Compagnie Chargeurs Invest

Governance roles

Reference: pages 34-35 (section 2.1.2.1 "CSR Governance players (Gov-1 and Gov-2)").

As of December 31, 2025 the Board of Directors was composed of seven members, including one executive member (14% of the Board), Mr. Michael Fribourg (Chairman and CEO). "The committee comprises four female directors (representing 57% of its members), including one independent director (14% of its members)." Mr. Emmanuel Coquoin is the director designated as lead director on climate change. "To date, employees and other workers are not represented within the administrative, management or supervisory bodies."

The Board relies on three specialized committees: the Sustainability Strategy Committee (preliminary discussions, major strategic orientations), the Audit Committee (reviews the process for mapping the Group's risks, impacts and opportunities) and the Nomination/Compensation-type committees described in chapter 4.

CSR governance chain: Board of Directors (defines multi-year CSR guidelines, annually reviews results) -> Group CSR Department (structures and coordinates CSR strategy, reports to Executive Management) -> a two-headed CSR Steering Committee (one meets monthly with business-line CSR/HR Directors, the other meets quarterly on the Group's two priority themes, Climate and Responsible Purchasing) -> a network of CSR correspondents in each business line -> an Ethics Committee for business conduct.

Information provided to and sustainability matters addressed

Reference: pages 34-37 (sections 2.1.2.1-2.1.2.4).

The Audit Committee reviews the process for mapping the Group's risks, impacts and opportunities, "as well as the strategy for managing the issues assessed as the most material." The Board "annually reviews the results obtained and assesses the opportunity, if necessary, to adapt the action plan."

The CSR Steering Committee structure informs the Board's agenda: one committee "meets monthly with the CSR and Human Resources Directors of the business lines," the other "meets quarterly on the Group's two priority themes: Climate and Responsible Purchasing."

On internal control (GOV-5): "The Audit Committee, on behalf of the Board of Directors, reviewed the results of this work [the 2025 double materiality assessment] and issued recommendations to make the approach even more closely aligned with the Group's context and its operational challenges."

Executive Management "presents to the Board of Directors the policies developed in the area of CSR, the methods for implementing them, and the time horizons... It informs the Board of the results obtained on an annual basis.

Integration of sustainability-related performance in incentive schemes

Reference: page 35 (section 2.1.2.2).

"Since 2019, CSR criteria have been integrated into the compensation system for executives and managers. They concern 100% of Compagnie Chargeurs Invest's managers, representing approximately 261 people in 2025."

Mechanism:

• "a 10% portion of the annual bonus of subsidiary directors and managers is indexed to the performance of their teams in connection with the roll-out of the CSR roadmap and the achievement of two objectives in 2025: the lost-time injury frequency rate and the percentage reduction in greenhouse gas emissions based on the 2022 baseline year";
• "the annual variable compensation of the Chairman and Chief Executive Officer... is composed of 70% financial criteria and 30% non-financial criteria."

Full compensation-policy detail is cross-referenced to subsection 4.4 (Directors compensation) of the URD.

Group Due Diligence (GOV-4)

Reference: pages 35-36 (section 2.1.2.3).

Undertaken "under the Sapin II law, and in anticipation of the transposition into French law of the new Corporate Sustainability Due Diligence Directive (CS3D), adopted in May 2024."

The report maps the five core elements of due diligence to sustainability-statement sections and the departments responsible:

"In 2026, Compagnie Chargeurs Invest plans to enhance this assessment by establishing a responsible investment procedure... beginning with the impact on the Group's climate-transition trajectory."

Management standards such as ISO norms are promoted across directly managed sites and among partners/suppliers; certification coverage tables (ISO 14001, 45001/SMETA, 9001, 50001, OEKO TEX 100) are reported for production sites with more than 50 employees.

Articulation with the overall internal control framework (GOV-5)

Reference: pages 36-37 (section 2.1.2.4).

"Compagnie Chargeurs Invest updated its double materiality assessment in 2025 based on a fully integrated method between the Steering Department and the Sustainability Department... The Audit Committee, on behalf of the Board of Directors, reviewed the results of this work and issued recommendations."

Control layers for data integrity (page 37):

• "a digital reporting platform that incorporates the regulatory requirements of the CSRD. This platform details the regulatory data points";
• "a data-validation structure that follows an internal Group procedure";
• "controls and verifications performed by the Statutory Auditors" (conclusion in section 2.8, the sustainability data certification report - limited assurance, no material errors/omissions/inconsistencies identified).

"Beginning in 2026, a specific control relating to sustainability issues will be incorporated into the Group's internal control framework, enabling the business lines to ensure the completeness and integrity of the data reported by their operating subsidiaries, particularly when those subsidiaries have recently joined the Group.

Strategy, business model and value chain

Reference: pages 37-38 (section 2.1.3.1).

Following "the successful takeover bid conducted by Groupe Familial Fribourg and its partners in 2024," the Group "embarked in 2025 on a new strategic trajectory that refocuses its business model around three priority and competitive sectors of activity": Culture & Education (Museum Studio), Fashion & Know-how (Chargeurs PCC, Senfa Cilander, Luxury Fibers, Personal Goods) and Innovative Materials (Novacel). The outlook section separately notes the Group's disposal of Novacel, completed after the 2025 close.

Key figures (page 38): total employees 2,262 (France 630, Europe excl. France 670, outside Europe 962); total turnover EUR 713.4 million (EUR 419.7 million without Novacel); "No other significant ESRS sector identified"; "No activity in this sector" for fossil-fuel involvement (SBM-1_09).

The value chain table links upstream raw materials/semi-finished products, core activities (investment management, design, manufacturing, cultural venue management) and downstream marketing/use/end-of-life to the Group's CSR objectives (climate, biodiversity, supplier management, health & safety, pollution, water, circular economy, customer satisfaction).

Stakeholder interests and methods of dialog (SBM-2)

Reference: pages 39-40 (section 2.1.3.2).

"During 2025, Compagnie Chargeurs Invest conducted formal, structured interviews with 23 internal stakeholders within the business lines to update the Group's double materiality assessment."

Seven stakeholder categories are mapped with expectations and dialog channels: employees (Group Works Council, annual interviews, social surveys, alert mechanism); customers/consumers (satisfaction surveys, retail websites); shareholders/financial partners/rating agencies (Board meetings, AGM, site visits); suppliers/subcontractors (CSR performance assessments, alert mechanism); civil society/local communities (partnership with local associations); public authorities (technical meetings); financial community (analyst meetings, rating questionnaires); and professional associations/schools (sponsorships, the Chargeurs Philanthropies Foundation).

The prior year's assessment included "an extensive consultation of external stakeholders... including with clients and suppliers"; 2025 relied on internal interviews plus a documentary review.

Material impacts, risks and opportunities (SBM-3)

Reference: pages 40-42 (section 2.1.3.3).

"The double materiality assessment updated in 2025... identified the following 12 families of sub-issues as material," covering "all ten CSRD topical standards" (page 43).

Environment: Climate change (GHG-emission and climate-event impacts; financing/differentiation opportunities); Pollution (health/air-water-soil impacts); Water (withdrawal-capacity impact); Biodiversity (land-footprint impacts); Circular economy (resource-pressure/waste impacts; eco-design opportunity, the one issue "for which the Group is able to estimate the associated positive financial impact with precision").

Social: own and value-chain employees (health, equal treatment, skills/retention); affected communities (job creation); customers/end-users (quality, retention, sustainability contribution).

Governance: Business ethics (corporate culture, corruption prevention, lobbying as positive impacts; payment terms as a negative-potential impact); cybersecurity (entity-specific: data-theft/ransom impact).

Less-material sub-themes (whistle-blower protection, broader animal welfare, some human-rights sub-categories) and 2024-2025 reassessments are detailed in section 2.1.4.2.

Methodology for assessing issues (IRO-1)

Reference: pages 42-45 (section 2.1.4).

"Based on the 10 CSRD topical standards, 37 sub-themes were identified. In addition, 43 other financial and operational issues were also assessed using the same methodology... for regulatory-compliance reasons [internal control, Chapter 3]."

Three phases: (1) issues/rating frameworks - severity (scale, scope, irremediability) per ESRS 1, probability on a four-step scale, normalized on a 0.95-4 scale, threshold 1.7, set by the CSR Department; (2) stakeholder consultation - a five-sector documentary review plus 23 internal interviews in 2025 (external stakeholders were consulted extensively the prior year); (3) rating of impact and financial materiality, weighted by the Risk Committee and CSR Department.

Boundary: "themes, sub-themes and sub-sub-themes have been identified at the level of the Group's operations, in the upstream value chain within Tier 1 suppliers, or even 2 for Luxury Fibers, and in the downstream value chain up to Tier 1."

2025 reassessments: whistle-blower protection, broader animal welfare and some human-rights sub-categories moved to less-material; affected-communities' economic/social/cultural rights and two consumer sub-themes moved to more-material, driven by Museum/Culture growth and technical-textile traceability demand (section 2.1.4.2).

Company sustainability statement (IRO-2)

Reference: page 45 (section 2.1.4.3), cross-referencing section 2.7 "Cross reference table" (pages 108-110) and section 2.5 "Data from other legislative acts" (pages 94-96).

Section 2.7 is the company's ESRS content index: topic by topic, it lists every disclosure requirement addressed with a page reference, covering ESRS 2 and all ten topical standards (E1-E5, S1-S4, G1). Five DRs used elsewhere in the ESRS universe are not listed there: E1-8 (page 56: "not yet reported"/"will be covered in 2026"), E1-9 (partially covered via the page 47-48 physical-risk tables, remaining datapoints "Planned for year 2"/"Under review" per the Appendix B table, page 95), and E2-6, E5-6, G1-6, for which no index entry or declared reason was found.

Section 2.5 separately lists mandatory datapoints derived from SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law, with page references or "Not applicable"/"Non-material"/"Planned for year 2" markers; phase-in position is carried via "Quick Fix" delegated-act references in the page-106/107 methodological note.

Transition Plan (E1-1)

Reference: pages 48-51 (section 2.2.1.2-2.2.1.3).

Climate ambition for 2030 rests on "three pillars aligned with regulatory expectations": mitigation, adaptation and energy-consumption optimization. "Compagnie Chargeurs Invest is aligned with the ambition of reducing CO2 emissions inspired by the scientific principles of the SBTi Well-below 2 deg.C method." Net Zero by 2050; 2030 targets (2022 baseline): -42% Scope 1&2, -25% Scope 3. The waterfall chart runs a 2022 base of 490,262 tCO2eq down 26% to a 2030 reference of 360,509.

Candour on feasibility: identified levers "can achieve a maximum reduction of 10% to 13% by this horizon... almost half of the trajectory's target for 2030, excluding growth and acquisitions."

Resources: "not available to date and will be presented next year." Locked-in emissions "were not subject to a 2025 calculation." Transition-risk financial analysis "is planning an additional analytical component... within two years." The plan (defined summer 2024) is due for a 2026 redesign to integrate business lines whose Scope 3 is still on a limited perimeter.

Policies (E1-2)

Reference: page 45, 49 (section 2.2, 2.2.1.2); page 60 (section 2.2.1.1 cross-reference).

Climate policy sits within the Group's single Environmental Policy, which frames action on climate transition and adaptation together with pollution, water, biodiversity and circular economy. The policy identifies three climate-issue categories the Group manages: transition issues (decarbonization-driven regulatory/technological/market change and asset-value effects), physical risk (losses/damage to assets and value chains from weather hazards) and liability/reputational risk (stakeholder expectations, litigation exposure).

No standalone internal-carbon-pricing policy or dedicated adaptation policy document is separately named; policy content is carried through the Environmental Policy and operationalized via the transition plan (E1-1) and the site-level climate-risk assessment programme (E1-2-ScenarioAnalysis).

Identification of climate-related risks and scenario analysis

Back-filled from section 2.2.1.1 "Issue for the Group" (pages 47-48). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk (reported): an independent consulting firm's assessment, launched 2024, now covers 60 Group sites. Projections for 2030/2040/2050 use three IPCC scenarios: "orderly" (SSP1-2.6), "disorderly" (SSP2-4.5) and high-emissions (SSP5-8.5), on 70 years of climate data and CMIP6 model data. Top 2024-2025 hazards: severe storms (26% of sites at severe risk) and extreme precipitation (21%). In 2025 the assessment extended to 57 of 69 strategic/critical supplier sites, led by river flooding and storms.

Transition-risk scenario analysis - explicit gap: transition-risk analysis (cost, asset value, competitiveness, financing) "is planning an additional analytical component... within two years" (page 49); no named 1.5 deg.C-aligned scenario (e.g. IEA NZE) or temperature projection is disclosed. Resilience-to-transition-risk analysis is a 2026 objective, not yet performed.

Resilience in relation to climate change

Back-filled from section 2.2.1.5 (pages 53-54) and the 2026-objectives list (page 49). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No formal ESRS-defined resilience analysis for financial transition risk is complete: it is listed as a 2026 objective, not a finished exercise.

Capacity to adjust (site-level): Argentina/Brazil workplace-heat mitigation (ventilation, shading); Chargeurs PCC's Lainiere de Picardie site added fire-water storage (to 1,200 m3) and air-conditioned workshops; Novacel's European plants' business-continuity procedures for extreme climatic/geological events "were tested in 2025." The 2030 ambition includes "the first sustainable water management plans for the priority production sites."

Monitored metric: percentage of production sites with a climate-risk action plan stood at 31% in 2025 (25% without Novacel) against a "TBD" 2030 target (page 54).

Mitigation and adaptation actions - 2025 Focus (E1-3)

Reference: pages 50-51 (mitigation) and 53-54 (adaptation).

Mitigation: new carbon-footprint procedure shifting from centralized to business-line ownership; updated Purchases-perimeter footprint for Chargeurs PCC, Luxury Fibers and Novacel plus a first full Museum Studio footprint; on-site renewable-energy investment favored over GOs/PPAs ("cannot demonstrate their contribution to the decarbonization of local networks"); target that "at least 30% of the Group's key suppliers... align with a GHG-emission-reduction target."

Business-line examples: Chargeurs PCC hired a dedicated carbon engineer and replaced a 10-ton boiler with a 5-ton unit; Brazil signed a new natural-gas agreement ("estimated 15-20% reduction in CO2 emissions"); Novacel's OXYGEN range volumes grew 92%; Cambridge Satchel cut electricity 65% via lighting modernization.

Adaptation: the 2025 supplier-site risk assessment (~50 companies) found river flooding, storms and heatwaves (one-third of facilities, notably the Indian subcontinent) as top hazards; site actions include Argentina/Brazil heat-mitigation works and Chargeurs PCC's expanded fire-water storage.

Metrics and targets (E1.4)

Reference: pages 52-53 (section 2.2.1.4); page 54 (adaptation metric).

2030 targets (2022 baseline): Scope 1&2 emissions -42%; Scope 3 emissions -25%; (total emissions implied -26%, per the transition-plan waterfall).

2025 performance: Scope 1&2 41,186 tCO2eq (2024: 41,029) - "falling short of the internal target of -11%" against the Group's internal 2025 milestone; Scope 3 399,523 tCO2eq (2024: 440,353), "a reduction exceeding the internal target of -7%"; total 440,709 tCO2eq, "surpassing the internal target of -7%" with an overall -10% decrease versus 2022. Without Novacel: Scope1&2 14,782 / Scope3 254,920 / total 269,702 tCO2eq.

Supplier-engagement indicator: "Strategic suppliers committed to climate action" at 14% in 2025 (2024: 4%) against a 2030 target of 30% (calculated excluding Museum Studio and Personal Goods).

Adaptation metric: percentage of production sites with a climate-risk action plan, 31% in 2025 against a "TBD" 2030 target (page 54).

Metrics related to energy consumption and the energy mix (E1-5)

Reference: pages 54-55 (section 2.2.1.7).

Energy intensity: 261 MWh/EUR million net revenue in 2025 (2024: 265). Nuclear-source consumption: "Not available." By-business-unit energy-mix chart shows Chargeurs PCC and Novacel as the largest consumers (117 and 116 GWh respectively), with natural gas (186 GWh) and grid electricity (186 GWh) the two largest sources.

Gross greenhouse-gas emissions (E1-6)

Reference: pages 45-47, 55-56 (sections 2.2.1.1, 2.2.1.8).

Scope 3 breakdown (2025, tCO2eq): purchased goods & services 354,999 (2024: 397,967); capital goods 230; fuel/energy-related 7,508; upstream transport 7,518; waste 3,385; business travel 2,369; employee commuting n/a for Group total; downstream transport 20,000; investments 3,908.

Drivers: Scope 1 +4% vs 2024 ("more rigorous consolidation of petroleum-fuel consumption"); Scope 2 location-based -8% (China/Sri Lanka/Argentina production declines, Novacel Cranbury closure December 31, 2025); Scope 3 -9% despite perimeter expansion (Museum Studio, Senfa Cilander, Cambridge Satchel additions), "partly explained by actual emission reductions... particularly at Novacel and Chargeurs PCC." Intensity: 618 tCO2eq/EUR million (location-based, 2025) versus 660 in 2024. First-time market-based Scope 2 calculation in 2025 using guarantees of origin (UK), supplier-specific factors (France/US/Italy) and a partial Italian GO.

Other metrics not yet reported (E1.7)

Reference: page 56.

"To date, the Group has not implemented greenhouse-gas absorption projects financed through carbon credits (E1.7)." This nil disclosure is listed in the cross-reference table (section 2.7) as covered. Biogenic/removal-related activity is not otherwise described in the climate chapter.

The Group's challenge and ambitions (2.2.2.1)

Reference: page 57.

Pollution is covered by the single Group Environmental Policy, "which applies to all the Group's activities and aims to prevent, reduce and manage environmental impacts, particularly regarding air, water and soil pollution." Own-activity pollutants named: "volatile organic compounds (VOCs), powders, oils, carbon, carbon dioxide, carbon monoxide and sulfur, toxic chemical additives (related to plastic granules), chrome (related to tanned leather)." Upstream/downstream exposure: "accidental spillage of products at suppliers, microplastics released into the air by synthetic textiles during washing... plastic process film waste."

2030 ambition: "Reduce, or even eliminate if possible, hazardous substances, through an eco-design approach... Limit emissions and prevent environmental incidents... Commit to a process of continuous improvement... through ISO 14001 certification."

2026 objective: "Strengthen the monitoring of substances of concern through Group-level reporting as required by the CSRD. Discussions with the business lines are still underway to define a reduction target, given the technological constraints."

Chargeurs PCC operates under a business-line Restricted Substances List (RSL) aligned with REACH and ZDHC, developed with TUV SUD and the Hohenstein laboratory.

Actions implemented - Focus 2025 (2.2.2.2)

Reference: pages 57-58.

Chargeurs PCC: RSL testing covers PFAS, bisphenol and formaldehyde; "to date, the results are particularly strong, with no PFAS detected either in finished products or in wastewater." Site actions: Argentina replaced formaldehyde-heavy resins and fluorinated formulations, and reduced antimony-type substances with two suppliers under ZDHC; China achieved "a 97% increase and an achievement rate of 85% at ZDHC level 3" in chemical-compliance optimization.

Senfa Cilander: developed a PFAS-free product range in 2025 and has "long developed bromine-free and antimony-free solutions." A 2024-2025 environmental audit of the area around the Luetzelfluh (Switzerland) site addressed historical contamination.

Novacel: commissioned a VOC incinerator at its French site in 2025; Group-wide VOC emissions rose 11.4% at Novacel sites, attributed to "lower performance of the activated-carbon beds" and a transitional treatment phase during RTO installation.

Group-level: centralized reporting on the Group's digital platform for "the most hazardous substances," and continued HSE/R&D work on CMR (Carcinogenic, Mutagenic, Reprotoxic) substance management.

Metrics and targets (2.2.2.3)

Reference: page 58.

No quantified numerical target is set for substances of concern/SVHC: the 2030 key-performance-indicator table lists both "Substances of concern purchased for production" and "Substances of very high concern purchased for production" against a "TBD" target, and the 2026 objective states discussions "are still underway to define a reduction target, given the technological constraints that clearly exist in certain sectors."

The qualitative objective is stated instead: "Reduce, or even eliminate if possible, hazardous substances, through an eco-design approach... using solvent-free processes where possible," alongside a commitment to ISO 14001 certification as the continuous-improvement vehicle.

Metrics and targets - monitoring indicators (2.2.2.3)

Reference: page 58.

The 2025 VOC increase is "mainly due to the increase in production, particularly for Novacel"; water-pollutant reporting changed methodology in 2025 (direct bulk reporting), limiting 2024 comparability. "The Group has no measurement tools to separate Non-Methane Volatile Organic Compounds (NMVOCs) from methane emissions"; microplastic-release data is "not available, due to a lack of methodology," though operational teams estimate the discharges as small.

Metrics and targets (2.2.2.3)

Reference: page 58.

Substances of concern purchased for production: 317,697 kg in 2025 (2024: not available; without Novacel: negligible). Substances of very high concern (SVHC) purchased: 13,149 kg in 2025. Substances of concern present in sold products: 12,552 kg (2024: not available); SVHC present in sold products: 13,149 kg.

These figures sit alongside the pollution monitoring indicators (VOC, TSS, COD) in the same table and are explicitly described as Group-level metrics newly disclosed under the CSRD framework ("the scope used for the metrics concerning substances of concern... for the first publication of these metrics" is flagged as an auditor observation, page 112-113).

The Group's challenge and ambitions (2.2.3.1)

Reference: pages 58-59.

Water is covered by the Group's Environmental Policy, "which recognizes sustainable water-resource management as a priority issue and aims to reduce freshwater withdrawals, particularly in areas exposed to water stress, as well as to prevent pollution linked to industrial activities." The Group applies the LEAP method (Locate, Evaluate, Assess, Prepare) recommended by TNFD and the CSRD.

Methodology uses the WRI Aqueduct database: each geolocated site receives an "Overall Water Risk" score (13 indicators) and, new in 2025, a baseline water-stress indicator, which "leads to the inclusion of two additional production sites within the scope of sites considered exposed to a significant water-related risk." "At this stage, the Group has not implemented a structured approach to consulting local communities at Group level as part of the analysis of water-related issues," though Luxury Fibers runs occasional local initiatives.

2030 ambition: reduce withdrawal "from the eco-design of its products and services to the optimization of its industrial processes"; 2026 objectives include establishing "the first sustainable water management plans for the priority production sites.

Actions implemented - Focus 2025 (2.2.3.2)

Reference: pages 59-60.

2025 actions: a roadmap through 2030 (less water-intensive R&D, prioritizing withdrawal reduction in high-risk areas, rainwater harvesting, recycled-water sourcing, closed-loop cooling); internal water-risk assessment extended to key suppliers using the WRI database; risk analysis extended to high-water-stress areas beyond the overall-risk score.

Business-line examples: Novacel's Italian site "reduced its water-withdrawal ratio per million m2 produced by 39% between 2020 and 2023"; Chargeurs PCC's Zero Water Dye range ("saves up to 2,600 liters of water for every 1,000 linear meters") and Argentina cooling-water reuse (-20% consumption); Luxury Fibers' NATIVA Regen Cotton program introduced new irrigation systems on 10 Greek farms; Senfa Cilander maintains a groundwater-decontamination system since 2006 for historical tetrachloroethylene/trichloroethylene contamination, with a September 2024 PFAS test on Selestat drinking water showing 0.004 ug/L against a 20 ug/L limit; Novacel's Deville site saved 1,280 m3 of groundwater via a steam-recovery installation.

Metrics and target (2.2.3.3)

Reference: pages 60-61.

"Quantity of water withdrawn" target: -30% by 2030 versus 2022. 2025 actual: 375,380 m3 (2024: 370,557; without Novacel: 228,175), i.e. moving away from, not toward, the target in the headline year. The 2022 baseline figure and intermediate milestones are carried in the Group Priorities table (page 39).

Metrics and target (2.2.3.3)

Reference: pages 60-61.

Recycled/reused water withdrawals: 0 m3 in 2024, 81 m3 in 2025 (0 without Novacel). Water intensity rose to 287 m3/EUR million (2024: 276). A footnote flags that the 2024 water-risk-area figure "was modified to include water withdrawals from areas exposed to high water stress, in accordance with CSRD requirements," limiting year-on-year comparability.

E3-5 is listed in the section 2.7 cross-reference table with a page-107 reference, which points to the methodological note's "Reasons for non-inclusion of certain ESRS data points" table (pages 106-107) rather than to a standalone financial-effects narrative. No monetary figure for anticipated financial effects from water-related risks or opportunities is given in the Water Resources chapter itself (section 2.2.3, pages 58-61); that chapter covers exposure scoring (WRI Aqueduct), withdrawal volumes and a qualitative 2030 ambition, but stops short of quantifying financial impact. The page-106/107 table lists several E3 sub-datapoints (E3-1_09, E3-3_02, E3-3_08, E3-4_05) alongside a bare "E3-5" entry, whose exact stated reason did not extract legibly from the source PDF's table layout - a human should verify this against the original page 106-107 before treating the reason as settled.

The Group's challenge and ambitions / transition (2.2.4.1)

Reference: pages 61-63.

The Group applies the LEAP method to biodiversity, mindful of "the five recognized drivers of biodiversity loss: habitat fragmentation, overconsumption of resources, climate change, pollution and invasive species." In 2024 it assessed biodiversity-risk exposure for 18 production sites: 0 "very sensitive" (inside a protected area), 14 "sensitive" (within 5 km of one) and 4 "not very sensitive," using the WDPA and EUNIS databases with a non-profit partner, LaCEN.

2030 ambition (four action areas): continue reducing hazardous substances; minimize emissions/prevent accidents; reduce freshwater consumption under stress; protect biodiversity through structured site action plans. 2026 objectives: continue monitoring-indicator improvement, raise team awareness, and extend local action plans to sites nearest protected areas.

No quantified CapEx/OpEx transition-plan figure for biodiversity is given; "to date, we have not yet calculated" the French Climate and Resilience Law's Permeable Surface Ratio and Biotope Area Factor indicators, which "could enable business lines to set quantified objectives.

The Group's challenge and ambitions (2.2.4.1)

Reference: page 61.

Biodiversity policy is carried by the Group's Environmental Policy ("through its Environmental Policy, the Group seeks, as far as possible, to take into account the five recognized drivers of biodiversity loss") and, at the business-line level, Luxury Fibers' NATIVA certification, which "guarantees that both farms and industrial partners manage natural resources responsibly." Personal Goods' leather sourcing policy requires 100% Leather Working Group (LWG)-certified partners at Silver or Gold level.

Actions implemented - Focus 2025 (2.2.4.2)

Reference: pages 62-64.

2025 Group actions: a cartographic visualization of site-level water/biodiversity physical-risk for teams, and an inventory of Group biodiversity initiatives.

Business-line examples: Senfa Cilander's Swiss plant sits near a river habitat for a protected beaver population that the site "ensures the protection and preservation of"; Chargeurs PCC's Lainiere de Picardie site keeps about three-quarters of its land undeveloped, with regular stream phosphate monitoring, and international sites added vegetation (Bangladesh rooftop garden, Brazil tree planting, Argentina treated-effluent irrigation of green areas); Luxury Fibers' NATIVA farms are scored on an Ecosystem Integrity Index (vegetation, species diversity, soil, riparian-zone condition); Novacel's Deville site maintains watercourse-protection practices and, since 2021, has funded anti-waste nets on the Seine.

Metrics and target (2.2.4.3)

Reference: page 64.

Target: 50% of (very) sensitive sites with a protection and/or renaturing plan by 2030. 2025 actual: 29% (38% without Novacel). This single KPI is the only quantified biodiversity target in the statement; it sits alongside the qualitative 2030 ambition (four action areas, section 2.2.4.1) and the as-yet-uncalculated Permeable Surface Ratio and Biotope Area Factor indicators noted under E4-1, which the Group says "could enable business lines to set quantified objectives" once available.

Metrics (2.2.4.3)

Reference: pages 61-64.

Site-sensitivity screening (18 sites, 2024): 0 very sensitive, 14 sensitive, 4 not very sensitive (2.2.4.1).

Surface-area metrics (m2, 2025, not available for 2024): built area of production sites 181,533 (107,340 without Novacel); permeable surface 205,239 (34,375); built area in biodiversity-risk areas 138,489 (64,295); permeable surface in biodiversity-risk areas 171,864 (1,000); uncategorized surface in biodiversity-risk areas 199,151 (34,349); additional constructed space completed/planned 11,000 (2,000).

E4-6 is listed in the section 2.7 cross-reference table with a page-107 reference, pointing to the methodological note's "Reasons for non-inclusion of certain ESRS data points" table (pages 106-107) rather than a standalone narrative. No monetary figure for anticipated financial effects from biodiversity-related risks or opportunities appears in the Biodiversity and Ecosystems chapter itself (section 2.2.4, pages 61-64), which covers site-sensitivity scoring, actions and the protection-plan target but does not quantify financial impact. The qualitative framing given is that biodiversity is "both a source of value-creation opportunity... and also a source of risks, notably those relating to the price and availability of raw materials, and to regulatory compliance" (page 62), without a figure attached.

The Group's challenge and ambitions (2.2.5.1)

Reference: page 65.

Circular-economy matters are governed by the Group's Environmental Policy ("sets common principles applicable to all entities and business lines in terms of preservation of resources, control of environmental impacts and continuous improvement of industrial practices") and the Responsible Purchasing Charter ("provides a framework for relations with suppliers and helps to limit the impacts of raw materials, substances used and waste management").

Two priority ambitions: "an increasing eco-design of the products or services placed on the market" (materials optimization, energy efficiency, repairability/recyclability) and "a responsible sourcing approach demonstrated through ongoing dialogue with strategic suppliers.

Actions implemented - Focus 2025 (2.2.5.2)

Reference: pages 65-69.

2025 actions: strengthened R&D collaboration on hazardous chemicals; new eco-designed solutions (e.g. at Senfa Cilander); a responsible-purchasing working group linking the Responsible Purchasing Charter to targeted climate actions.

Detailed eco-design product table (pages 65-67) lists more than 20 "more sustainable" ranges across business lines, e.g.: Novacel's OXYGEN Lean (-20% plastic, patented process), OXYGEN Recycled (25% mechanically recycled PE, Plastica Seconda Vita certified), OXYGEN Vegetal+ (>80% plant-based PE); Chargeurs PCC's Sustainable 360(TM) (5% recycled polyester, GRS) and mass-dyed yarn (>80% water savings); Personal Goods' BCI cotton (-50% synthetic fertilizers) and organic cotton (100%, GOTS); Senfa Cilander's Alterra/Altimis/Theater R ranges (100% recycled-bottle polyester, Ecoprofile) and PFAS-free Galaxy/Shiryu/Backdrop lines.

Luxury Fibers: Lanas Trinidad (Uruguay) runs 22 treatment lagoons, reuses wool-washing impurities as fertilizer, and reports a Water Circularity Index of ~90% (2 l/kg wool consumed versus a traditional ~20 l/kg). 314 farms are NATIVA-certified, 109 in the NATIVA Regen program. Personal Goods prohibits landfilling of leather waste at Fournival Altesse and donated 10 tonnes of wood shavings to a local farmer as soil amendment in 2025.

Metrics and targets (2.2.5.3)

Reference: page 69.

"In 2024, despite a more stringent definition of the Group, 49.2% of [Novacel's] business-line revenue consisted of ranges vastly improved in one or more aspects of sustainability," and OXYGEN-range sales grew to 17.9 million m2 in 2025 from 9.3 million in 2024.

E5-4 is listed in the section 2.7 cross-reference table with a page-107 reference, pointing to the methodological note's "Reasons for non-inclusion of certain ESRS data points" table (pages 106-107) rather than an aggregate Group-level figure. No consolidated weight/volume of raw materials used, nor a recycled-content percentage at Group level, was found in the Resources and Circular Economy chapter (section 2.2.5, pages 65-70): the chapter instead reports recycled-content rates per individual product range (e.g. Novacel OXYGEN Recycled at 25%, Chargeurs PCC Sustainable 360 at 5%) rather than a single inflow total. "At this stage, the share of recyclable content in products and their packaging is not available at the Group consolidated level, due to the heterogeneity of the activities and scopes covered" (page 70) - a related, explicit nil-statement that supports the index placement without itself being an E5-4 figure.

Resource outflows (2.2.5 narrative)

Reference: page 69-70.

Novacel's eco-design ranges (OXYGEN family) reduce material outflow intensity per unit sold; Chargeurs PCC's Zero Water Dye and mass-dyeing technologies reduce process outflows. "The share of recyclable content in products and their packaging is not available at the Group consolidated level, due to the heterogeneity of the activities and scopes covered" (page 70). The waste-generation and recovery figures that make up the quantified outflow picture are reported under the dedicated Waste metric (E5-5-Waste).

Metrics and targets - waste tables (2.2.5.3)

Reference: page 70.

Percentage of waste recycled: 59% in 2025 (2024: 59%; without Novacel: 39%), against the 50% 2030 target reported under E5-3.

Own workforce section (2.3.1)

Reference: page 78.

Workforce policy is anchored in the Code of Conduct (distributed at hiring, covers whistleblowing procedure - see G1-1) and, for diversity, a newly published Diversity and Inclusion Policy, communicated to HR Directors in 2025 with training pathways identified for non-discrimination issues, targeting recruitment teams, managers and HR teams across hiring, skills development, promotion and job rotation.

Social dialogue (2.3.1.2)

Reference: pages 78-79.

"The Group also conducts internal social surveys within the business lines, such as Great Place To Work or Zest, which allow employees to be consulted on their perceived level of trust according to five criteria: credibility, respect, fairness, pride and camaraderie." A new survey was run in 2025 across Museum Studio and Chargeurs PCC. The Group Works Council provides formal social-partner dialogue, with employee-elected directors feeding into Board-level engagement (see GOV-1).

Ethics whistleblowing system

Reference: page 78.

"The process for collecting and handling reports enables employees to report behavior that does not comply with applicable rules... The mechanism is open to all employees and stakeholders." Reports go via a dedicated email (alertes@chargeurs.com) to the Chief Compliance Officer; whistleblowers "receive an acknowledgment," benefit from CCO-guaranteed protection during processing, and investigations may involve internal auditors (fraud/embezzlement) or HR managers (harassment) or neutral third parties. "During the 2025 fiscal year, the Group was not convicted or fined for corruption or the payment of bribes.

Occupational health and safety (S1-4_08 and S1-14)

Reference: pages 78-79.

"Despite the mobilization of its teams and Management, the Group saw its lost-time accident frequency rate rise again in 2025, exceeding the target set." An annual Safety Day ran at all sites (1,203 participants, 2,197 training hours in 2025); the HSE department runs safety-behavior audits and site inspections with CSSCT members; 1,337 on-site safety inspections and 79 near-miss incidents were recorded in 2025. "A specific action plan is already underway at the LPBC site," following an analysis finding most accidents were hand injuries, leading to a targeted safety reminder on chemical hazards and glove use. "Accountability must clearly be strengthened within the Divisions.

Metrics and targets (2.3.1.3)

Reference: pages 38-39, 83-84.

A gender-equality target is also set: "the Group has set a quantified target to increase the proportion of women within the workforce" (S1-9), illustrated by Executive Committee composition changes (URD section 4.3.1).

Characteristics of the workforce (2.3.1.3)

Reference: pages 84-85.

By region (2025): France 632, Asia/Africa/Oceania 593, Americas 379 (of which Argentina 57, Bangladesh 90, China 241, Great Britain 261, Hong Kong 96, Italy 285, USA 250). By business line: Headquarters 42, Chargeurs PCC 903, Museum Studio 365, Luxury Fibers 27, Personal Goods 167, Senfa Cilander 74. Payroll costs: EUR 148.2 million in 2025 (2024: EUR 144.2m).

Non-employee workforce tracking

Reference: page 79 (section 2.3.1.2); page 107 (cross-reference).

"The Group began tracking indicators related to non-employees in 2025 (fatalities, accidents with or without lost-time, lost days, occupational illnesses), for a publication from the 2026 fiscal year. Non-employees include temporary workers and contractors active over a 12-month period on behalf of Group entities." No 2025 figures are therefore published for this metric; the statement is explicit that collection started this year and disclosure is deferred one year.

Social dialogue

Reference: pages 78-79, 86.

Formal dialogue runs through the Group Works Council, employee-elected Board directors, and the Health, Safety and Working Conditions Committee (CSSCT), which organizes site inspections ahead of dedicated meetings. "Percentage of employees covered by social protection (including coverage provided through agreements and collective bargaining arrangements)" stood at 96% in 2025 (98% with Novacel).

Diversity, Equal Treatment (S1-5, S1-9, S1-10, S1-11, S1-12)

Reference: pages 79, 86.

"With regard to gender equality in the workplace (S1-9), the Group has set a quantified target to increase the proportion of women within the workforce."

2025 figures: percentage of women 39% (2024: 36%; 2023: 35%; without Novacel: 45%); percentage of women in management positions 28% (2024: 36%; without Novacel: 38%); percentage of women among the top 50 executives 9% (2024: 7%). Age breakdown (2025): under 30 - 241 employees (192 without Novacel); 30-50 - 1,220 (882); over 50 - 794 (484). Share of employees with disabilities (France scope): 5.33% in 2025 versus 5.03% in 2024 (the body text) / 4% Group-wide per the metrics table (3% without Novacel).

Equal treatment (Adequate wages)

Reference: page 79.

"Local HR teams pay close attention to ensuring that base salaries (S1-10) are higher than local minimums in every country." A survey against the Anker living-wage methodology "revealed that the vast majority of employees were paid above the minimum wages," with exceptions identified in Sri Lanka and Bangladesh: "the few cases identified... are taken into account and that a remediation plan is defined." For Sri Lanka, a plant-closure project is under way; for Bangladesh, CPCC's HR department is to reassess and share a 2026 action plan. "The workforce in Sri Lanka and Bangladesh potentially below the threshold is estimated at 4.10% of the Group's workforce."

Equal treatment (Social protection)

Reference: page 79, 86.

"Through its collective agreements and conventions, the Group's employees are covered by social protection (S1-11) against loss of income due to major life events (e.g., illness, workplace accident, family leave)." All employees also get International SOS coverage for business travel. A 2025 audit with broker DIOT SIACI reviewed health/welfare coverage in the USA, Hong Kong and Italy (alongside France, already well understood, which is 56% of the workforce), finding "a very high level of social coverage in these areas." Coverage metric: 96% in 2025 (98% with Novacel; exclusions: 42 male Personal Goods UK employees for parental leave, and 1 part-time Chargeurs PCC Thailand employee for retirement).

Equal treatment (Disability)

Reference: page 79.

"With regard to disability-related initiatives (S1-12), local efforts are being made to improve accessibility at the Group's sites and to develop tailored support for affected employees, particularly through workplace accommodations. In France, in 2025, 5.33% of the workforce comprised people with disabilities (vs. 5.03% in 2024)." The Group-wide metrics table (page 86) shows a broader 4% for 2025 (3% without Novacel), reflecting a France-only versus Group-wide scope difference the statement does not fully reconcile.

Training (S1-13)

Reference: pages 79-80.

"More than 32,136 training hours (vs. 32,540 in 2024) were delivered... Employees averaged 14.21 hours of training in 2025 (vs. 14.8 hours in 2024)." By gender: women averaged 13.92 hours, men 14.38 hours.

2025 flagship programmes: two AI webinars (150+ live participants) plus an internal AI assistant and a responsible-AI-use charter; six anti-corruption training sessions with partner Lamy (63 participants); three Board members trained on CSR (June/October 2025); two Carbone 4 training days on carbon-footprint measurement and purchasing decarbonization (27 employees).

Health and Safety (2.3.1.3)

Reference: pages 84-85.

"There were no fatalities at Group level; the number of lost-time accidents stood at 40, compared with 20 in 2024. This sharp increase calls for decisive action." Absenteeism hours fell to 122,687 (2024: 143,735).

Work-life balance

Reference: page 79.

Not yet tracked at Group level: "the number of employees who have taken family leave will be recorded in 2026." The statement otherwise addresses parental-leave coverage qualitatively within social-protection disclosures (S1-11), including an exclusion for 42 male Personal Goods UK employees from the parental-leave scope of the coverage metric.

Diversity, Equal Treatment (gender pay gap)

Reference: page 86.

Gender pay gap: 9% in 2025 (2024: 7%), "difference calculated on the basis of employees' contractual salaries in France, excluding the entity Fournival Altesse." This is flagged by the statutory auditors as one of the metrics given "for the first publication... " this fiscal year (page 112-113 observation), i.e. a new Group-level disclosure with limited prior-year comparability.

Human rights alerts (2.3.1.3)

Reference: page 86.

The statement confirms: "During the 2025 fiscal year, the Group did not record any confirmed serious human rights incidents."

Workers in the value chain (2.3.2.1-2.3.2.2)

Reference: pages 86-87.

Policy coverage comes through the Responsible Purchasing Charter (signed by more than 300 suppliers in 2023-2024, strengthened in 2024), adherence to the UN Global Compact, the Code of Conduct, and the annual Modern Slavery Statement published on the Group's website. "Human rights are a major issue in the textile sector, particularly in Asia, where recurring controversies and studies by the International Labour Organization highlight a high level of risk.

Actions implemented - Focus 2025 (2.3.2.2)

Reference: page 87.

Engagement runs through "a performance-assessment and monitoring system focused on working conditions (with an emphasis on health and safety)," Sedex-standard supplier audits (Chargeurs PCC), NATIVA independent third-party audits (Control Union, ICEA) covering worker housing, food provision and chemical-handling procedures, and Novacel's EcoVadis-based supplier evaluations covering Human Rights and Working Conditions as one of four pillars. "Ongoing dialog with relevant stakeholders, such as specialized financial analysts (including Amundi)" is also listed as a 2026 objective.

Remediation channel

Reference: page 87.

"Any suspected violation of these rights can be reported via a dedicated email address - alertes@chargeurs.com - accessible to both internal and external stakeholders," the same channel described for own-workforce grievances (S1-3).

Specific actions of the business lines (2.3.2.2)

Reference: page 87.

Chargeurs PCC: Better Cotton Initiative member since 2019, accelerating GOTS-licensed cotton sourcing; since 2023 a dedicated resource monitors social practices in China (infrastructure renovation, canteens, dormitory modernization, biometric time-tracking, overtime-rate verification). Novacel: supplier mapping to identify highest-risk suppliers, EcoVadis assessment, and "a new internal procedure... to systematically assess supplier risk exposure and CSR strategy"; notes that "the risk of infringement of workers' rights at suppliers is generally very low" given Western Europe/US supplier concentration, but flags natural-rubber plantations as a higher-risk area for coming-months attention.

Metric and target (2.3.2.3)

Reference: page 87.

"Percentage of input procurement spend allocated to suppliers audited to the Sedex standard": 80% in both 2024 and 2025 (Chargeurs PCC scope, "25 suppliers with a reinforced qualification scope" in 2025), against a "TBD" 2030 objective.

Affected communities - challenge and ambitions (2.3.3.1)

Reference: pages 87-88.

"At this stage, issues relating to affected communities are not the subject of a dedicated Group policy or specific targets. They are taken into account in a cross-functional manner through the Group's vigilance approach and the existing policies governing its environmental and social impacts. The Group plans to structure its approach to affected communities more formally over the next two years." Pollution-related community risk is explicitly cross-referenced to the ESRS E2 chapter.

Actions implemented - Focus 2025 (2.3.3.2)

Reference: page 88.

Engagement is limited and indirect: "two members of the Compagnie Chargeurs Invest central team took part in a Global Compact France training program on Human Rights, allowing them to compare the Group's experience with that of other companies." Business-line community engagement (Museum Studio's Mohawk Institute project with Indigenous experts and survivors; Luxury Fibers' NATIVA Regen social programs) is described under S3-4 rather than through a dedicated consultation process.

Remediation channel

Reference: page 87-88 (by cross-reference to the Group's general vigilance/alert mechanism).

No community-specific grievance channel is separately described; the statement treats affected-community impacts "in a cross-functional manner through the Group's vigilance approach," which elsewhere (S1-3, S2-3) is carried by the alertes@chargeurs.com mechanism open to "internal and external stakeholders." The Group states it has not yet formalized a dedicated process for this stakeholder group and "plans to structure its approach to affected communities more formally over the next two years.

Specific actions of the business lines (2.3.3.2)

Reference: page 88.

Museum Studio: Lord Cultural Resources supported the 2025 reopening, in Canada, of the former Mohawk Institute Residential School as an International Site of Conscience, developed "in close collaboration with Indigenous experts and survivors," plus UK pro-bono work with Artbox London (adults with intellectual disabilities) and Without Shape Without Form (Middle East/North Africa/Global South artists). Luxury Fibers: the NATIVARegen(TM) social program with Gucci supports women artisans in rural Uruguay (40 new 2025 participants joining 2024's cohort); the 2025 "Raices en Lana" project trains participants in digital sales, branding and costing while preserving traditional weaving techniques.

No target is set. "At this stage, Compagnie Chargeurs Invest has not set itself any specific targets on this issue at Group level, as the actions carried out are aimed primarily at preventing adverse impacts and making a positive contribution to communities, in line with the nature of the business lines' activities" (page 88).

Consumers and end-users - challenge and ambitions (2.3.4.1)

Reference: page 89.

No dedicated consumer policy exists yet: the 2030 ambition is to "define a consumer and end-user policy addressing product and service quality, health and safety, as well as human-rights commitments." In the interim, "a strict quality policy is put in place by the business lines as of the design stage of a product or service," and the Group distinguishes two consumer categories - business users and end-users.

Actions implemented - Focus 2025 (2.3.4.2)

Reference: pages 89-90.

Engagement channels include customer satisfaction surveys, dedicated sales contacts coordinating with regional quality teams (Chargeurs PCC), Key Account Management introduced in 2025 (Senfa Cilander), and periodic commercial/R&D/CSR presentations to clients on sustainability progress. Luxury Fibers' NATIVA collaborated with 57 brands worldwide in 2025, of which 68% renewed their purchases, and periodic performance reports are shared with partner brands (76% of NATIVA Regen brands requested detailed program data for their own reporting).

Remediation and complaint handling

Reference: page 90.

"Sales teams, working closely with quality departments, monitor and analyze customer complaints and feedback, ensuring a timely and structured response" (Chargeurs PCC). At Senfa Cilander, "in the event of a non-conformity, products from the same production run are immediately blocked to prevent recurrence with other customers," with Quality and Production teams analyzing root causes. Novacel offers direct follow-up "in the event that customers encounter defects in a product.

Specific actions of the business lines (2.3.4.2)

Reference: pages 89-91.

Product quality/safety systems: Senfa Cilander is ISO 9001-certified (Switzerland) / pursuing certification (France); Luxury Fibers' NATIVA guarantees full fiber-to-consumer traceability; Personal Goods' Fournival Altesse holds the French EPV (Living Heritage Company) label; Novacel provides free material-sample recommendation services and technical/environmental data sheets for all products, and is extending individual product carbon footprints via life-cycle analysis, working since 2025 with AFERA's sector-specific carbon-footprint tool.

Metrics and targets (2.3.4.3)

Reference: page 91.

Corporate culture (G1-1)

Reference: page 92.

"Work continued on raising employee awareness of the Code of Conduct; 100% of active employees trained in the last two years." New joiners follow a course covering "the definitions and methods for identifying the various types of corruption, the internal whistleblowing procedure, the consequences associated in the event of failure to comply with the Code of Conduct." Delivery runs through "a highly structured Compliance Network" of officers and correspondents in every business line and region. The Group also runs a cyber-risk program: a secure generative-AI-use policy was adopted in 2025, alongside updated cybersecurity/personal-data-protection training.

Supplier management (G1-2)

Reference: page 92.

Since 2017 the Group has run "numerous actions with its suppliers (charter, regular audits, etc.)." In 2025 a cross-functional responsible-purchasing working group: established "an internal procedure to define metrics for monitoring supplier performance in terms of sustainability"; built "a common methodology for identifying 'strategic and critical' suppliers"; and began "setting targets to track the progress of these strategic suppliers in the area of CSR." The Responsible Purchasing Charter, updated since September 2024, has been progressively communicated to suppliers. "In every country where the Group operates, teams are required to comply with local laws regarding supplier payments, regardless of the size of the organization, especially when the supplier is a small or medium-sized business.

Prevention and detection of corruption and bribery (G1-3 and G1-4)

Reference: page 92.

2025 actions: "strengthening of internal anti-corruption control systems, in particular through the Group policy for all business lines and the implementation of tools to assess third parties (as required by the Sapin II law)." 2026 objectives include relaunching "a training campaign dedicated to the prevention of corruption, targeting as a priority those exposed to risks" and extending third-party assessment to all business lines. The Ethics Committee is informed of developments in these policies (cross-referenced to URD section 4.5, Code of Conduct and Ethics Committee).

Targets related to business conduct

This disclosure requirement is a standalone DR only from the 2025/2026 ESRS; under the 2023 ESRS the equivalent ground was covered by MDR-T. The statement is prepared under the 2023 ESRS and has no dedicated "G1-3 targets" heading.

No quantified corruption-prevention target (e.g. a numeric reduction or coverage goal) is stated. Effectiveness is instead tracked via monitoring indicators and periodic review, the other MDR-T limb: "100% of active employees trained in the last two years" on the Code of Conduct (G1-1, page 92); the rollout of third-party-assessment tools under the Sapin II law, with 2026 objectives to "extend the analysis of strategic and critical suppliers to all business lines" and relaunch targeted anti-corruption training; and the outcome metric that "during the 2025 fiscal year, the Group was not convicted or fined for corruption or the payment of bribes" (page 92).

Incidents of corruption or bribery

Reference: page 92.

"During the 2025 fiscal year, the Group was not convicted or fined for corruption or the payment of bribes." No incident count or investigation detail beyond this nil statement is disclosed for G1-4 specifically; the whistleblowing-system description (G1-1/S1-3) and Sapin II third-party-assessment tooling are presented as the Group's detection infrastructure.

Political influence and lobbying activities (G1-5)

Reference: page 92.

"In 2025, the Group continued to monitor regulatory developments and highlighted its business model and progress toward climate transition. This advocacy effort focused on its Innovative Materials platform (Novacel), which is directly affected by the phased implementation of the European Packaging and Packaging Waste Regulation (PPWR). As part of AFERA, documents were drafted and submitted to the European Commission to ensure that the specific characteristics of these products are taken into account in the reorganization of packaging classifications."

This DR is named and addressed with real content under its own "(G1-5)" heading, and SBM-3's material-issues table (page 41) explicitly lists "Lobbying (Positive - Actual)" as a material impact under Business ethics. Flag for review: G1-5 does not itself appear as a separately listed row in the section 2.7 cross-reference table (pages 108-110), which is an apparent gap in the company's own index given this clean, labeled body content.