Compagnie d'Entreprises CFE SA

The role of the administrative, management and supervisory bodies

Reference: pages 50, 53, 76 (incorporated by reference to the Corporate Governance Statement).

CFE's Table 3 ("List of ESRS2 sections found in another section of the annual report", page 76) states that information on GOV-1 "Information on administrative, management and supervisory bodies (role, composition, expertise, etc.)" is incorporated by reference to the Corporate Governance Statement.

The Company has a single-tier structure: the Board of Directors "is responsible for the general conduct of the Company's business and is accountable for its management" (page 50). The Board "determines the direction of the Company's activities, its strategy and key policies... decides on the level of risk the Company is prepared to take" and "approves the general internal control and risk management system" (page 50).

As at 31 December 2025 the Board had eight directors, including five non-executive directors and three independent directors (37.5%); four members are nominated by reference shareholder Ackermans & van Haaren and one by VINCI Construction SAS. One-third of Board members are women (page 53). The Board met six times in 2025 (page 53).

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: pages 76, 93, 108, 123 (incorporated by reference to the Corporate Governance Statement, supplemented by topical sections).

Table 3 (page 76) incorporates GOV-2 information by reference to the Corporate Governance Statement. Within the sustainability statement itself, CFE describes recurring reporting lines to governance bodies: "Changes in indicators and targets are also presented annually to the Audit Committee and the Board of Directors" for climate (page 108), and for safety, "Group strategy, including health and safety strategy, is presented at least once a year to the Audit Committee and the Board of Directors" (page 120-121).

At Executive Committee level, "every Executive Committee meeting begins with an analysis and review of accident frequency and severity rates on construction sites by the Head of Safety", and "specific safety KPIs are also presented to the Audit Committee at least once a year" (pages 93, 123). The materiality matrix revised in 2025 "was approved by the Board of Directors on 5 December 2025" (page 87).

Integration of sustainability-related performance in incentive schemes

Reference: pages 76, 93 (incorporated by reference to the Remuneration Report, supplemented by the ESG governance section).

Table 3 (page 76) incorporates GOV-3 "Integrating sustainable development performance into incentive programmes" by reference to the Remuneration Report. Within the sustainability statement, CFE states explicitly that, as part of monitoring the health and safety of staff and subcontractors (the topic selected as material by the DMA): "the variable remuneration of Executive Committee members takes safety criteria into account (severity rate, frequency rate and number of safety visits carried out)" (page 93).

The same passage records that "all members of the Executive Committee carry out at least 10 safety visits each year" and that every Executive Committee meeting "begins with an analysis and review of accident frequency and severity rates on construction sites by the Head of Safety" (page 93). No equivalent remuneration link is disclosed for the climate change mitigation targets.

Statement on due diligence

Reference: pages 77-78 (Table 5: Mapping information relating to the due diligence process).

CFE maps the core elements of due diligence against sections of the sustainability statement in Table 5 (pages 77-78):

Due diligence is integrated into the Group's existing risk management framework: "CFE's ESG governance is fully integrated into the Group's overall risk management and due diligence framework (see section 1.2 GOV-4 & 5 Risk and due diligence)... ESG risks are not managed separately or in silos, but according to the same methodology as other strategic, financial and operational risks" (page 93).

Risk management and internal controls over sustainability reporting

Reference: page 77 (section 1.2, "GOV-4 & 5 Notion of risk and due diligence").

"As stipulated in the 'Management Report' in section 1.2 'Main risks', the Executive Committee puts in place internal controls and risk management, subject to approval by the Board of Directors. This is responsible for implementing this framework taking the recommendations of the Audit Committee into account. At least once a year, the Audit Committee evaluates the internal control systems to ascertain that the main risks have been properly identified, reported and managed." (page 77)

CFE's subsidiaries manage their own operational and financial risks, which are not centralised at CFE level; "the management teams of the subsidiaries report on risk management to their respective Board of Directors" (page 77). To identify and manage sustainability risks, CFE "has carried out a double materiality assessment (DMA) of ESG risks" (page 77), repeated and detailed in the DMA chapters that follow.

Strategy, business model and value chain

Reference: pages 78-80.

CFE is "a multi-disciplinary group developing global solutions to complex societal challenges in the fast-growing markets of sustainable buildings, intelligent industries and tomorrow's energy and mobility infrastructures", combining four segments: Real Estate Development (BPI Real Estate: Belgium, Luxembourg, Poland), Multitechnics (VMA: building technologies and industrial automation; MOBIX: Rail and Utilities), Construction & Renovation (Belgium, Luxembourg, Poland, Germany) and Investments and Holdings (stakes in DEEP C Holding, Greenstor, Green Offshore, held with Ackermans & van Haaren and explicitly out of CSRD scope as CFE lacks exclusive operational control) (pages 78-79).

"The priority material issues concern, on the one hand, the reduction of greenhouse gas emissions (climate change mitigation) and, on the other hand, the health and safety of the Group's employees and workers in the value chain involved in our projects" (page 79). Strategy is expressed through the SPARC acronym (Shift, Perform, Accelerate, Return, Community). CFE had 2,681 workers at year-end 2025: 2,145 in Belgium, 223 in Luxembourg, 313 in Poland (page 79).

Interests and views of stakeholders

Reference: pages 80-86.

Key stakeholders mapped through the DMA process include employees, subcontractors/value chain workers, suppliers, clients and investors. CFE used multiple engagement channels: internal interviews with in-house ESG experts, external interviews with sector experts to validate methodology and relevance, and ongoing dialogue (page 85: "This exercise confirmed the importance of the following themes: climate change, the circular economy, health and safety, governance and talent management").

All stages of the DMA "have been progressively validated by the various management and control bodies, at Executive Committees, Audit Committees and Boards of Directors" (page 79). "The results of the DMA have confirmed the Group's strategy. In fact, the strategic focal points formulated by the group are well in line with the material themes highlighted by the DMA analysis" (page 79). The stakeholder exercise fed into a 19-theme shortlist of potentially material subjects (pages 85-86) that was subsequently narrowed by scoring to three material topics.

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

Reference: pages 86-89 (Table 9: IROs for material topics).

"On the basis of the DMA, three topics were selected as material: 'Climate change mitigation', 'Safety and health of own workforce' and 'Safety and health of subcontractors'" (page 87). Table 9 (page 88) lists the material IROs: a negative impact and a risk under climate change mitigation (embodied/operational carbon; CO2 quotas or taxes), opportunities from designing EU-Taxonomy-aligned buildings, a high CO2-performance-ladder score, and the energetic-renovation market; and a negative impact (site accidents) each for own workforce and for value-chain workers.

"At this stage, the analysis does not highlight any significant material impacts on the Group's current CapEx, OpEx or turnover, either in the short or medium term, directly related to the material impacts, risks and opportunities identified" (page 89). CFE's business model is described as resilient through segment diversification and a total-cost-of-ownership investment approach (page 89).

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

Reference: pages 89-91.

CFE scored potential IROs on impact materiality and financial materiality. Impact severity uses scale, scope and irremediable character on a 1-5 scale; "A topic must score at least 3.5 out of 5 to be considered material. With a score of 3 or above, a theme is considered to be one to watch" (page 90). Weighting combines a project-mix percentage with ESG allocation keys (e.g. headcount for worker-related themes) rather than purely financial weights, "to prevent potentially significant issues in (financially) smaller business sectors from being overlooked" (page 90).

Financial materiality uses a rolling basis on net income; "a financial impact greater than 10% was considered as material by the Board of Directors. This corresponds to a threshold of EUR 3,178,380" (page 90). In 2025 CFE conducted a critical review of the 2024 DMA via peer benchmarking and trigger-based analysis; Business Ethics (G1) was reassessed upward on the impact axis but "even after this revision, the sub-theme 'Business Ethics' remains immaterial for CFE" (page 87).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 74; pages 139-142 (Annex 2: List of references); pages 144-150 (Annex 3: List of omitted information); pages 151-154 (Annex 4: datapoints derived from other EU legislation).

"Following the completion of the DMA, three sub-topics were selected as material for CFE. These are the sub-topic 'Climate change mitigation' (ESRS E1) and the sub-topics 'Health and safety' for our own workforce and for workers in the value chain (ESRS S1 and ESRS S2). CFE will therefore publish information on these three sub-topics in the sustainability statement" (page 74).

"The sub-themes relating to corporate culture, whistleblower protection and the fight against corruption and fraud... were not selected as material following the Double Materiality Assessment... However... CFE has chosen to voluntarily publish information on this subject, drawing on the relevant provisions of ESRS G1 – Business Conduct" (page 74). ESRS E2, E3, E4 and E5 and ESRS S3 and S4 are marked "Non-material theme" in Annex 3. Appendix 2 ("List of references") gives the DR-and-paragraph-level content index with page locations, and Appendix 3 lists omitted data points with their justification (non-material sub-theme, not applicable, transitional implementation, or voluntary reporting).

Transition plan for climate change mitigation

Reference: pages 107-113.

"CFE revised its decarbonisation objectives in 2024 and now aims to reduce its direct emissions (scope 1 and 2) by 40% by 2030 compared with 2020 emissions. Indirect emissions (scope 3) need to be reduced by 20% by 2030, compared with the values measured in 2024" (page 107). "This plan is based on the SBTi framework. Although not yet formally validated, CFE will adhere to the SBTi framework as soon as possible" (page 107).

Responsibility sits with the Executive Committee; "changes in indicators and targets are also presented annually to the Audit Committee and the Board of Directors" (page 108). By 2025 CFE "has already achieved an absolute reduction of 38.1% in total scope 1 and 2 compared with the 2020 reference values", against an expected 20% (page 109). "As a result, the 2050 transition plan is still under development" (page 107), and "no significant capital investment is planned for economic activities related to thermal coal, nuclear power or fossil fuel" (page 112). CFE is not excluded from the EU Paris-aligned benchmarks (page 112).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS E1.IRO-1 (section 2.2.2), where this content is disclosed in the FY2025 report (pages 104-107). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

CFE names two contrasting scenario sets (page 104): a "Strong transition scenario (aligned with the Paris Agreement, < 1.5°C)", based on "IPCC RCP1.9 or RCP2.6 scenarios and the NGFS's 'Net Zero 2050' scenario"; and a "Low transition scenario (warming between 2°C and 3°C)", based on "IPCC RCP4.5 or RCP6.0 scenarios and the NGFS's 'Current Policies' or 'Delayed Transition' trajectories".

Time horizons used are 2030 (short term), 2040 (medium term) and 2050 (long term), assessed for four segments: Construction & Renovation (~60% of turnover), Real Estate (~10%), Multitechnics Rail & Energy (MOBIX) and Multitechnics VMA (~20%) (pages 104-106). Physical hazards named include extreme rainfall/flooding, heat waves, storms, landslides, droughts and, longer term, sea-level rise; transition risks include stricter regulation, low-carbon technology cost/availability and investor/insurer expectations (page 105). The analysis does not separately disaggregate monetary exposure by hazard, consistent with E1-9's stated phase-in.

Resilience in relation to climate change

Back-filled from ESRS E1.IRO-1 and E1-9 (sections 2.2.2 and 2.2.8), where this content is disclosed in the FY2025 report (pages 106-107, 118-119). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"The main drivers of climate resilience are the intensification of physical hazards, regulatory changes, the availability of low-carbon technologies, the associated financial impacts, and the ability of the business model to adapt and capture transition opportunities... the Group's strategy and business model integrate these risks and demonstrate adequate resilience to contrasting climate trajectories" (page 107). "As of the date of this report and based on the 2025 results, no Group activity has been identified as incompatible with our climate resilience trajectory" (page 107).

E1-9 adds that "transition risks are more significant for CFE than physical risks", while physical risks such as floods or heat waves "are localised and short-term, and CFE mitigates them through project diversity, short execution cycles and upstream feasibility studies" (page 118). CFE notes the mitigation plan "only partially covers the physical risks... identified in the analysis" and that "resilience indicators are lacking" (page 118) -- the analysis is qualitative, not a formal resilience test against the two named scenarios.

Policies related to climate change mitigation and adaptation

Reference: pages 107-108.

"CFE has drafted a policy entitled 'Climate Change Policy'. It does not cover climate change adaptation, as this theme has not been deemed material" (page 107). The policy was drafted by the Group's Chief Sustainability Officer and "approved by the Executive Committee and Board of Directors"; it is available to employees on the Group intranet (page 107).

"With this policy, CFE undertakes not only to monitor its GHG emissions, but also to implement the actions necessary to achieve its ambitions in terms of reducing these emissions", supported by "a specific manual on data definition and collection methods" with data consolidated centrally per GHG Protocol methods (page 107). The policy also assigns Business-Unit-level roles for local action plans and references relevant certifications (ISO, CO2 performance ladder). Decarbonisation objectives (-40% scope 1&2, -20% scope 3 by 2030) are stated to be "an integral part of the policy" (page 107).

Actions and resources in relation to climate change policies

Reference: pages 108-113.

For Scope 1-2, three levers are quantified: Lever 1 - Mobility and logistics (EV fleet, charging stations, van-route optimisation) is stated to represent "a potential 28% reduction in total GHG scope 1 and 2 emissions by 2030"; Lever 2 - Site energy consumption (monitoring, insulation, solar panels, green electricity) has "a reduction potential... of the order of 15% by 2030"; Lever 3 - Office energy consumption, exemplified by the Wood Hub headquarters ("primary energy consumption of no more than 8.59 kWh per m²" versus a sector average of "180 kWh/m²/year"), has "a reduction potential... fairly limited (less than 1%)" (pages 108-109).

For Scope 3, levers are "sustainable suppliers and materials" (BPI Real Estate's Life Cycle Assessment approach), "stimulating change in the sector" (Belgian Alliance for Sustainable Construction), and new business units Wood Shapers, Vmanager and Pulse (pages 109-111). Resourcing is largely OPEX-based; CFE states safety/sustainability framework costs are "included in 'operating costs'... As these costs are not material, CFE does not consider it necessary to detail them further" (page 112).

Targets related to climate change mitigation and adaptation

Reference: pages 107-111 (Tables 16 and 18).

Scope 1-2: "reduce its direct emissions (scope 1 and 2) by 40% by 2030 compared with 2020 emissions" (reference year 2020, reference value 17,683.79 tCO2eq); 2025 value 10,946.65 tCO2eq, a 38% reduction against the reference year (Table 18, page 111). Scope 3: "reducing its Scope 3 emissions by 20% by 2030, based on 2024 values" (reference year 2024, reference value 482,306.42 tCO2eq); 2025 value 359,432.70 tCO2eq, a 25.5% reduction against the reference year (Table 18, page 111).

Both targets are stated to be "aligned with SBTi and therefore compatible with the Paris agreements... although they have not yet been formally validated by SBTi" (page 107). "The definition of these targets and the analysis of the various reduction levers are not based on a specific climate scenario" (page 108). Table 16 (page 108) shows 100% of scope 1-2 emissions covered by a 2030 reduction target and by a GHG reduction plan, but 0% covered by "a transition plan in line with the ESRS" for either scope.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 113-117 (Tables 19-22).

Total Scope 1 GHG emissions (2025): 9,711.44 tCO2eq (2024: 11,235.58; 2020 reference: 15,812.17); the fleet accounts for "78% of these emissions" (page 115). Total Scope 2 market-based: 1,235.21 tCO2eq (2025); location-based 2,497.51 tCO2eq. 78% of purchased and consumed electricity uses green electricity (page 115). Total Scope 3: 359,432.70 tCO2eq (2025, down from 482,306.42 in 2024), dominated by Category 1 Purchased goods and services (281,375.76 tCO2eq, ~78% of Scope 3), with Categories 2, 4, 11 and 12 also quantified; Categories 3, 5, 6, 7 and 15 are marked "Non material" and Categories 8-10, 13-14 "Not applicable" (Table 19, page 114).

Total GHG emissions scope 1-2-3 market-based (2025): 370,379.73 tCO2eq (location-based 371,642.04). GHG intensity (market-based): 10.51 tCO2eq/€M net revenue in 2025, down from 11.16 in 2024 (Table 21, page 116). Scope 3 is reported "for the first time in 2024" and remains largely spend-based (0% primary data) (page 116).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 117 (section 2.2.6).

"CFE has no disposal or storage of GHGs resulting from projects developed as part of its own activities or to which it has contributed in their upstream and downstream value chain. In addition, there are no GHG emission reductions or removals taken into account in the GHG emissions disclosed from climate change mitigation projects outside their value chain, which they have financed or intend to finance through the purchase of carbon credits" (page 117).

This is a complete nil disclosure under E1-7: CFE neither holds carbon removals/storage in its own value chain nor relies on purchased carbon credits to offset its reported GHG figures.

Internal carbon pricing

Reference: page 117 (section 2.2.7).

"CFE does not have internal, structured carbon pricing systems to support decision-making or incentivise the implementation of climate-related policies and objectives" (page 117).

This is a complete nil disclosure: CFE confirms it does not operate an internal carbon price for capital allocation, risk assessment or incentive purposes, rather than omitting the topic.

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

Reference: pages 118-119 (section 2.2.8).

"Transition risks are more significant for CFE than physical risks, as they have a systemic and long-term impact on the company's ability to remain competitive and comply with evolving regulations" (page 118). "No portfolio of assets held has been identified as being subject to material impairment related to climate hazards or transition risks over the horizons considered... Consequently, no significant anticipated financial impact has been identified under ESRS E1-9 for owned assets", reflecting that "CFE does not operate an asset-heavy model" (page 118).

Revenue exposure to coal/oil/gas (Table 23, page 119): revenues from gas-related industries are 2.87% of total group-share revenues (EUR 29.85m of EUR 1,041.59m); coal- and oil-related revenues are nil. Table 4 (page 77) records that full monetary quantification of physical/transition risk effects is phase-in deferred: "From the next reporting year, qualitative disclosures will be included, with monetary impacts disclosed from the reporting year ending 31 December 2027."

Policies related to own workforce

Reference: pages 121-122.

"CFE is committed to zero accidents, to setting an example and to providing the resources, support and training needed to ensure the safety and well-being of its workers and partners" (page 121, Code of Conduct). A dedicated QHSE policy, "regularly reviewed in consultation with the Safety Board... last revised in 2024 and approved by the Executive Committee and the Board of Directors", applies to "all workers of the CFE group... as well as its subcontractors and partners" and targets "zero workplace accidents and zero environmental incidents" via ISO 9001/14001/45001 compliance, training, risk identification, incident investigation and communication (page 121).

"Risks relating to child labour and forced labour have been assessed as non-material given the geographical scope of the Group's activities" (page 122), though the Code of Conduct and Human Rights Policy still address the obligation to respect applicable laws. No specific vulnerable worker group was identified for health and safety purposes beyond site workers generally (page 122).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 122-123.

CFE uses both direct engagement (employee commitment surveys, town halls, team meetings, performance reviews) and indirect representation (works councils, trade unions, the CPPT workplace prevention committee, collective agreements) (page 122). A Head of Safety and BU-level prevention advisors meet monthly as the "Safety Board"; advisors "regularly visit their BU's worksites to ensure compliance with safety rules" and write site-specific onboarding brochures (page 123).

Two targeted surveys were run in 2023/2024: NOSAQ (safety-culture perception, which informed the "Go for zero" campaign) and eNPS (page 123). "At this stage, the analysis does not highlight any specific subgroup (age, gender, origin, language or other characteristic) with a significantly different level of risk within this population" (page 123), though an inclusion/respect-for-differences campaign has been launched.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: pages 123-124.

Workers can report concerns, including "all health and safety concerns", via team leader, manager, HR or the Group Compliance Department, in any language, confidentially and anonymously, or via CFE's Whistleblowing Tool (page 123). Each Group subsidiary has a digital tool for encoding safety remarks and suggestions, accessible to all workers and fed by management/prevention-advisor site-visit comments; external project stakeholders may also comment, supported by a 24-hour hotline (page 124).

More general health and safety comments are discussed and recorded at monthly CPPT and CE meetings. "The NOSAQ survey carried out proved the commitment and confidence of CFE workers in their approach to health and safety" (page 124).

Taking action on material impacts on own workforce and approaches to managing material risks

Reference: pages 123-124.

Every project has a "specific risk analysis" before work begins, with insurance during construction and the ten-year warranty period (page 123). CFE states it "doesn't want to settle for minimum safety standards": following the NOSAQ survey, "a communication campaign and specific training courses were launched to reinforce the Group's safety culture" (page 124). Progress is tracked via a safety dashboard (incidents, accidents, management visits, toolbox meetings); "A target for improving the frequency rate has been set for 2030" (page 124).

Co-activity with subcontractors is explicitly managed as part of own-workforce safety. Financially, "the actions undertaken... are therefore only OPEX-type expenses", included in "operating costs"; "the granularity of financial information is not yet sufficient to provide reliable quantitative values" (page 124).

Targets related to own workforce

Reference: page 124.

"CFE has... set itself the target of achieving a maximum severity rate of 0.52 by 2030. This objective has been defined with the aim of halving average sector values (source: Fedris)", with internal annual targets set by linear regression from a 2021 reference severity rate of 0.69 (page 124). The severity rate (calendar days of absence x 1,000 / hours worked) "concerns only accidents involving the CFE group's own workforce" (page 124).

"The ambition level and quantitative target for the severity rate were decided by the Executive Committee after validation of this proposal by the Safety Board. There were no changes made in 2025 with regard to these objectives" (page 124). Internal proactive objectives (incidents, near-misses, toolbox-meeting counts, management-visit counts) are also monitored via BU dashboards.

Characteristics of the undertaking's employees

Reference: pages 125-126 (Tables 24-26).

Total headcount 2,681 (2025), down from 2,854 (2024); by contract type: 2,580 open-ended, 101 fixed-term, 0 zero-hours (Table 24, page 125). By gender: 457 women (17.05%), 2,224 men (82.95%) (Table 25, page 125). By country: Belgium 2,145, Luxembourg 223, Poland 313 (Table 26, page 126).

"At the end of December 2025, the Group's staff turnover (by headcount) for the year was 16.23%. This corresponds to 435 leavers" (page 126). Figures are by headcount, not FTE, "consolidated in a single HR management dashboard", but "this data is not validated by an external body". Non-employees are explicitly excluded: "Non-employees are currently not included. Although these data are not material, they will gradually be integrated into the reporting" (page 126).

Social protection

Reference: page 126 (section 3.1.9).

"In accordance with current European and local legislation, all CFE group workers benefit from social protection in the event of illness or accident on site or on the way to or from work" (page 126).

This is a short, standalone disclosure confirming statutory-level social protection coverage tied to the material health-and-safety sub-topic (illness/accident cover); it is not expanded with quantified coverage-rate data by worker category.

Training and skills development metrics

Reference: page 126 (section 3.1.10).

Training runs through "training plans, coaching, career plans" and the "CFE Academy", an online platform launched at end-2022 offering customised content and both digital and face-to-face formats (page 126). "Specific health and safety training sessions are organised, for example, when employees are hired, when they arrive on site, at monthly toolbox meetings and during dedicated 'safety days'" (page 126), linking training directly to the material health-and-safety sub-topic.

Training-hours data is collected (total and by gender) via the CFE Academy, but "At this stage, CFE is not publishing this data externally" (page 126). A performance-appraisal participation metric is explicitly phase-in deferred: "A new programme to digitise the performance appraisal process will make it possible to measure the percentage of workers who have taken part in the appraisal. It will be deployed in 2025. This data will therefore not be published until the next report" (page 126; Table 4, page 77).

Health and safety metrics

Reference: pages 126-127 (Table 27).

Own-workforce accident data for 2025: 0 work-related fatalities (own workforce; 2024: 0, 2023: 1); 114 recordable accidents (excluding first aid); 44 lost-time accidents (down from 64 in 2024); frequency rate 11.4 (down from 15.34); severity rate 0.35 (down from 0.56); 1,333 days lost to accidents (Table 27, page 126-127). 100% of the Group's own workers are covered by the data, which excludes self-employed, temporary staff and subcontractors (page 126).

"Regarding the severity rate, an improvement of 38% is observed compared to 2024. The 2025 results exceed the target set for 2030 (frequency rate = 0.52). However, it remains essential to sustain these excellent results over time, and the 2030 target is maintained" (page 127). Belgian and Luxembourg figures are validated by insurers; Polish data comes from national records (page 127).

Incidents, complaints and severe human rights impacts

Reference: page 127 (section 3.1.11.1).

"No offences or complaints of discrimination or failure to respect human rights were recorded in 2025. No fines have been reapplied either" (page 127).

This is a nil return, directly disclosed and tagged to ESRS S1-17 in the report, rather than a gap: the company states plainly that no incidents of this kind occurred during the reporting year. Annex 4 separately marks the "Incidents of discrimination" SFDR-derived datapoint as "Not material" (page 151), consistent with the narrative nil return.

Policies related to value chain workers

Reference: page 128 (section 3.2.3).

"CFE has adopted a series of policies that apply both to its own workforce and to the various parties involved on site. These include the Human Rights Policy and the QHSE Policy" (page 128), cross-referenced to the S1-1 detail. A "Code of Conduct for commercial partners" has also been drawn up, "includ[ing] an obligation to comply with the internal Code of Conduct, and in particular to respect the safety rules set out in the QHSE policy" (page 128).

"The obligation to comply with local and European laws and regulations, as well as with the aforementioned policies, are an integral part of the contractual clauses for sub-contractors" (page 128), embedding the health-and-safety policy commitments contractually across the value chain.

Processes for engaging with value chain workers about impacts

Reference: pages 128-129.

Subcontractor onboarding is formalised through a short site-introduction training; "Each team should have a manager who speaks one of the project's national languages, to ensure that he or she can communicate with the site management teams at all times" (page 128). "Formal meetings are held at least once a week with subcontractors working on the site", producing action reports, schedule updates and phase overviews, under a "LEAN and collaborative approach" (page 128-129).

"Value chain mapping enables us to analyse each stage of the construction process, from design to delivery, and detect critical points where safety incidents may occur" (page 129). "Penalties are foreseen and communicated for any worker who does not respect the safety rules in force on projects" (page 129).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 129.

Remediation begins with subcontractor risk analysis shared with site management at the start of activities, followed by preventive or corrective measures (modified procedures, improved equipment, targeted training) (page 129). Channels for value-chain workers to raise concerns include onboarding with a comprehension test (a condition of site-access badges), weekly safety meetings, direct communication with site teams, a mobile app for incident reporting, and regular visits by the site QHSE manager (page 129).

"If, for any reason, a whistleblower is uncomfortable or reluctant to report misconduct through the usual reporting channels, CFE's internal whistleblowing tool provides another channel through which they can report misconduct confidentially or anonymously" (page 129).

Taking action on material impacts on value chain workers, and approaches to managing material risks and opportunities and the effectiveness of those actions

Reference: pages 129-130.

Subcontractors must carry out project-specific risk analysis before work begins, validated jointly with CFE's project management team; subcontracting agreements "specify in detail the roles and responsibilities of all parties involved", including collective versus personal protective equipment (page 129-130). "Regular checks are carried out on site by the BU's QHSE manager and by management teams", each followed by a visit report, and "a specific monthly dashboard also includes the number of incidents and accidents involving subcontractors" (page 130).

"In the event of serious misconduct, the person responsible will be asked to leave the site with immediate effect and will not be allowed to return. CFE also monitors the company's track record in terms of safety compliance... when selecting subcontractors" (page 130). "CFE is not aware of any serious human rights problems or incidents linked to the upstream or downstream value chain (other than the site accidents listed in the following chapter)" (page 130); these actions are OPEX-only and already accounted for under own-workforce safety spend.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (value chain workers)

Reference: pages 130-131 (Table 28).

"At this stage, no quantifiable annual target has been set. Nevertheless, the overall objective is the same as for own workforce, i.e. to aim for zero accidents" (page 130). Subcontractor accident data (Table 28, page 130): 0 work-related fatalities (subcontractor/third party) in both 2024 and 2025 (down from 1 in 2022 and 2023); 21 accidents with incapacity in 2025 (down from 35 in 2024).

"This data should be treated with great caution, as they are supplied by the subcontractors themselves, and their quality or completeness cannot be guaranteed", and frequency/severity rates cannot be calculated for subcontractors since hours worked are not reported to CFE (page 130). "At this stage, CFE does not have sufficiently comprehensive and consistent data to set specific quantitative targets for the safety of workers in the value chain"; data is limited to Tier-1 subcontractors (page 130-131).

Business conduct policies and corporate culture

Voluntarily disclosed: "the double materiality assessment shows that the topics related to corporate culture, whistleblower protection, and corruption and bribery... are not material, as they fall below the defined materiality thresholds... Nevertheless, CFE is committed to respecting these rules of business conduct" (page 132).

Governing documents are the "Code of Conduct", the "Business Integrity Policies" manual (gifts/entertainment, antitrust, political involvement, international sanctions, conflict of interest, anti-bribery and corruption) and the "Whistleblowing Policy", applying globally to all employees and, via a separate "Business Integrity Policies for Business Partners" manual, to the value chain (pages 132-133). A formal whistleblowing mechanism offers an online tool, available 24/7, with confidentiality, anonymity and an explicit anti-retaliation guarantee, open to external stakeholders too (page 132).

At Executive Committee level, responsibility sits with the General Counsel, a permanent guest (page 133). In 2025, 85.26% of employees completed ethics and compliance training against a 95% target; the ABAC module completion rate was 82.37% (page 135).

Management of relationships with suppliers

Voluntarily disclosed: the DMA found "the theme of partnership, which covers such topics as supplier relations and payment practices" not material (page 132), but CFE reports on it.

"CFE ensures that it respects its partners, which also involves strict compliance with payment deadlines. Certain suppliers and SMEs constitute a significant and sometimes vulnerable part of its supply chain. This monitoring is based on rigorous administrative procedures, digital invoice processing and regular monitoring of payment deadlines by the finance teams" (page 134).

"As part of strengthening its approach to business integrity within the supply chain, CFE has initiated the development of a procurement policy" covering supplier selection, evaluation and monitoring, including corruption and social/environmental risks (page 135). Business-partner obligations are contractually embedded: "the code of conduct applicable to business partners corresponds in all material respects to that applicable internally" (page 132).

Prevention and detection of corruption and bribery

Voluntarily disclosed: "the topics related to corporate culture, whistleblower protection, and corruption and bribery (combined under the theme 'business conduct and respect for the law') are not material" (page 132), but CFE reports on it.

Prevention runs through mandatory "ethics and compliance" e-learning for all employees and staff since 2024, covering professional integrity, corruption prevention, conflicts of interest, data protection, human rights, fair competition, sanctions and financial integrity, delivered via the CFE Academy in multiple languages (page 134-135). Workers (lower assessed risk) receive awareness campaigns rather than mandatory e-learning (page 135).

Detection relies on vigilance and reporting through team leaders, HR, the Compliance Department or the whistleblowing tool, with independent handling of reports "by individuals who are independent from the reported situation" (page 135). Internal audit "reports functionally to CFE's Audit Committee by submitting the annual audit plan"; the General Counsel "reports annually to the Audit Committee on statistics and substantiated reports submitted through the whistleblowing tool" (page 135-136). "At this stage, CFE has not assessed the full alignment of these policies with the United Nations Convention Against Corruption" (page 134).

Incidents of corruption or bribery

Voluntarily disclosed, within the "not material" G1 topic (page 132).

"The CFE Group recorded no convictions or fines during the 2025 financial year for violations of anti-bribery and anti-corruption (ABAC) laws" (page 136).

"However, it should be noted that the Belgian judicial authorities are currently conducting an investigation into alleged criminal acts relating to the construction of the Grand Hotel in N'Djamena, Chad... this contract, which dates back to 2011, resulted in a loss of more than EUR 50 million for CFE, due to the non-payment of part of its receivables. The work was carried out by CFE Tchad, a Group subsidiary until its sale in 2021." A search was carried out at CFE's head office on 4 September 2024; "at the date of this report, CFE has not yet had access to the investigation file and no charges have been brought against CFE or its current managers and/or directors". "CFE is unable to reliably estimate the financial consequences of this ongoing procedure. Consequently, no provision has been recognised as at 31 December 2025" (page 136).