The company promotes quality social dialogue."

Collective agreements signed in 2024

A total of 12 specific agreements were signed in 2024, including:

France:

• Agreement on forward-looking management of jobs and career paths
• Fourth agreement on employment and retention of people with disabilities (signed unanimously)
• Cost-of-living measures collective agreement (signed with UNSA, CFDT and FO)

Spain:

• Equality Plans for Senior and ITA entities

European level:

• European Charter of Fundamental Principles of Social Dialogue (October 2023)
• Joint European Company Works Council declaration on the Group refinancing plan

Working groups

Thematic working groups established with the European Works Council:

• Working group on occupational health & safety and workplace accident prevention (since 2019, meeting at least twice per year)
• Working group on reducing absenteeism (since 2020)
• Working group on CSR strategy and training (since 2023, meeting at least twice per year)
• Ad hoc working group on internal communications

Methodology note

The training metric covers site directors with more than one year's seniority present at 31 December 2024. Coverage percentages are calculated based on all employees under employment contracts in each country. Collective bargaining coverage includes both sector-wide and company-level agreements.

Diversity metrics

Gender diversity in top management and governance

Women on Group and Country Management Boards:

Women in top management (approximately top 150):

Additional gender diversity metrics at 31 December 2024:

Women in site manager positions:

Board of Directors gender diversity:

As disclosed in section 3.1.2.1 and 4.1 Corporate governance.

Age band distribution of workforce

Breakdown of FTEs by age group at 31 December 2024:

Scope: All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils). All countries. Own operations.

Gender pay gap

Average pay gap by country (2024):

Negative values indicate women earn more on average. The calculation is based on the pay of permanent and temporary employees who have been with the company for more than six months, using the French Pénicaud index calculation method. The pay gap can be as high as 15% for engineers and managers in France.

Persons with disabilities

Number and percentage of persons with disabilities at 31 December 2024:

Scope: All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils). All countries. Own operations.

Multi-year trends

The Group has set targets to achieve and maintain gender balance, with a particular focus on women in top management (≥50% target) and on Group and Country Management Committees (≥40% target) by 2026. The proportion of women in top management decreased slightly from 54% (2023) to 53% (2024), while the proportion on Management Committees decreased from 42% (2023) to 38% (2024).

Adequate wages

Benchmark used

Clariane states that all employees are paid at or above the benchmark minimum wage in the main European markets. The company references:

• National and/or local legislation which "systematically imposes minimum levels of pay for each job category"
• Applicable collective pay scales (collective agreements, industry agreements)
• Regular review of minimum levels "to ensure that the Group's employees all receive an adequate basic wage"

In France specifically, minimum wages are negotiated annually at sector level under collective agreements drawn up by the main trade unions and federations (FHP for healthcare institutions and SYNERPA for nursing homes).

The Group explicitly states: "Although the Group's exclusively European footprint ensures that benchmark minimum wages are regularly reviewed to take into account changes in the cost of living, Clariane plans to launch a comparative analysis in 2025 between the starting salaries of these employees and the appropriate wage levels recommended by market benchmarks."

Coverage

The metric "% of employees earning less than the minimum reference wage" is listed in the methodology table (S1-10) with scope:

• All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils)
• All countries
• Own operations

However, no percentage or numeric value is disclosed in the excerpts provided.

Geographic scope

All six countries where Clariane operates: France, Germany, Belgium, the Netherlands, Italy and Spain.

Targets and commitments

Clariane plans to launch a comparative analysis in 2025 between starting salaries and "appropriate wage levels recommended by market benchmarks" (i.e., living wage benchmarks). No numeric target or commitment deadline is provided.

Methodology

No living wage methodology is disclosed for 2024. The company notes in section 3.7 (certification report) that there were "methodological difficulties encountered in determining the living wage, which is not presented for the 2024 financial year".

The S1-10 metric is defined as "% of employees earning less than the minimum reference wage. At end of period." No further detail on how this reference wage would be calculated or which external benchmark would be used is provided.

Social protection

Coverage of employees by social protection schemes

All Group employees are covered by social protection against loss of income due to major life events, in accordance with the legal requirements and specific characteristics of each country.

France:

Type of scheme: Employees are covered by a health and personal protection insurance scheme, with contributions paid in accordance with the rules in force in the various countries and sectors.

Scope: All the Group's employees are covered, operating exclusively in Europe. Coverage is provided through public programmes and company-offered schemes in accordance with national and/or local legislation.

Exclusions: Coverage details for countries other than France are not fully disclosed in the extracted sections, though the document confirms all Group employees across all European countries are covered by social protection in accordance with local legal requirements.

Persons with disabilities

Policies and actions

Clariane has committed to promoting the employment and retention of people with disabilities as part of its comprehensive Europe DE&I (Diversity, Equity and Inclusion) action plan developed in 2024.

Key initiatives include:

• France: In 2024, a fourth agreement was signed to promote the employment and retention of people with disabilities. A major awareness-raising campaign focused on DYS disorders was run.

• Germany: An action plan involving the creation of a working group on disability inclusion.

• Italy: Specific training on inclusive language has been introduced. A DE&I Committee has been formed with 10 members from HR and operations.

The Group's Diversity, Equity and Inclusion policy aims to eliminate all forms of discrimination and create a climate of trust where all differences are embraced.

Metric definition and scope

According to the Group's methodology note (section 3.5), the following metric is tracked:

Methodology and legal restrictions

The metric is subject to legal restrictions regarding data collection, which vary by country. This means that disability status cannot be reported uniformly across all jurisdictions where Clariane operates.

The data represents employees with disabilities at end of period, excluding:

• Shared housing (Âges & Vie) operations
• Home care franchise network (Petits-Fils)

Measurement of effectiveness

Measuring the effectiveness of diversity and inclusion actions involves:

• Assessing employees' feelings about discrimination (annual C-Pulse survey of employees in all countries and activities)
• Reviewing the results in the Diversity section of Top Employer certifications by country
• Measuring the representation of diversity where it is possible to do so (proportion of women vs men, age, people with disabilities)

Note: The document acknowledges that measurement of disability representation is only possible where legally permitted.

Quantitative disclosure

No specific percentage or headcount figures for persons with disabilities are disclosed in the 2024 Universal Registration Document, reflecting legal restrictions on collecting and reporting such data across the Group's operating countries.

Training and skills development metrics

Average training hours per employee

Scope: All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils). All countries. Own operations.

Employees on qualifying training paths

As % of FTEs: 12.1% in 2024

Note: 2023 Group data includes UK activities (81 employees on qualifying training paths). UK excluded from 2024 data following sale in April 2024.

Scope: All countries. Own operations.

Internal promotion - facility directors

Scope: All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils). All countries. Own operations.

CSR awareness initiatives

Scope: All countries. Own operations.

Performance and career development reviews

Disclosure: The Group has activated transitional provisions for performance review and career development metrics. One-year phase-in for these data. Publication planned from 2026 for the 2025 reporting period.

Breakdown by gender and employee category

Disclosure: Due to difficulties in collecting certain data in all countries, the Group has activated transitional provisions for certain breakdowns of average training hours (by gender and employee category). These breakdowns are not disclosed for 2024.

Training investment

Total investment in training: €2,254 million spent on salaries and training (combined figure disclosed in sustainability statement, not separately itemized for training alone).

Health and safety metrics

Coverage of health and safety management system

100% of Clariane's employees and non-employee workers on its sites are covered by the Group's health and safety management system.

Fatalities

No fatalities were reported as a result of a workplace accident or in relation to a work-related illness in 2024.

Work-related accidents recorded

Workplace accident frequency rate

The frequency rate is calculated on the basis of the total number of lost-time accidents for the reference year, for all types of employment contract, multiplied by 1,000,000 and divided by the total number of hours worked (12 months) for the same period.

Days lost to work-related accidents or illness

Absenteeism rate

Absenteeism covers several forms of absence: workplace accidents, commuting accidents, simple sick leave and occupational illnesses.

Scope and methodology notes

The Group has activated the transitional provisions for metrics related to non-employee workers' health and safety, the number of work-related illnesses and eligibility for and use of family-related leave. These will be included in the next sustainability statement for 2025.

All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils) are covered in own operations across all countries.

Due to reporting deadlines, the presented frequency rates may still include some workplace accident reports that were subsequently rejected by national social security organisations, particularly in Belgium. However, in France, the 2024 frequency rate excludes, for the first time, reports of workplace accidents rejected by the primary health insurance funds (CPAM).

Work-life balance metrics

Disclosure status

Clariane has activated transitional provisions for ESRS S1-15 metrics. The company explicitly states:

"One-year phase-in for these data" (ESRS S1-15 Work-life balance)

And in the note on methodology:

"as a reminder, due to difficulties in collecting certain data in all countries where it operates, the Group has activated the transitional provisions for metrics related to non-employee workers' health and safety, the number of work-related illnesses and eligibility for and use of family-related leave. These will therefore be included in the next sustainability statement for 2025."

Employee survey insights on work-life balance

While quantitative metrics on family-related leave are deferred, Clariane reports employee perceptions of work-life balance through its annual C-Pulse survey:

• 78% of employees who responded agreed with the statement "I have a good work-life balance" (2024)
• Survey participation rate: 70% (2024)

Social protection coverage

Clariane confirms that 100% of employees are covered for parental leave under legal regimes, though detailed utilization metrics and gender-disaggregated data are not yet reported.

Detailed metrics on percentage of employees entitled to family-related leave (maternity/paternity/parental/family care), percentage who took such leave by gender, and return-to-work rates after parental leave will be disclosed in the 2025 sustainability statement.

Compensation metrics (ESRS S1-16)

Pay gap

Clariane calculates the gender pay gap for all countries using the French Pénicaud index calculation method. The calculation is based on the pay of permanent and temporary employees who have been with the company for more than six months.

On this basis, the average pay gap varies from -1.22% to 2.61% for women, depending on the country and/or for all activities combined in 2024. As there are many employees at the lower end of the pay scale, where there is little or no pay gap, the overall gap is small.

Gender pay gap by country (2024):

Phase-in approach:

In 2025, work on a more detailed analysis by level will be started to identify variations in the pay gap by employee categories and to provide the consolidated gender pay gap at Group level. For example, the pay gap can be as high as 15% for engineers and managers in France.

Data points not yet reported:

The following data points for which reporting is mandatory from the first year have not been reported or have only been partially reported, and for which an action plan is being implemented to publish the information in 2025:

• The breakdown of the gender pay gap by main employee category and the publication of this indicator at consolidated Group level (see section 3.3.1.8)

Remuneration ratio

The annual total pay ratio is calculated each year to measure the difference between the highest and median compensation of the Group's employees.

Components included in the calculation:

• Annual fixed compensation paid during the relevant year
• Annual variable compensation paid during the relevant year in respect of the previous year
• Other components of annual compensation paid during the year in question (such as exceptional bonuses, Ségur bonuses, etc.)
• Performance shares that vest during the year, valued in accordance with IFRS

The ratio is calculated by dividing the compensation of the highest paid individual to the median annual total compensation for all employees of the Clariane Group who have been with the company for more than 12 months.

Annual total pay ratio:

*Data from the United Kingdom has been removed from the 2023 data, following the disposal of the UK subsidiary in 2024.

It was 34 in 2024, down by 17% vs 2023 (recalculated excluding the United Kingdom following the disposal of the subsidiary in 2024).

Methodology

Pay gap methodology:

The Group calculates the gender pay gap using the French Pénicaud index calculation method (the Group scored 92 on this metric in France in 2024). The calculation is based on the pay of permanent and temporary employees who have been with the company for more than six months.

Remuneration ratio methodology:

The scope used to calculate median compensation is that of the entire Clariane Group. The ratio is calculated for employees who have been with the company for more than 12 months.

Scope:

Gender pay gap: All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils); all countries; own operations.

Remuneration ratio: All activities excluding shared housing (Âges & Vie) and home care franchise network (Petits-Fils); all countries; own operations.

Incidents, complaints and severe human rights impacts

Incidents of discrimination and harassment

In 2024, 69 of the 78 justified complaints (those involving substantiated claims) concerned violence (verbal or physical), and one concerned theft. 53 disciplinary measures were taken, with 13 cases still under review as of the date of this Universal Registration Document. 20 cases were reported to the authorities.

Of the 63 reported incidents of discrimination, 19 had been confirmed by the end of the reporting period and primarily concerned cases of harassment.

Complaints and severe human rights impacts

With regard to alerts, complaints and incidents recorded as of 31 December 2024:

• There were no fines, penalties or compensation for damages as a result of these incidents and complaints
• The Group was not subject to any severe human rights incidents related to its own workforce
• The Group did not observe any non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises
• The Group was not subject to any fines, penalties or compensation for damages as a result of severe human rights incidents

Scope

The metrics cover all activities, all countries, and own operations (including upstream non-employee workers where applicable).

Data table summary from methodology section

Policies related to affected communities

Clariane addresses affected communities (local communities) through several policy instruments and commitments, as disclosed in sections 3.3.2.3 to 3.3.2.5.

Sustainable Procurement Charter

Policy name: Sustainable Procurement Charter (updated in 2024)

Scope: The Charter applies to relationships with suppliers and is sent out with each call for tenders for suppliers to sign when they sign their contract. It has also been sent to all existing referenced suppliers.

Key content and principles:

• Integration of Corporate Social Responsibility (CSR) commitments into relationships with suppliers
• Clear definition of mutual obligations between the Group and its suppliers
• Particular focus on compliance with applicable regulations
• Commitment to promoting local and inclusive purchasing to contribute to economic development in the regions where Clariane operates
• Support for the inclusion of the most vulnerable people in society
• Supporting local and inclusive suppliers
• Consideration of criteria relating to product origin and the supplier's practices in terms of employing vulnerable people and developing the social and solidarity economy

Link to international standards: The Charter aims to ensure compliance with applicable regulations regarding human rights and fundamental freedoms (referenced in sections 3.3.2.1 and 3.3.2.2 in relation to UNGPs, ILO principles, and OECD guidelines).

Implementation and monitoring:

• Criteria relating to product origin and employment of vulnerable people are considered throughout the purchasing process, notably during supplier selection and contracting
• The weighting of these criteria in calls for tender is determined by purchasing category
• In 2024, preferred suppliers accounted for 82% of the Group's purchasing volume
• The indicator is measured using a questionnaire sent to preferred suppliers
• The aim for 2025 is to set targets for metrics and develop corresponding action plans

Clariane Quality Standard

Policy name: Clariane Quality Standard

Scope: Applies to all facilities

Key content and principles:

• Outlines consistent requirements for all facilities regarding management of relationships with local stakeholders
• A facility's integration into its local health, medico-social and social ecosystem
• Quality of relationships with local authorities (regulatory bodies, public authorities, and local elected officials) are among the management responsibilities
• Activities fostering connections with the local community (bringing local people into the facility and taking residents out into the wider community) must be offered to residents in nursing homes

Implementation and monitoring:

• Management responsibilities are formalized within the Standard
• A survey was conducted across facilities in 2023 to identify local partnerships and best practices
• In 2024, an issue of the Group CSR newsletter was devoted to local partnerships to report survey findings and share practical examples

Locality Commitment (2024-2028 CSR Strategy)

Policy commitment: Promoting partnerships with local communities is a key initiative within Clariane's 2024-2028 CSR strategy, aligning with the Locality commitment.

Scope: Group-wide, with focus on facilities and Group-level support

Key content and principles:

• A local partnership is defined as a partnership with a local organisation or volunteers, generally formalised by a partnership agreement
• Aim of carrying out regular joint initiatives (at least one a year) with positive impact on residents/patients/families, employees and local communities
• Support for charitable and philanthropic projects that benefit local communities in the areas where the Group operates

Implementation and monitoring:

• At Group level: facilitating the sharing of best practices between countries; identifying and showcasing inspiring local partnerships
• Creation of two corporate foundations, one in France (Clariane "Aimer Soigner" Foundation) and one in Germany
• Partnerships with non-profit organisations in countries where Clariane operates
• The 2026 initiative aims to support facilities in developing partnerships

Clariane "Aimer Soigner" Foundation (France)

Policy instrument: Corporate foundation dedicated to caregivers and care professions (extended for three years from 1 January 2023)

Governance: Funded jointly by Clariane France and the Clariane Group

Key content and principles:

• Dedicated to caregivers and the care professions
• Taking action to care for caregivers and promote care professions
• Conducting social studies and social initiatives in partnership with other stakeholders, including public authorities and non-profit organisations
• Supporting partners through financial sponsorship, skills sponsorship provided by Clariane employees, and sponsorship in kind (including provision of premises)

Implementation: Main projects in 2024 included:

• Cardiovascular health prevention through the Women's Heart Bus
• SMOKEOUT studies on smoking among caregivers in partnership with University of Versailles-Saint-Quentin-en-Yvelines
• End-of-life care support through "Café Pallia"
• Promotion of physical activity among caregivers
• "Aimer Soigner" podcast highlighting care professions
• Presentation of care professions to young people through United Way partnership (23 Clariane volunteer workers introduced their profession to more than 700 young people)

Taking action on material impacts on affected communities

1. Local and Inclusive Purchasing (ESRS S3-1, S3-4, S3-5)

Scope: Own operations and upstream value chain

Description: Clariane's Sustainable Procurement Charter (updated 2024) aims to integrate CSR commitments into supplier relationships, with two key pillars:

• Local Purchasing: Promoting geographic origin of goods and services (national, regional, local levels)
• Inclusive Purchasing: Employment of vulnerable people, disabled workers, marginalised workers, and social/solidarity economy development

Actions implemented:

• Supporting local and inclusive suppliers through the Sustainable Procurement Charter
• Considering product origin and vulnerable employment criteria throughout purchasing process (supplier selection, contracting, dialogue)
• Weighting criteria in calls for tender by purchasing category
• Participation in collaborative initiatives (France: founding member of Collective of Companies for a More Inclusive Economy)
• Charter sent with all tenders and to existing referenced suppliers

Metrics (2024):

• Preferred suppliers with national products/services: 82% of purchasing volume
• Inclusive purchasing: €22.8 million spent with inclusive sector suppliers (2.4% of Group purchasing volume)

Next steps (2025):

• Set target for inclusive purchasing metric
• Develop action plan to promote local/inclusive purchasing through:
  • Strengthening existing partnerships
  • Identifying new local/inclusive suppliers
  • Strengthening contract clauses on product origin and vulnerable employment

Link to policy: Sustainable Procurement Charter, Locality commitment in CSR strategy

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2. Local Partnerships (ESRS S3-1, S3-4, S3-5)

Scope: Own operations (1,200+ facilities in 6 countries)

Time horizon: 2026 initiative within 2024-2028 CSR strategy

Description: Development of partnerships with local organisations or volunteers, formalised by partnership agreements, conducting regular joint initiatives (minimum one per year).

Partnership types:

• Volunteers
• Schools
• Cultural institutions
• Local residents
• Local authorities

Actions:

• Survey conducted across facilities (2023) to identify partnerships and best practices
• Group CSR newsletter issue (2024) devoted to local partnerships, reporting survey findings and sharing practical examples
• Facilitating sharing of best practices between countries
• Identifying and showcasing inspiring partnerships
• Facility directors invited elected/re-elected members of parliament to visit facilities to raise awareness

Requirements: Formalised in Clariane Quality Standard:

• Integration into local health, medico-social and social ecosystem
• Quality relationships with local authorities
• Activities fostering community connections (bringing people into facility and residents out)

Link to policy: Clariane Quality Standard, Locality commitment in 2024-2028 CSR strategy

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3. Partnerships with Non-Profit Organisations and Corporate Foundations (ESRS S3-1, S3-4, S3-5)

Scope: Group-level support for local communities across operating countries

Time horizon: 2024-2028 CSR strategy

Structure:

• Two corporate foundations (France and Germany)
• Partnerships with non-profit organisations in operating countries
• Funded by Clariane France and Clariane Group

3.1 Clariane "Aimer Soigner" Foundation (France)

Purpose: Dedicated to caregivers and care professions (since 2023, extended for 3 years)

Resources:

• Financial sponsorship
• Skills sponsorship (employee volunteers)
• In-kind sponsorship (provision of premises)

Actions - Caring for Caregivers:

Women's Heart Bus (cardiovascular health prevention)

• Multi-year partnership with Agir pour le Cœur des Femmes non-profit
• Travelling initiative stopping in ~20 French cities
• Clariane facility professionals volunteer for screening women without healthcare access
• 2024: Supported Women's Heart Day at Inicea Sur Moreau clinic in Saintes

SMOKEOUT studies (smoking among caregivers)

• Partnership with SPOT department, University of Versailles-Saint-Quentin-en-Yvelines
• Ground-breaking prevention programme
• Completed first phase: protocol definition and consumption study

"Café Pallia" (end-of-life care support)

• Digital café series for caregivers on end-of-life support
• Expert: Dr Claude Grange (palliative care specialist)
• Videos available to all on Foundation website

Physical activity promotion

• Partnership with SPS non-profit
• Six digital workshops on physical activity and well-being for caregivers
• Videos available on Foundation website

Actions - Promoting Care Professions:

"Aimer Soigner" podcast

• 12 episodes highlighting 14 care professions
• Partnership with Partage de Voix non-profit
• Testimonies from Clariane professionals
• Available on all podcast platforms and Foundation website

"Mémoires de soignants" (testimonies, 2nd edition)

• Collaboration with biographer Régine Zohar
• Personal testimonies showcasing profession diversity and careers
• Available on Foundation website

Presentation to young people (2023/2024 school year)

• Partnership with United Way (Alliance pour l'Education)
• 12 events in partner schools
• 23 Clariane volunteer workers
• Reached 700+ young people

Link to policy: Locality commitment in 2024-2028 CSR strategy, Foundation roadmap focusing on caring for caregivers and promoting care professions

Targets related to affected communities

Clariane discloses several metrics related to local communities (ESRS S3-5) in its sustainability statement. However, no quantified targets with target years are explicitly disclosed for these metrics. The company presents measurement approaches and metrics but does not establish specific numerical targets or timelines.

Metrics presented (without quantified targets or target years):

Strategic commitments mentioned:

The document states: "The aim for 2025 is to set a target for this new metric and to develop a corresponding action plan" regarding local purchasing metrics. This indicates that quantified targets are planned for the future but have not yet been established in this reporting period.

Business conduct policies and corporate culture

Clariane's corporate culture is guided by its company purpose and values, as defined in its Articles of Association in 2023: "Taking care of each person's humanity in times of vulnerability". Two of Clariane's five commitments relate to compliance with fair and sustainable business practices:

• Consideration: show respect and consideration to every individual for whom we care and their loved ones, as well as every one of our employees and stakeholders, while also fighting all forms of discrimination;
• Fairness: develop a fair and sustainable business operating model that benefits patients, residents and their families, employees and other stakeholders for all business lines and investment decisions.

Clariane has defined three core values: Trust, Initiative and Responsibility. Professional conduct must be reflected in actions carried out in an ethical manner with integrity and transparency, embodying the corporate purpose and culture.

Ethics Charter

Policy name: Ethics Charter

Key content/principles: Sets out the Group's values and ethical commitments, defining attitudes expected and those to be avoided. The Charter lays the foundations for values and attitudes expected of Group employees. It addresses care ethics, work ethics and business ethics. The Charter was updated in June 2023 to coincide with the change of corporate name and transition to purpose-driven company status.

Scope: All employees. The Charter is binding on each employee.

Governance:

• The Board of Directors' Ethics, Quality and CSR Committee meets quarterly
• The Group's Safety, Ethics and Crisis Management Department (reporting to the Medical, Ethics and Health Innovation Department) is responsible for facilitating and coordinating actions and tools relating to ethical matters
• Supported by the Human Resources Department and the Legal Department in charge of Compliance
• Actions are reported to the Risk, Ethics and Compliance Committee, chaired by the Chief Executive Officer

Public availability: Published on the institutional websites of the Group and its subsidiaries for consultation by all internal and external stakeholders. Given to all employees during onboarding.

International standards: As a signatory of the United Nations Global Compact since 2019, and as formally set out in its Human Rights Policy Statement, Clariane is committed to respecting internationally recognised human rights principles defined by the International Bill of Human Rights and the fundamental conventions of the International Labour Organisation. The Group strives to implement relevant policies and actions in line with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.

Monitoring:

• All new employees receive a document outlining the Group's values and ethical commitments, including information on whistleblowing channels
• Presentation of values given during onboarding process
• Annual "Values Month" with communication and training activities focusing on Group values and expected ethical behaviour
• "Let's Talk Values" card game developed around practical cases and ethical dilemmas for team discussion
• E-learning module introduced for employees
• Annual "Live my Life" day during Values Month for head office employees to spend a day in facilities

Anti-corruption Code of Conduct

Policy name: Anti-corruption Code of Conduct

Key content/principles: The Group attaches utmost importance to preventing and combating all forms of corruption, whether active or passive, public or private, and any risk of breaches of probity and influence peddling. The Code is the basis for the Group's policy on gifts and entertainment, prevention of conflicts of interest, and management of sponsorship/patronage operations. It is supplemented by internal procedures and guidelines covering:

• Gifts and hospitality
• Prevention of conflicts of interest
• Sponsorship and patronage
• Third-party due diligence
• Accounting controls

Scope: All employees. The Code of Conduct applies to and is binding on all employees, and is communicated to partners with whom the Group has a contractual relationship.

Legal framework: Subject to French Law No. 2016-1691 of 9 December 2016 on transparency, prevention of corruption and modernisation of the economy (Sapin II Law). Article 17 provides for implementation of a system to prevent and detect acts of corruption and influence peddling.

Governance:

• Compliance Department (established September 2022) reporting to the Group Legal Department
• Departments in charge of compliance in each country
• Actions discussed by the Group Risk, Ethics and Compliance Committee (meets every two months)
• Audit Committee reviews implementation of compliance system and reports regularly to the Board of Directors

Components of compliance programme:

• Corruption risk mapping, updated annually
• Third-party assessment procedure applied in countries where the Group operates
• Online and in-person training modules dedicated to raising employee awareness
• Specific accounting procedures incorporated into internal control standards
• Whistleblowing system managed at Group level by the Director of Safety, Ethics and Crises and at country level by compliance departments

Monitoring:

• 86% of top management have taken anti-corruption training in the last two years
• Regular reminders sent to main functions most exposed to risks
• Employees and suppliers made aware of the Compliance Department for assistance
• System control plan drawn up specifying departments in charge of control
• Group's Audit and Internal Control Department conducts level 3 controls and includes corruption/fraud issues in audit plan
• In 2024, there were no convictions or fines for violation of anti-corruption or anti-bribery laws

Whistleblowing System (Integrity Line)

Policy name: Internal Whistleblowing System / Integrity Line

Key content/principles: Allows anyone connected to the company to report anonymously or not, via secure external platform, email or post, any incident concerning Clariane or its facilities that appears to represent a threat or harm to the general interest, or violate applicable laws or ethical rules (as set out in the Ethics Charter). Covers:

• Situations contrary to regulations
• Breaches of Ethics Charter or Code of Conduct
• Risks of corruption or conflict of interest
• Serious violations to the environment, human health or safety, human rights and fundamental freedoms

Scope: Open to employees, job applicants, employees of co-contractors, shareholders, voting rights holders at AGM, Board members, residents/patients and their relatives.

Governance:

• Managed at Group level by the Director of Safety, Ethics and Crises
• At country level by departments in charge of compliance
• Dedicated department in each country responsible for overseeing the internal whistleblowing system
• Group and country alert committees meet monthly
• Most complex or sensitive events monitored at Group level and presented to Group Risks, Ethics and Compliance Committee
• Summary of special cases presented quarterly to the Ethics, Quality and CSR Committee of the Board of Directors

Legal protections: Firmly committed to providing legal protections available to whistleblowers, including safeguarding anonymity and ensuring no retaliation for making a report, in accordance with laws governing such systems in European countries where Clariane operates.

Public availability: System set out on company's website and intranet, in the Group's Ethics Charter and Code of Conduct. Brought to attention of all new recruits and approved service providers in contracts. Communication campaigns frequently organised at head offices and facilities.

Compliance with standards: Complies with Articles 6 and 17 of French Law 2016-1691 (Sapin II Law) and French Law 2017-399 of 27 March 2017 on duty of care. Supplemented by procedures relating to processing of alerts and handling of internal investigations.

Monitoring: Reports systematically reviewed to determine validity; appropriate measures taken where necessary. Handling may involve internal investigation led by department responsible for internal whistleblowing system. In 2024, use of this reporting channel is increasing year on year thanks to information and awareness-raising campaigns.

Sustainable Procurement Charter

Policy name: Sustainable Procurement Charter

Key content/principles: Aims to integrate Clariane's Corporate Social Responsibility (CSR) commitments into relationships with suppliers and clearly define mutual obligations of the Group and its suppliers, particularly with regard to applicable regulations. Includes commitments on:

• Supporting local and inclusive suppliers
• Considering criteria relating to product origin and supplier's practices in employing vulnerable people
• Respect for human rights and working conditions of employees of Clariane Group suppliers

Scope: All suppliers. The Charter is sent out with each call for tenders so suppliers can sign it when signing their contract. Also sent to all existing referenced suppliers.

Governance: Group Purchasing teams manage implementation in conjunction with country purchasing departments.

Public availability: Systematically sent out during invitations to tender and incorporated into contracts with approved service providers.

Monitoring: Referenced suppliers (nearly 1,200 accounting for 82% of total expenditure) subject to EcoVadis assessment to evaluate sustainability performance.

Human Rights Policy Statement

Policy name: Human Rights Policy Statement

Key content/principles: Formal commitment to respecting internationally recognised human rights principles. Part of broader commitments formalised in the Ethics Charter and Sustainable Procurement Charter.

International standards: Based on:

• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises on Responsible Business Conduct
• United Nations Global Compact (signatory since 2019)
• International Bill of Human Rights
• Fundamental conventions of the International Labour Organisation

Public availability: Published on the Group's website.

Additional governance and compliance elements

Clariane implements a due diligence process as defined in the United Nations Guiding Principles on Business and Human Rights. The Group is subject to French Law No. 2017-399 on the duty of care incumbent on parent companies and contracting companies, requiring establishment of a Duty of Care Plan.

The Group ensures compliance with minimum safeguards regarding:

• Human rights (compliance with French Law 2017-399)
• Corruption (compliance with Sapin II Law)
• Labour law (compliance with employment legislation)
• Taxation (verification that the Group complies with national tax legislation)
• Business ethics

Clariane has not identified any cases of convictions calling into question compliance with minimum safeguards in relation to these aspects.

Any failure to comply with internal anti-corruption standards or applicable regulations may result in sanctions being imposed on employees concerned and, for the Group's partners, termination of contractual relationship.

Prevention and detection of corruption and bribery

Anti-corruption policy

Clariane has established an anti-corruption policy as part of its business conduct framework.

Scope and coverage:

• Common core training for all Group employees in the form of e-learning
• Specific awareness-raising initiatives and face-to-face workshops
• Specific training for functions deemed most at risk, particularly members of top management who can make the most important commitments on the Group's behalf
• Suppliers are also made aware of the Compliance Department

Governance and oversight:

• Supervised by the Legal Department in charge of compliance matters
• The Group Risk, Ethics and Compliance Committee meets every two months to discuss implementation and monitoring of compliance actions
• The Audit Committee reviews the implementation of the compliance system, particularly regarding prevention of corruption, and reports regularly to the Board of Directors

Key content and principles:

• Internal procedures set out in the Code of Conduct to prevent incidents of corruption
• Covers corruption and fraud in the audit plan
• Employees and suppliers can be assisted by the Compliance Department in all matters relating to business ethics

Monitoring implementation:

• 86% of top management have taken anti-corruption training in the last two years (2024)
• Regular reminders sent to main functions concerned and those most exposed to risks
• In 2024, there were no convictions or fines for violation of anti-corruption or anti-bribery laws
• Non-compliance may result in sanctions on employees and termination of contractual relationships with partners

Links to international standards:

• Reference to the UN Convention (ESRS G1-1 disclosure requirement mentions alignment with UN Convention)

Whistleblower protection policy

The Group has procedures in place to provide whistleblower protection (referenced in sections 3.4.1 and 3.7).

Incidents of corruption or bribery

Confirmed incidents and convictions

In 2024, there were no convictions or fines for violation of anti-corruption or anti-bribery laws.

As stated in section 3.4.2: "In 2024, there were no convictions or fines for violation of anti-corruption or anti-bribery laws."

Investigation procedures and speak-up mechanisms

Clariane has implemented a comprehensive compliance programme in accordance with the French Sapin II Law (Law No. 2016-1691 of 9 December 2016). The programme includes:

• Corruption risk mapping: Updated annually to identify and assess risk scenarios based on the Group's processes, evaluating criticality in terms of impact and probability of occurrence
• Anti-corruption Code of Conduct: Supplemented by internal procedures and guidelines covering gifts and hospitality, prevention of conflicts of interest, sponsorship and patronage, third-party due diligence, and accounting controls
• Internal whistleblowing system: Available to all employees, job applicants, co-contractors, shareholders, Board members, residents, patients and their relatives. The system is deployed across all countries where Clariane operates. Reports can be made anonymously through a secure external platform, by email, or by post
• Training programme: Common core e-learning for all employees, plus specific awareness-raising and face-to-face workshops for functions deemed most at risk. In 2024, 86% of top management completed anti-corruption training
• Governance oversight: The Risk, Ethics and Compliance Committee meets bi-monthly to discuss implementation and monitoring of compliance actions. The Audit Committee reviews the compliance system regularly and reports to the Board of Directors

Whistleblower protections

Clariane is firmly committed to providing legal protections to whistleblowers, including:

• Safeguarding anonymity
• Ensuring no retaliation for making a report in good faith
• Strict confidentiality duties for staff handling alerts, who receive specific training

Sanctions policy

Any failure to comply with internal anti-corruption standards or applicable regulations may result in sanctions being imposed on the employees concerned and, for the Group's partners, termination of their contractual relationship with Clariane. The Group reserves the right to take additional measures to assert its rights.

Payment practices

Supplier overview

Clariane maintains business relations with a network of more than 39,000 suppliers, including nearly 1,200 referenced suppliers, accounting for 82% of total expenditure.

Annual purchase breakdown: July 2023 to June 2024

Total annual purchasing expenditure exceeds €1.1 billion.

Purchase breakdown by category

The percentage of total purchases represented by main categories (analysis carried out in H2 2023 and H1 2024):

• Food and beverages: 13.9%
• Facility management and maintenance: 13.2%
• Support function services: 13.2%
• Energy: 11.8%
• Furniture, fixtures and equipment: 8.1%
• Medical products and consumables: 7.6%
• HR: 6.6%
• IT and telecoms: 6.2%
• Resident services: 5.1%
• Laundry and linen: 5.0%
• Real estate: 4.1%
• Non-medical products and consumables: 2.2%
• Mobility: 1.7%
• Events: 0.9%
• Office furniture: 0.5%

Supplier payment terms

Contractual payment terms (number of days / % of purchases calculated over the period from H2 2023 to H1 2024):

Methodology note: In general, new suppliers are created with a contractual payment term in accordance with the laws in force in the country concerned, taking into account specific one-off legal requirements, depending on the purchasing category.

Average payment time and late payments

The Group's purchasing database does not allow Clariane to exhaustively monitor its compliance with supplier payment terms (percentage of invoices paid late and average payment period) for the Group's entire scope and reporting period. The Group considers that an estimate would not give a sufficiently accurate picture of reality. Accordingly, the data reporting tool is currently being rolled out and a review of supplier contracts has been launched to identify and check the payment deadlines to be met, particularly for SME suppliers.

As a result, the Group will wait until the end of 2025 to ensure that it reports reliable, complete and comparable indicators for 2024.

Legal proceedings for late payment

At 31 December 2024, there were no legal proceedings in progress relating to late payments.

Supplier assessment (EcoVadis)

• In 2023, 669 referenced suppliers were eligible for an EcoVadis assessment in all countries
• In 2023, 226 suppliers had a valid EcoVadis score (33% of eligible suppliers)
• In 2024, 252 of these suppliers obtained or improved their valid EcoVadis score (an increase of 11% in the number of suppliers), representing 37% of eligible suppliers
• At the end of 2024, 359 new referenced suppliers in France and Italy had yet to receive an EcoVadis assessment

Scope exclusions

Data exclude shared housing (Âges & Vie) and home care franchise network (Petits-Fils) activities.