CUF

The role of the administrative, management and supervisory bodies

CUF's governance structure is made up of administrative, management and supervisory bodies responsible for the strategic definition, monitoring and supervision of impacts, risks and opportunities, including matters related to sustainability.

The Board of Directors is made up of six executive members and nine non-executive members, as well as two independent members (13.3% of the members), ensuring a balance between operational management and independent supervision. As for gender representation, there is a diversity index of 0.33, which corresponds to 33.3% female and 66.6% male. The members of the Board of Directors have professional experience in sectors relevant to CUF's activity, ensuring a comprehensive and informed view when making strategic decisions. There is no employee representation on the company's administrative, management or supervisory bodies.

The functioning of the Board of Directors and of the Executive Committee is regulated in addition to the Law, the Articles of Association, the Code of Ethics and the CUF Code of Conduct. The supervision of CUF is under the purview of a Supervisory Board and of an Audit Firm.

Board Competencies

Board of Directors: It is incumbent upon the Board of Directors to define the strategy, the major policies and the social, economic and financial planning of CUF, ensuring their application in its subsidiary companies. To that effect, it is responsible, namely, to decide on:

• The acquisition of real estate and movable goods, including equity interests, as well as to sell or encumber such property by any acts or contracts, even if they serve to establish real guarantees.
• The approval of the budget, preparation of the balance sheet and financial statements of the financial year and preparation of reports on CUF's activities and economic situation, as well as the proposal for distribution of profits, to be submitted to the General Meeting.
• The amicable or judicial settlement of questions regarding rights and interests of CUF.
• Appointing people who do not belong to the governing bodies, to be the officers responsible for top-level executive management of all of CUF's technical and administrative services, and establishing representatives for any other purposes.
• The contracting of internal or external financing that CUF needs to fulfil its corporate purpose.
• Decision on the issuance of bonds and/or other securities.
• Preparation and approval of all regulations that detail the exercise of social rights, as well as those that concern practical aspects of the operation of the Board of Directors or of other bodies.

Executive Committee: The Executive Committee takes on a set of responsibilities, delegated by the Board of Directors, including carrying out the day-to-day management of the Company, with the ability to deliberate on all matters concerning the performance of the Company's activity, following its corporate purpose and the resolutions made by the Board of Directors and by the General Meeting.

Supervisory Board: The Supervisory Board is responsible for supervising the management of CUF and monitoring compliance with the rules governing its operation, participating in meetings where financial statements are evaluated, verifying the correctness of accounting information, monitoring the effectiveness of risk management systems, and supervising the process of preparation and disclosure of financial information.

Advisory Bodies: The Board of Directors and the Executive Committee are assisted by corporate and shared-services departments and by a set of advisory bodies including:

• Code of Conduct Monitoring Committee
• Risk Auditing and Management Committee
• Innovation and Sustainability Committee
• Medical Council
• Nursing Council
• Customer Ombudsperson
• CUF Licensing Compliance Committee

Sustainability Governance: Sustainability is transversal to the whole of CUF and, in terms of the governance model, is taken on in the first instance by the Chief Executive Officer. The development of the strategy, its transversal implementation and the progress made in all units and departments are overseen by the Innovation and Sustainability Committee and also by the Code of Conduct Monitoring Committee, both of which have representatives from the Board of Directors.

Information provided and sustainability issues addressed by the company's administrative, management and supervisory bodies

The double materiality assessment process, aimed at identifying material impacts, risks and opportunities for CUF, was conducted with the active involvement of the different management bodies and approved by the Executive Committee. This process also included an exercise to align the impacts, risks and opportunities with CUF's strategy.

The Risk Management Department is responsible for monitoring the risks identified in the company's risk dictionary, which includes a description of the material risks and the respective mitigation measures, with the goal of reducing their likelihood of occurrence and/or impact (financial, environmental and social). Risks are classified on the basis of probability and impact scales and, during the reporting period, the risks with the highest levels are presented at periodic meetings with the Executive Committee for detailed analysis and a decision on possible corrective actions.

The Corporate Citizenship Department is responsible for aggregating sustainability issues throughout the company, coordinating with the various departments to implement the necessary plans to ensure compliance with the defined metrics. This department discusses material impacts, risks and opportunities, as well as the results and effectiveness of the policies and actions adopted to mitigate them, reporting to the Executive Committee, Board of Directors, Innovation and Sustainability Committee, Risk Auditing and Management Committee and Code of Conduct Monitoring Committee on all situations and their results at regular meetings of these bodies.

Integration of sustainability performance into incentive schemes

There has been a sustainability criterion in CUF's overall performance assessment since 2022, which has a weighting of 7.5% with an impact on variable remuneration (annual bonus) and is applicable to all employees of the organization, including member of management bodies. In 2024, the Executive Committee approved a new global objective, specifically the reduction in paper consumption measured by a ratio per visit to CUF units, without the measurement of greenhouse gases (GHG).

Statement on the duty of care in matters of sustainability

CUF defends human rights both in the sphere of its employees and in its relations with the outside world, also promoting due diligence across the board in its strategy and business model. The Code of Conduct (a guide for internal and external relations), available on the CUF website, also emphasises the importance of scrupulous compliance with the law and respect for human rights, environmental standards, the fight against corruption and other relevant matters related to sustainability in its social component, namely the Organisation for Economic Co-operation and Development (OECD) guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights established in the fundamental conventions identified in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights.

Essential elements of the duty of care

Risk management and internal controls for sustainability reporting

CUF has been reporting sustainability information since 2016, having developed a robust process for collecting and reviewing information. However, with the preparation of the first ESRS-aligned report, adaptations were necessary to ensure compliance with the new requirements. The main risks identified in this process are related to the completeness and accuracy of the data reported, having been developed several documents to gather information for different corporate areas, to mitigate these risks.

The risk management process is supported by a transversal and systematic methodology which, starting from the identification of CUF's objectives and those of each department/service/business segment, identifies all types of events, internal or external, which may influence their realisation, as well as those responsible for managing them. This is followed by an analysis of each event, identifying the causes, consequences and ongoing mitigation measures that could help mitigate the risk. Once identified, the risks are assessed by assigning levels of "probability of occurrence" and "impact", according to the scales in effect. Depending on the level of risk (obtained by combining probability and impact), the strategy to be adopted for dealing with it is identified (eliminate, transfer, mitigate or accept the risk).

Monitoring is carried out on an ongoing basis, namely by sharing and analysing risk indicators, with the frequency being dictated by the level of risk.

Each year, depending on the expected evolution of the context (national and international), internal developments and the level of residual risk, the risks that will be monitored more closely by the Executive Committee are identified and the mitigation strategies developed.

The conclusions arising from the risk management process, related to the sustainability statement, go through various levels of review, namely: reviews by directors of corporate areas and by the Executive Committee and, ultimately, review by the Board of Directors, which is responsible for validating and supervising the effectiveness of internal controls.

Market position, strategy, business model(s) and value chain

CUF operates in the provision of Healthcare and Occupational Health and Safety at the national level, in an integrated and comprehensive manner, and has a dedicated clinical staff and multidisciplinary teams that are committed to the quality of the healthcare services provided, namely:

Services Provided

• Specialty consultations
• Dental Medicine
• Exams
• Adult Permanent Care
• Paediatric Permanent Care
• Remote Consultation
• Day remote consultation
• Surgeries
• Hospitalisation
• Home Hospitalisation
• Maternity Care
• Intermediate Care
• Intensive Care
• Palliative Care
• Home Care
• Vaccination
• Nursing Care

Business Segments

Hospitals and Clinics: Present in various parts of the country, CUF offers differentiated healthcare, driven by the knowledge and experience of an excellent clinical team. It has 30 hospitals and clinics with 50 medical and surgical specialties and 7,862 salaried employees, whose geographical dispersion can be found in Chapter S1.

Domiciliary Services: CUF provides home clinical support and accompanies customers in the comfort of their own homes, with an experienced team, through home care and home hospitalisation.

Digital Channels: Anywhere in the country, or even abroad, it is possible to access CUF's services through its digital channels, offering convenience and flexibility to those who need care: Teleconsultation, Day Remote Consultation, My CUF Symptom Evaluator and App.

CUF Strategy

Aspiration: To be a reference in Portugal in three dimensions:

• In the quality and scope of the healthcare provided
• In the personal and professional development of all those who work at CUF
• In the creation of value with sustainability for its shareholders and the community

Strategic Assets:

• Talent
• Technology
• Network and Brand

Strategic Axes:

• Differentiation in the care continuum
• Focus on patient care, with consistency and efficiency
• Articulation of the growth of the units with the launch of new businesses and focus on digitisation

Sustainability in Strategy

CUF remains strongly committed to creating value, in a sustainable way, and to positively impacting society. By integrating sustainability into its strategy and business practices, CUF endeavours to generate a positive impact on the communities in which it operates, in line with sustainability criteria in its social, environmental and governance dimensions.

CUF's strategy on sustainability encompasses:

• Decarbonisation: Reducing carbon emissions through transition to renewable energy sources
• Reducing the Ecological Footprint: Minimising environmental impact through waste management and resource conservation
• Inclusive Service: Ensuring accessibility for all stakeholders and combating inequalities
• Digitalisation: Key enabler for achieving sustainability objectives

Stakeholders' interests and perspectives

Value Chain

CUF recognises that the sustainability of the healthcare sector depends not only on its direct operations, but also on the way its value chain is managed. In working with a vast network of partners, suppliers and service providers, CUF ensures that the principles of social, environmental and ethical responsibility are incorporated into all its activities.

From the careful selection of suppliers to the development of innovative and efficient practices, we promote a collaborative and transparent approach, ensuring compliance with the highest standards of quality and sustainability. Our actions are based on trust, the creation of shared value and the mitigation of environmental impacts, contributing to a more responsible and resilient health ecosystem.

Stakeholder Engagement

Recognising the importance of understanding and valuing the expectations and needs of all stakeholders, CUF maintains an open, transparent dialogue and active, ongoing involvement. Each stakeholder represents a vital part of the health ecosystem and the relevance, the involvement profile and the contribution to value creation have been identified for each one.

Key Stakeholders:

• Suppliers
• Customers
• Industry associations
• Employees
• Communities
• Shareholders
• Regulators
• Investors
• Academic and Scientific Community
• Responsible Financial Entities

CUF conducts consultations with stakeholders to gather needs and opinions related to professional and personal development prospects, remuneration and talent, with the ultimate goal of contributing to the definition of the company's strategy and business model.

The sustainable transformation of the healthcare sector requires a collective commitment. For this reason, CUF encourages the adoption of good practices throughout the supply chain, aligning itself with partners who share the company's values and who also recognise sustainability as an essential pillar of their strategy.

Material impacts, risks and opportunities and their interaction with the strategy and the business model(s)

Climate change

Adapting to climate change, Mitigating climate change

• Impact/Risk/Opportunity: Extreme climatic events that require an additional effort from infrastructure regarding energy efficiency
• Location in value chain: Own Operations and the Entire Value Chain

Energy

• Impact/Risk/Opportunity: Investment in more efficient equipment and self-consumption solutions that enable medium-term savings
• Location in value chain: Own Operations and the Entire Value Chain

Water

Water Consumption

• Impact/Risk/Opportunity: Water shortages and the possible higher cost of purchasing water from the network
• Location in value chain: Own Operations and Upstream Value Chain

Circular Economy

Outflows of resources related to products and services

• Impact/Risk/Opportunity: Waste reduction and hazardous waste management
• Location in value chain: Own Operations and Downstream Value Chain

Waste

• Impact/Risk/Opportunity: Waste reduction and hazardous waste management that allow for lower costs and fewer GHG emissions into the atmosphere
• Location in value chain: Own Operations and Downstream Value Chain

Own labour

Work conditions, Job security

• Impact/Risk/Opportunity: Ensuring the well-being, health and safety of employees
• Location in value chain: Own Operations

Working hours

• Impact/Risk/Opportunity: Continuous activity 24 hours a day, 7 days a week in hospital units, which increases the demands on employees
• Location in value chain: Own Operations

Adequate wages; Social dialogue; Freedom of association; Work-life balance

• Impact/Risk/Opportunity: Attracting, developing and retaining talent
• Location in value chain: Own Operations

Health and safety

• Impact/Risk/Opportunity: Employee well-being, health and safety, which will make it possible to better attract human resources
• Location in value chain: Own Operations

Research and innovation

• Impact/Risk/Opportunity: Advanced training awarded to employees through doctoral scholarships and grants for the publication of scientific articles
• Location in value chain: Own Operations and the Entire Value Chain

Equal treatment and opportunities for all

Gender equality and equal pay for work of equal value, Training and skills development and Diversity

• Impact/Risk/Opportunity: Attracting, developing and retaining talent
• Location in value chain: Own Operations and Downstream Value Chain

Employment and inclusion of people with disabilities

• Impact/Risk/Opportunity: More diverse teams lead to diversity of thought, added value in teams and, consequently, a higher quality of service
• Location in value chain: Own Operations and Downstream Value Chain

Workers in the Value Chain

Work conditions, Freedom of association, Collective bargaining

• Impact/Risk/Opportunity: Attracting, developing and retaining talent
• Location in value chain: Own Operations and Upstream Value Chain

Consumers and End Users

Impacts related to information for consumers and/or end users, Privacy, Freedom of expression

• Impact/Risk/Opportunity: Confidentiality of user information preserved
• Location in value chain: Own Operations and Downstream Value Chain

Access to (quality) information

• Impact/Risk/Opportunity: Recognition from stakeholders for the provision of excellent healthcare
• Location in value chain: Own Operations and Downstream Value Chain

Digital Transformation

• Impact/Risk/Opportunity: Greater process efficiency, which allows for a faster and better quality response for the customer
• Location in value chain: Own Operations and Upstream Value Chain

Personal safety of consumers and/or end users, Health and safety, Personal safety and Child protection

• Impact/Risk/Opportunity: Recognition from stakeholders for the provision of excellent healthcare
• Location in value chain: Own Operations and Downstream Value Chain

Business Conduct

Corporate culture

• Impact/Risk/Opportunity: Interacting with all stakeholders in accordance with our standards of business ethics
• Location in value chain: Own Operations and the Entire Value Chain

Supplier relationship management, including payment practices

• Impact/Risk/Opportunity: Good relations with the supply chain
• Location in value chain: Own Operations and the Entire Value Chain

Description of the processes for identifying and assessing material impacts, risks and opportunities

CUF carried out its double materiality analysis (DMA) exercise in 2022, in line with the draft version of the ESRS (European Sustainability Reporting Standards) published in November 2022.

This assessment considered both the impacts of CUF's business on society and the environment (impact materiality) and how these topics affect CUF in the form of business risks and opportunities (financial materiality).

Scope of Double Materiality Analysis

The impacts, risks and opportunities on CUF's own operations were identified taking into account the various areas of activity and locations where CUF operates. Double Materiality has also incorporated the upstream and downstream value chain.

The double materiality assessment was initiated by combining the list of topics and subtopics, which included issues specific to the CUF context. An outside-in perspective was also considered, through consultation with various relevant stakeholders in the value chain. For all the topics identified, a four-stage process was followed:

1. Input from internal subject matter experts
2. Engagement with external stakeholders
3. Calibration by internal leaders, including discussion by senior management
4. Review and approval by the Executive Committee

Methodology

Impact Materiality: Identification of material topics when the company is associated with real or potential impacts on people or the environment in the short, medium, or long term. This includes the impacts directly caused by the company, as well as those it has or may have on its entire value chain.

Financial Materiality: Identification of material topics that trigger financial effects on the company, i.e., that generate or may generate risks or opportunities that influence future cash-flows and therefore the value of CUF in the short, medium or long term.

Stakeholder Involvement

Stakeholders Affected:

• Customers
• Employees
• Suppliers
• Academic and Scientific Community
• Communities (Local Authorities and Social Economy Organizations)

Users of the sustainability statement:

• Shareholders
• Investors
• Responsible Financial Entities
• Regulators
• Industry associations

CUF formally invited its stakeholders to take part in the consultation process by answering an anonymous online questionnaire.

Assessment Scales

Impact Materiality Scale:

1. Irrelevant contribution
2. Insignificant contribution
3. Relevant contribution
4. Very relevant contribution
5. Extremely important contribution

Financial Materiality Scale:

1. Affecting in an irrelevant way
2. Affecting with little relevance
3. Affecting in a relevant way
4. Affecting in a very relevant way
5. Affecting in an extremely relevant way

The score of impacts, risks and opportunities, calculated from 0 to 5, was compared to a quantitative threshold of >= 3.53 and >= 3.83 respectively, to determine which topics would be material to report according to the ESRS.

Material Topics Identified

In the course of systematising the 2024 activity in this Report, in line with the CSRD, it was found that Risk Management and Financial Sustainability, previously classified as material topics, should be considered cross-cutting strategic axes, with a different framework. In this sense, the CUF matrix now includes 13 material topics.

Climate-related impacts, risks and opportunities

The identification of climate-related risks and opportunities was based on the exercise carried out in 2023, in light of the Task Force on Climate-related Financial Disclosures (TCFD), which identified physical and transition risks and opportunities in the short, medium and long term.

Risks identified:

• Extreme Weather Events
• Water Scarcity
• Carbon Price
• Legal Non-Compliance

Opportunities identified:

• Investment in Renewable Energy Sources
• Research and innovation
• Investment in more Efficient Equipment
• Green Financing

Decision-making process

The Double Materiality analysis was reviewed and approved by the Executive Committee.

Disclosure requirements for ESRS covered by the company's sustainability statement

Transition plan for climate change mitigation

Scope and status

CUF's decarbonisation strategy is under development. A Climate Change Transition Plan is scheduled for 2025, which will reinforce the decarbonisation strategy and promote additional measures to reduce greenhouse gas (GHG) emissions.

The initiatives apply to CUF's operations nationwide, covering all units.

Decarbonization initiatives and levers

Concrete measures already underway include:

• Fleet electrification: CUF has set a goal of having 40% electric or hybrid cars in its fleet by 2028. This target is part of CUF's Sustainability-Linked Financing Framework and applies to the entire employee fleet, with the exception of courier vehicles (whose transition depends on market availability of options with greater range). Service vehicles are all already electric.

• Elimination of desflurane: From 2022, CUF discontinued desflurane, a highly polluting anaesthetic gas. Awareness-raising among internal teams and promotion of international best practices have reduced the use of halogenated gases in surgical practice, resulting in significant emission reductions.

• Energy efficiency measures: Implemented to reduce energy consumption and optimize resource management.

Carbon footprint monitoring

Annual monitoring of the Carbon Footprint is an essential pillar of CUF's commitment to sustainability. The company has worked internally and together with its suppliers to collect and make available data on its emissions, enabling continuous assessment of environmental impacts. This process identifies opportunities for improvement and supports implementation of projects that contribute to reducing CUF's ecological footprint.

CUF has not yet determined the reduction of carbon emissions that result from each initiative.

Energy targets

Energy efficiency targets for 2025 (base year 2024):

*Energy intensity is the ratio between energy consumption in kWh and CUF's turnover in thousand euros (€k).

These targets are annual and apply to CUF's own operations and are transversal to all units. The targets are based on increasing production and implementing improvement measures. There are no intermediate targets set.

Progress: Comparing only existing units since 2023, the intensity of electricity and natural gas consumption has decreased by 9.04% and 15.95% respectively.

Alignment and strategic context

The implementation and monitoring of adopted measures and targets are directly aligned with CUF's commitments as reflected in its Sustainability Policy, with emphasis on reducing the ecological footprint. There is strategic convergence with the United Nations' Sustainable Development Goals (SDGs), in particular:

• SDG 13 – Climate Action: combating climate change and its impacts
• SDG 9 – Industry, Innovation and Infrastructure: encouraging modernisation and adoption of sustainable practices

The fleet electrification measure is aligned with the national strategy for sustainable mobility. Since 2023, the Portuguese Government has provided for an exemption from value added tax (VAT) for companies with vehicle fleets made up of electric, hybrid and compressed natural gas (CNG) vehicles.

Future development

During 2025, CUF will continue to closely monitor regulatory developments of the EU Taxonomy Regulation. CUF is currently developing its Climate Transition Plan, which seeks to contribute to its decarbonisation strategy, as well as to the implementation of a climate risk management procedure, based on an assessment of vulnerability and climate risks and on the development of an adaptation plan, which could lead to an increase in the eligibility and alignment of CUF with the EU Taxonomy in future reporting cycles.

Policies related to climate change mitigation and adaptation

CUF has adopted three main policies that address climate change mitigation and adaptation:

Sustainability Policy

Approval and oversight:

• Approved by the Executive Committee in September 2023
• Overseen by the Innovation and Sustainability Committee and the Code of Conduct Monitoring Committee, both with Board of Directors representatives
• Chief Executive Officer has primary responsibility for sustainability
• Corporate Citizenship Department (reporting to CEO) is responsible for defining and developing CUF's sustainability strategy

Scope:

• Applies to companies fully owned, directly or indirectly, by CUF, S.A.
• Transversal to all CUF units and departments

Key content / principles related to climate change:

• Active contribution to the reduction of ecological footprint by seeking solutions to efficiently manage natural resources, combining best care practices with an environmentally responsible attitude
• Identification and management of climate risks, maintaining high standards of quality and safety
• Establishment of contracts or partnerships only with entities that share CUF's principles and ethical values, demanding compliance with environmental, social and governance criteria
• Contribution to sustainable development of communities where CUF operates with the least possible environmental impact

Public availability:

• Published on the CUF website in September 2023

Implementation monitoring:

• Progress assessed annually in an integrated approach through 11 ESG commitments
• Linked to Double Materiality analysis and Strategy 21–25

Fleet Management Policy

Approval and oversight:

• Drawn up by the People Management Department and the Means and Assets Department
• Final approval by the Executive Committee

Scope:

• Applies to all employees who use the fleet

Key content / principles related to climate change:

• Minimising environmental impact by choosing more efficient vehicle makes and models
• Ensuring and optimising electrical infrastructures installed by CUF for employees and clients

Public availability:

• Available on CUF intranet
• Sent individually to each employee who uses the fleet

Implementation monitoring:

• Commitment to sustainability made available to stakeholders

Quality, Environment and Safety Policy

Approval and oversight:

• Developed by the Quality, Environment and Safety Department
• Complies with international standard ISO 9001

Scope:

• Applies to companies fully owned, directly or indirectly, by CUF, S.A.

Key content / principles related to climate change:

• Respect for guiding principles of sustainable development
• Ensuring value creation and stakeholder satisfaction
• Energy efficiency considerations (referenced in context of the policy)

Public availability:

• Available on the intranet for all employees

Implementation monitoring:

• Monitoring and implementation differs according to scope, with specificities indicated in policy text

Actions and resources in relation to climate change policies

CUF has developed a comprehensive set of actions to mitigate climate change, structured into three main strategic areas: Energy Efficiency and Use of Renewable Energy, Electrification and Sustainable Fleet Management, and Replacement of Technologies and Infrastructures to Reduce Emissions.

1. Energy Efficiency and Use of Renewable Energies

Installation of photovoltaic self-consumption production units

• Scope: Own operations (hospitals and clinics)
• Time horizon: Implementation expected by 2025
• Expected outcome: Estimated reduction of 1.44 GWh in electricity consumption from the public grid per year
• Resources: Power purchase agreement (PPA) to be signed

Implementation of energy and water management platform (SGE)

• Scope: Own operations
• Time horizon: Implementation planned
• Resources allocated: €32,227 (CapEx included under Property, plant and equipment in progress)
• Expected outcome: Monitor and reduce electricity and gas consumption

Optimisation of building automation and control system (BACS)

• Scope: Own operations (several units)
• Time horizon: 2025-2026
• Expected outcome: Significantly reduce energy consumption in several units

2. Electrification and Sustainable Fleet Management

Transition to electric vehicles and plug-in hybrids

• Scope: Own operations (company fleet)
• Time horizon: Since 2024 (ongoing)
• Description: Cars in the Renault Clio or equivalent segment are exclusively electric since 2024

Fleet management platform and eco-efficient training (2024)

• Platform to manage electric vehicles in fleet
• Eco-efficient training for employees

Study into total electrification of courier vehicles

• Time horizon: Initiated 2024
• Note: Feasibility depends on evolution of vehicle range available on the market

Charging infrastructure investments (2025)

• Reinforcement of chargers in corporate units and centres
• Assessment of installation of ultra-fast chargers in strategic locations

Alternative mobility pilot project

• Time horizon: Planned for launch
• Description: Options include bicycles, scooters and taxis

3. Replacement of Technologies and Infrastructures to Reduce Emissions

Replacement of natural gas boilers with renewable technologies (heat pumps)

• Scope: Own operations
• Time horizon:
  • CUF Almada Clinic: 2024 (initiated)
  • CUF Viseu and CUF Coimbra hospitals: 2025 (planned expansion)
• Resources allocated: €180,000 total planned investment

Separation of domestic hot water (DHW) and air conditioning (HVAC) systems

• Scope: Own operations
• Time horizon:
  • CUF Sintra Hospital: 2024 (implemented)
  • Other units: expansion by 2030
• Resources allocated: €2,000,000 estimated total investment
• Expected outcome: Significantly reduce energy consumption by optimising the temperature of the HVAC circuit

Installation of inertia tank at CUF Porto Hospital

• Time horizon: 2025 (planned)
• Resources allocated: €30,000
• Expected outcome: Reduce energy losses and minimise the risk of legionella bacteria developing

4. Annual monitoring of the Carbon Footprint

• Scope: Own operations and value chain (with suppliers)
• Description: Collection and availability of emissions data for continuous assessment of environmental impacts
• Purpose: Identifying opportunities for improvement and implementing projects to reduce ecological footprint

5. Decarbonisation strategy measures

Discontinuation of desflurane (highly polluting anaesthetic gas)

• Time horizon: From 2022
• Expected outcome: Significant reduction in associated emissions from halogenated gases in surgical practice
• Approach: Awareness-raising among internal teams and promotion of international best practices

Climate Change Transition Plan

• Time horizon: Scheduled for 2025
• Purpose: Reinforce decarbonisation strategy and promote additional measures to reduce greenhouse gas (GHG) emissions

Key limitation noted

Although CUF has implemented the initiatives mentioned above and annually monitors its carbon footprint, it hasn't yet determined the reduction of carbon emissions that result from each initiative.

Links to policies and targets

The actions are aligned with:

• CUF's Sustainability Policy (emphasis on reducing ecological footprint)
• SDG 13 – Climate Action
• SDG 9 – Industry, Innovation and Infrastructure
• Commitment to smoother mobility and lower carbon emissions

Targets related to climate change mitigation and adaptation

CUF has disclosed targets related to climate change mitigation focusing on energy efficiency and vehicle fleet electrification.

Energy Efficiency Targets

Energy consumption in hospitals and clinics is essential for the operation of medical equipment, air conditioning and lighting, but it also represents one of the biggest operating costs. CUF is committed to implementing energy consumption reduction targets that will contribute to environmental preservation and guarantee more economical and responsible resource management.

Energy intensity is the ratio between energy consumption in kWh and CUF's turnover in thousand euros (€k).

Scope: These targets are annual and apply to CUF's own operations and are transversal to all units.

Target type: Intensity-based targets.

Basis: The targets are based on increasing production and implementing improvement measures. There are no intermediate targets set, nor have there been any changes in 2024 to the value and year of the target, the calculation or data collection methodology, the assumptions, sources or limitations. No stakeholders were involved in setting the target.

Progress: Regarding the progress of these targets in 2023 and 2024, there has been a reduction in the energy intensity of the main consumptions. Comparing only existing units since 2023, the intensity of electricity and natural gas consumption has decreased by 9.04% and 15.95% respectively, reflecting CUF's efforts to optimise energy efficiency and sustainable resource management.

Vehicle Fleet Electrification Target

CUF has implemented initiatives to reduce CO2 emissions from employee travel, contributing to the company's decarbonisation process. The CUF fleet is related to one of the two KPIs in CUF's Sustainability-Linked Financing Framework.

Target: 40% electric or hybrid cars in its fleet by 2028.

Scope: This target applies to CUF's operations nationwide, with a focus on new acquisitions, whether by allocation or replacement of vehicles. The measure covers the entire employee fleet, with the exception of courier vehicles, whose transition to electric models will depend on the availability of options on the market with greater range. Service vehicles are all already electric.

Alignment: The implementation and monitoring of the adopted measures and targets promote continuous improvement and are directly aligned with CUF's commitments, as reflected in its Sustainability Policy, with an emphasis on reducing the ecological footprint. In this context, there is strategic convergence with the United Nations' Sustainable Development Goals (SDGs), in particular SDG 13 – Climate Action, which seeks to combat climate change and its impacts, and SDG 9 – Industry, Innovation and Infrastructure, which encourages the modernisation and adoption of sustainable practices in industrial infrastructures and processes.

Energy consumption and mix

CUF reported its energy consumption for 2024 under ESRS E1-5 (formerly E1-7), disaggregated by source and fuel type:

Energy production

In 2024, CUF produced photovoltaic energy on the premises of CUF Tejo Hospital:

Energy intensity

CUF reported energy intensity targets for 2025 with 2024 as base year:

Energy intensity is the ratio between energy consumption in kWh and CUF's turnover in thousand euros (€k).

Comparing only existing units since 2023, the intensity of electricity and natural gas consumption decreased by 9.04% and 15.95% respectively in 2024.

Methodology notes

Energy consumption from non-renewable sources includes all fossil fuels used (natural gas, enthalpy, petrol and diesel from vehicles), plus consumption of purchased electricity associated with fossil sources. Natural gas consumption was calculated by the energy supplier based on lower calorific value (LCV). Enthalpy (hot and chilled water in HVAC and domestic hot water circuits) is used exclusively at CUF Descobertas Hospital, CUF Alvalade Clinic and CUF Contact Centre.

Energy consumption from renewable sources includes electricity and heat purchased and consumed from renewable sources. Energy consumption is based on meter readings and/or invoices.

CUF notes it does not operate in any sector with a high climate impact and therefore does not report information specifically on energy intensity per high-impact sector.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1, 2 and 3 gross GHG emissions and total GHG emissions (tCO₂eq)

Biogenic GHG emissions (tCO₂eq)

Measurement Policies

Scope 1 and 2 emissions

In the Portuguese electricity emission factor (APA 2024) used to calculate scope 2 location-based emissions, it is not possible to segregate gross and biogenic emissions. Market-based values use emission factors from information provided by electricity suppliers in the units and from the supplier of charging stations for electric or plug-in hybrid vehicles.

CUF has 0.3% of its scope 2 emissions associated with a PPA in place on the photovoltaic panels at CUF Tejo Hospital, with the installation of more photovoltaic solar panels at other facilities associated with PPA planned for 2025.

Scope 3 emissions

CUF has adopted a structured approach to quantifying Scope 3 GHG emissions, considering specific methodologies for each category:

• Category 1 (Goods and services purchased): Generic emission factors were used, grouping together similar purchases.
• Category 2 (Capital goods): Calculated on the basis of available data.
• Category 3 (Energy-related activities): Only actual energy consumption data was used.
• Category 4 (Upstream transport and distribution): A proxy of 10% of the purchase value of goods was applied; for services of the main supplier, real data was used.
• Category 5 (Waste generated in operations): Reported using the Integrated Waste Registration Models.
• Category 6 (Business trips): Calculated taking into account the mode of travel and kilometres travelled.
• Category 7 (Employees' commutes): Estimated using internal questionnaires.
• Category 9 (Downstream transport and distribution): Data on donations of goods was taken into account, though with little material impact.
• Category 11 (Utilisation of Products Sold): Integrated in 2024, based on real data on inhalers used in CUF units, in line with international trends in the healthcare sector.
• Category 15 (Investment): Included data on José de Mello Residências' carbon footprint and consumption of Gamma Knife and GreenImolis equipment.

Categories 10 (Transformation of products sold), 12 (End-of-life treatment of products sold), 13 (Downstream leased assets) and 14 (Franchises) are not applicable to CUF, as it is a service company.

Emission Factors

CUF's corporate inventory was calculated using emission factors from: GHGP, IPCC, DEFRA (UK Department of the Environment), NIR2024 (National Emissions Inventory), Sustainability Reports and ADEME (French Environment and Energy Management Agency).

Emissions Intensity

GHG emissions intensity was calculated using total GHG emissions (scope 1 + scope 2 + scope 3) per million euros in net revenue, defined as the total net sales generated by CUF.

Biogenic emissions

The biogenic emissions considered in scope 1 are associated with the incorporation of biodiesel and bioethanol into the fleet. In the case of scope 3, they are associated with the transport of goods, transport associated with analyses, shuttles, commuting and business travel.

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

Use of phase-in exemption

For the first year of reporting, CUF has used phase-in provisions applicable to all entities under ESRS with regard to disclosures about the expected financial effects of material risks and opportunities under disclosure requirement E1-9.

Cross-reference in alignment table

The following disclosure requirements under ESRS E1-9 are referenced in CUF's alignment table with financial services regulations:

Policies related to water and marine resources

CUF discloses that responsible water management is paramount given its extensive use in hospital processes and water quality's crucial role in community safety. The company adopts policies promoting reduction of consumption, treatment of effluents and compliance with environmental regulations.

Sustainability Policy

Scope:

• Companies wholly owned, directly or indirectly, by CUF, S.A.
• Entities that provide services at CUF facilities and infrastructures
• The company also promotes the application of the principles among other participants in the value chain, namely suppliers and partners

Key content:

• Includes among its main commitments the "search for solutions that enable the efficient management of natural resources"
• Covers the use and supply of water in the company's own operations
• Promotes sustainable water consumption
• Applies to CUF operations in several areas of high water stress

Approval and oversight:

• The Executive Committee is responsible for approving the policy and its successive revisions

Monitoring:

• Monitoring and implementation of the policies differs according to their scope, with specificities indicated in the text of the respective policies

Additional information:

• More information on this policy available in chapter E1-2

Water Safety Plans

Scope:

• Adapted to the specific needs of each unit
• Companies wholly owned, directly or indirectly, by CUF, S.A.
• Entities that provide services at CUF facilities and infrastructures
• The company also promotes the application of the principles among other participants in the value chain, namely suppliers and partners

Key content:

• Ensure water quality and avoid waste
• Follow applicable Portuguese legislation on water, wastewater and legionella bacteria

Approval and oversight:

• Drawn up by the Hospitality Management and Maintenance Department, without the involvement of stakeholders
• Approved by CUF hospitals management
• The manager is responsible for ensuring the provision of healthcare and coordinating the areas that support the operation
• At a strategic level, the CEO ensures the implementation of a single operator model, promoting alignment, standardisation, operational control and risk management in all units
• The Executive Committee is responsible for approving the policies and their successive revisions

Availability:

• Made available internally via CUF's document management tool

Monitoring:

• Monitoring and implementation differs according to scope, with specificities indicated in the text of the respective policies

Actions and resources related to water

CUF mostly uses water purchased from the water and sewage utilities where it has its facilities, and some units also use rainwater harvesting. Water is used for human consumption, food preparation, cleaning of the premises and watering green spaces, among other purposes.

Recognising the importance of water as an essential and scarce resource, CUF implemented several improvements in 2024 to optimise its management.

Implementation of an Energy and Water Management Platform (SGE)

What it does: To ensure water quality and prevent/correct any excessive consumption.

Time horizon: Implemented in 2024; planned to deepen this initiative in 2025.

Scope: Applies across the board to all the company's units, including those located in areas of high water stress.

Resources allocated: Estimated investment of around €11,000.

Expected outcomes: Reduction of 1.7% in the use of water resources through better monitoring (expected for 2025).

Link to policy/target: This measure is in line with the commitments made in the Sustainability Policy and in the Water Safety Plans, thus promoting a more efficient use of natural resources.

Targets related to water

CUF's units are not water-intensive when compared to other industries. However, CUF is endeavouring to reduce its water consumption and go beyond what is legally required.

Water consumption intensity reduction target

Monitoring: Progress is monitored every six months to assess whether annual objectives are being met.

Target methodology: No scientific scenarios or predictive models were adopted. No changes have been made to the target value, application period, calculation methodology, data sources or other assumptions. Target was set internally without consulting external stakeholders.

Water consumption

CUF uses water in various processes essential to its operation, including sanitisation, sterilisation and customer care, ensuring high standards of quality and safety.

Water sources and discharge destinations

CUF mostly uses water purchased from the water and sewage utilities where it has its facilities, and some units also use rainwater harvesting. Water is used for human consumption, food preparation, cleaning of the premises and watering green spaces, among other purposes.

Water reuse achievements

From March 2023 to December 2024, CUF managed to reuse 4,279 m³ of water from osmosis rejects. The company implemented water reuse measures in the sterilisation processes for medical devices, saving 2,500 m³ of water through a project that received international recognition. The volume of water reused from osmosis in 2024 was approximately 2,500 m³, which corresponds to around 7.5% of the total consumed in that period.

Measurement methodology

CUF uses estimates to quantify water consumption, since it does not have water discharge meters. The volume of water consumed is calculated based on extrapolations from the data provided by its largest supplier, which accounts for 50% of CUF's supply. This supplier estimates that 90% of the water supplied returns to the system, while 10% corresponds to actual consumption. The same estimate was applied to the rest of CUF's consumption.

Total water consumption in water risk areas concerns water consumption at facilities located in regions of high and extremely high water risk. These facilities were identified based on the methodology of Aqueduct tool Water Risk Atlas 4.0 from the World Resources Institute (WRI).

Water intensity was calculated using total water consumption per million euros in net revenue. The metrics were not validated by an external entity.

Policies related to resource use and circular economy

CUF adopts policies and practices for managing the impacts, risks and opportunities related to waste production and has promoted awareness of the global increase in waste recovery in its network.

This commitment is reflected in two internal policies:

Sustainability Policy

• Key content/principles: Commitment to "finding solutions that allow natural resources to be managed efficiently"
• Public availability: More detailed information can be found in chapter E1-2
• Note: Does not directly address the transition from the use of virgin resources or the sustainable sourcing and use of renewable resources

Quality, Environment and Safety Policy

• Key content/principles: Objective of "reducing, reusing and recycling the waste produced"
• Public availability: More detailed information can be found in chapter E1-2
• Note: Does not directly address the transition from the use of virgin resources or the sustainable sourcing and use of renewable resources

Waste Management Programme

• Scope: Applied to CUF's own operations; directly covers CUF employees, partners and suppliers in the area of waste
• Governance: Responsibility for implementation is assigned to the Hospitality Management and the Engineering and Maintenance areas (highest level)
• Key content/principles:
  • Establishing a strategy to minimise the environmental impact of waste produced at CUF units, reducing its production and recovery
  • Establishing processes and procedures for managing, sorting, depositing, storing and transporting waste within CUF units
  • Identifying and classifying all types of waste originating from the activity and produced within CUF units
  • Identifying all processes and legal procedures for correct packaging, transport, treatment and reporting of waste
  • Establishing contractualisation and supervision requirements for companies responsible for collection, external transport, treatment and final destination of waste
  • Addressing preparation for reuse, recycling and disposal
  • Implementing processes for reuse and recovery (recycling) of undifferentiated waste in units whenever possible
• Alignment: Developed in alignment with legislation in force, applicable standards and recommendations, and opinions of the Programme for the Prevention and Control of Infections and Antimicrobial Resistance
• Public availability: Made available to stakeholders via CUF's document management platform
• Monitoring: CUF identifies and evaluates activities that cause or could cause significant impacts on waste production. Hazardous hospital waste (groups III and IV) is assessed and monitored to avoid contamination. A process flow covering waste inputs, activities and outputs is implemented to optimise waste management throughout the value chain, guaranteeing safety and environmental compliance. Waste is disposed of by certified entities, complying with all applicable standards and legislation.

Actions and resources related to circular economy

CUF aims to be increasingly more responsible with regard to hazardous and non-hazardous waste management. In an effort to reduce production and promote the correct treatment of this waste, the company has implemented circular economy projects.

Responsibility: Implementation of policies and the Waste Management Programme is assigned to the Hospitality Management and the Engineering and Maintenance areas.

BioSystem Project

• Description: System for managing the use of containers to enable a reduction in their number, as well as in the number of collections and the waste associated with logistics packaging
• Timeline: Began implementation in 2023; completion expected by 2025, with results to be determined by end of year
• Scope: All hospitals except CUF Sintra Hospital and CUF Açores Hospital (which still have residual production)
• Link to policy: Related to application of circular business practices and contributes to Sustainability Policy and Waste Management Programme commitments to "establish a strategy to minimise the environmental impact of the waste produced at CUF units, reducing its production and recovery"

Reuse of aluminium anaesthetic bottles

• Description: Waste sorted and collected from units and delivered for recovery
• Timeline: Began in 2022 at national level; in 2024 implemented in two new units (CUF Descobertas Hospital and CUF Almada Clinic)
• Scope: Now present in seven units
• Outcome: Resulted in recovery of equivalent of 50 kg of waste in 2024

Non-woven Fabric (TNT) Project

• Description: Recycling fabric from packaging of surgical boxes, as part of Second Chance pilot project. CUF hospitals donate products (blankets and bed covers) to social economy entities for homeless people and elderly people in Residential Structures for the Elderly
• Timeline: Started in 2022
• Partnerships: Partners ENTRAJUDA and SecondChance
• Scope: In 2024 involves six units: CUF Tejo Hospital, CUF Descobertas Hospital, CUF Sintra Hospital, CUF Santarém Hospital, CUF Viseu Hospital and CUF Almada Clinic
• Outcome: Resulted in delivery of 3,850 kg of material in 2024

Nãm Project

• Description: Reusing coffee grounds from vending machines at CUF units and Corporate Centres for organic fertiliser used in mushroom production
• Partnerships: Developed in partnership with the coffee supplier
• Scope: CUF units and Corporate Centres

Project for the reuse of plastics from group III waste

• Status: Still in exploratory phase
• Timeline: Should be implemented in medium term
• Scope: Will cover all CUF hospitals nationwide
• Partnerships: In partnership with two waste management companies
• Expected outcome: Will enable a percentage of PVC waste to be diverted from landfill to recycling, helping to reduce CUF's environmental footprint

Local Group III waste treatment system at CUF Açores Hospital

• Status: Under analysis
• Description: Local system for treating Group III waste, based on shredding by rotating blades and microwave heat treatment
• Expected outcome: Could significantly reduce indirect emissions associated with road and sea transport of waste (currently sent to Terceira Island for reprocessing and landfill). System transforms hazardous waste into solid urban waste, allowing safe disposal and potential use as fuel in industrial furnaces
• Scope: CUF Açores Hospital

Monitoring

All actions monitored through local monitoring at each unit, by counting and recording quantities (of containers, bottles and non-woven fabric).

Targets related to circular economy

CUF does not yet have targets relating to resource utilisation and the circular economy. However, it monitors the effectiveness of its policies and actions regarding this issue through local monitoring at each unit, by counting and recording quantities (of containers, bottles and non-woven fabric).

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

Phase-in provision applied

For the first year of reporting, CUF has applied the phase-in provision with regard to disclosures about the expected financial effects of material risks and opportunities under disclosure requirement E5-6.

No quantified anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities are disclosed in this reporting period due to the application of this phase-in exemption.

Waste

Waste characterisation is a fundamental process for understanding the profile of waste, enabling the implementation of more efficient strategies for its management, reduction and reuse. Furthermore, this analysis contributes to compliance with environmental legislation, as well as to the definition of sustainable practices aimed at minimising negative impacts on the environment and optimising resources within CUF.

Hospital waste is CUF's main waste stream, which is broken down into:

• Non-Hazardous Hospital Waste (includes Groups I and II):

  • Group I (Municipal Waste) – Example: waste from general services such as offices, meeting rooms, lounges, toilets, changing rooms, etc.
  • Group II (Non-Hazardous Hospital Waste) – Example: orthopaedic material: splints, plasters and plaster bandages that are not contaminated and have no traces of blood, nappies and nappy covers that are not contaminated and have no traces of blood, empty packaging for medicines (vials, blisters, etc.), products for clinical or common use with the exception of those included in Group III and IV.

• Hazardous Hospital Waste (includes Groups III and IV)

  • Group III (Biohazardous Hospital Waste) – Example: all contaminated waste from infectious or suspected infectious patients' rooms or wards, haemodialysis units, operating theatres, treatment rooms, autopsy and pathological anatomy rooms.
  • Group IV (Specific Risk Hospital Waste) – Example: identifiable anatomical parts (amputations), foetuses and placentas, instead of cutting and piercing materials, discarded chemicals and drugs, cytostatics and all the material used in their handling and administration.

Of all the waste produced by CUF, and according to the codes on the European Waste List (EWL), the most relevant classifications are as follows:

• 18 01 03 – Waste whose collection and disposal is subject to special requirements in order to prevent infection (Group III).
• 18 01 01 – Sharp and piercing objects (Group IV).
• 18 01 03 – Waste whose collection and disposal is subject to special requirements in order to prevent infection (Group IV).
• 18 01 07 – Chemical products other than those mentioned in 18 01 06 (Group IV).
• 18 01 08 – Cytotoxic and cytostatic medicines (Group IV).
• 18 01 09 – Medicines other than those mentioned in 18 01 08 – narcotic drugs (Group IV).
• 18 01 09 – Medicines other than those mentioned in 18 01 08 (Group IV).
• 07 06 03 – Organic halogenated solvents, washing liquids and mother liquors.
• 07 06 04 – Non-halogenated solutions or solvents.

CUF has established internal processes to collect and monitor waste-related data. Since 2021, the data collected has been processed in each unit and compared with each other to identify best practices and implement them across the board.

In 2024, CUF generated the following quantities of waste:

Note: Waste from Corporate Centres and Contact Centres, which are located in business parks and whose management does not allow the waste generated to be segregated, was excluded from these calculations.

Of all the waste produced by CUF in 2024, around 2,815.6 tonnes will not be recycled (which corresponds to 87% of the total).

Measurement Policies

Some of CUF's units use radioactive materials for prostate brachytherapy and Nuclear Medicine. The radioactive waste generated is stored for four years in suitable containers on sites duly licenced for the purpose, until it decays (no longer shows radiation) and can be disposed of as ordinary waste duly classified according to the type of waste (sharp, biologically contaminated, among others). In this sense, the radioactive waste produced is not sent outside the CUF facilities with radiation, but is accounted for in the quantities of total waste.

The quantity of hazardous waste is obtained by recording the weighing of collected containers. In the units where non-hazardous waste is collected by local councils, the quantities are estimated taking into account the containers and collection periods.

Policies related to own workforce

CUF has disclosed multiple policies related to its own workforce under ESRS S1-1. These policies are managed by various departments and approved by the Board of Directors, with availability on the company's intranet and, in some cases, on CUF's website. They apply to all CUF employees.

Code of Conduct

Scope: All employees, regardless of employment relationship type or hierarchical position

Approval and oversight: Drawn up and monitored by the Code of Conduct Monitoring Committee; ultimately under responsibility of the Executive Committee

Key content: Addresses respect for fundamental rights, teamwork, integrity and loyalty to the company, active collaboration, career path, health and well-being, reconciliation of personal and professional lives, prevention of corruption, harassment in the workplace, and environmental responsibility. Relates to the Code of Ethics requiring all professionals to know and respect the Declaration of Human Rights (UN, 1950), the Convention for the Protection of Human Rights and Fundamental Freedoms, and the Convention for the Protection of Human Rights and Human Dignity.

Public availability: Available on CUF website and intranet

International standards linkage: Links to the Code of Ethics which implies compliance with:

• Declaration of Human Rights (UN, 1950)
• Convention for the Safeguarding of Human Rights and Fundamental Freedoms
• Convention for the Protection of Human Rights and Human Dignity
• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• ILO Declaration on Fundamental Principles and Rights at Work
• International Bill of Human Rights

Monitoring: Code of Conduct Monitoring Committee is responsible for promoting dissemination, application and compliance; monitoring implementation through an appropriate internal control system; preparing implementation policies; promoting training actions; proposing changes to the Board of Directors; monitoring and clarifying doubts; receiving and managing communications and complaints sent to codigodeconduta@cuf.pt; and reporting periodically to the Executive Committee

Employee Data Privacy Policy

Scope: All employees

Approval and oversight: Drawn up by the Data Protection Officer; implemented under responsibility of the Executive Committee

Key content: Ensures protection of employees' personal data in accordance with GDPR. Part of the Data Protection Governance Model (POL.0149).

International standards linkage: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation – GDPR)

Public availability: Available on intranet

Family-Responsible Company Certification (FRC)

Scope: All employees across entire CUF universe

Approval and oversight: Executive Committee

Key content: Includes measures relating to job quality, time and space flexibility, support for employees' families, personal and professional development, and equal opportunities

International standards linkage: Complies with FRC 1000 Standard

Public availability: Certification awarded by Fundación Más Familia (renewed in 2024 with score increase from C to C+)

Policy for Promoting Reconciliation between personal, family and professional lives

Scope: All CUF employees

Approval and oversight: Managed by People Management Department; ultimately approved by Executive Committee

Key content: Defines guiding principles for reconciling personal and professional lives to create better balance between demands of permanent healthcare provision activity and human development of employees

Public availability: Available on intranet

Policy to Make Work More Flexible through Remote Working

Scope: All employees

Approval and oversight: People Management Department and Executive Committee

Key content: Establishes guiding principles for adopting more adapted work organisation models to promote flexibility, motivation and productivity. Allows employees to work up to two days per week away from CUF premises.

Public availability: Available on intranet

Training Management Policy

Scope: All employees

Approval and oversight: People Management Department; CUF Academic Centre responsible for implementation

Key content: Supports development of skills, differentiation and valuation of employees through qualified training in healthcare area. Considered a critical success factor representing company value of Human Development.

Public availability: Available on intranet

Policy for the Prevention and Management of Harassment in the Workplace

Scope: All employees

Approval and oversight: Managed by People Management Department in close liaison with Code of Conduct Monitoring Committee

Key content: Establishes measures to ensure organizational climate that guarantees dignity and fairness among all employees. CUF does not tolerate discrimination of any kind based on race, ethnic origin, ability/disability, gender, sexual orientation, family situation, age, nationality, territory of origin, religion, party or trade union association.

Public availability: Available on intranet; detailed procedures available in G1 chapter

Human Resources Management Policy

Scope: All employees

Approval and oversight: People Management Department

Key content: Addresses strategic guidelines based on four strategic axes: attracting talent (e.g., Trainee "+Talent" Programme); facilitating integration of new employees through welcoming and training sessions; listening to organizational climate through satisfaction questionnaires; developing skills and promoting professional growth; facilitating career management with new professional challenges.

Public availability: Available on intranet

Recruitment and Selection Process

Scope: External recruitment activities

Approval and oversight: People Management Department

Key content: Regulates external recruitment and selection process, describing different stages and standardizing methodology to improve recruitment quality and enable monitoring

Public availability: Available on intranet

Internal Recruitment Procedure

Scope: Internal recruitment activities for all employees

Approval and oversight: People Management Department

Key content: Guarantees principles ensuring compliance with demand, transparency and rigour in internal recruitment. Methodology identifies candidates within CUF capable of satisfying company needs for new jobs or replacements, supporting employee career development perspectives.

Public availability: Available on intranet

CUF Retributive Policy

Scope: All employees

Approval and oversight: Board of Directors; People Management Department

Key content: Provides guidelines on remuneration ensuring company sustainability. Based on market reference studies available in Portugal used as comparative criteria when setting remuneration. Board of Directors may award occasional bonuses mainly based on collective performance.

Public availability: Available on intranet

Management and Performance Evaluation Policy

Scope: All employees

Approval and oversight: People Management Department

Key content: Defines guidelines supporting integrated management of employees, supporting development, management and recognition of performance. Meritocracy system rewards employees based on performance to boost motivation and retention.

Public availability: Available on intranet

Employee Health and Safety Policy

Scope: All employees (100% of salaried employees and 47% of non-salaried employees for occupational medicine)

Approval and oversight: People Management Department

Key content: Ensures occupational health and safety coverage. Safety management system covers all employees including salaried and non-salaried.

Public availability: Available on intranet

Sustainability Policy

Scope: All CUF operations

Approval and oversight: Developed and published September 2023; overseen by Innovation and Sustainability Committee with representatives from Board of Directors; Chief Executive Officer has primary responsibility; Corporate Citizenship Department (reporting to CEO) responsible for defining and developing sustainability strategy

Key content: Public affirmation consolidated in 11 ESG commitments in environmental, social and governance spheres, assessed annually in integrated approach. Includes commitments related to own workforce such as contribution to sustainable development of communities, establishment of contracts only with entities sharing CUF's principles and ethical values.

Public availability: Published on CUF website (September 2023)

International standards linkage: Links to human rights commitments aligned with UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, and ILO fundamental conventions

Quality, Environment and Safety Policy

Scope: All operations; applies to companies fully owned directly or indirectly by CUF, S.A.

Approval and oversight: Developed by Quality and Safety Department; Executive Committee approval

Key content: Reflects respect for sustainable development principles; includes identification of environmental aspects and impacts; promotion of sustainable use of natural resources including energy and water, pollution prevention and reduction, reuse and recycling of waste generated

Public availability: Available on intranet

International standards linkage: Developed in accordance with international standard ISO 9001

Fleet Management Policy

Scope: All employees who use company fleet

Approval and oversight: Drawn up by People Management Department and Means and Assets Department; final approval by Executive Committee

Key content: Contains commitment to sustainability; minimizes environmental impact by choosing more efficient vehicle makes and models; ensures and optimizes electrical infrastructures for employees and clients

Public availability: Available on CUF intranet; sent individually to each employee who uses fleet

Risk Management Policy

Scope: All operations

Approval and oversight: Risk Management Department; overseen by Risk Auditing and Management Committee

Key content: Follows COSO guidelines, ISO 31000 Risk Management, and IIA three lines of defense model. Establishes integrated risk management structure ensuring identification of risks and opportunities, definition of response strategies. Risk Dictionary includes risks related to internal fraud and external fraud.

International standards linkage: COSO (Committee of Sponsoring Organizations of the Treadway Commission), ISO 31000, Institute of Internal Audit (IIA) model

Monitoring: Risk Management Department monitors risks; periodic meetings with Executive Committee for detailed analysis and corrective action decisions

Taking action on material impacts on own workforce

Equal Treatment and Opportunities for All

Scope: Own Operations and Downstream Value Chain

Description: CUF promotes positive impacts on its employees by continuous reinforcement of its diversity, equity and inclusion initiatives, ensuring that every employee can contribute, feel part of the organization and that is an attractive place to come to work.

Adaptation of jobs for people with disabilities

Time horizon: 2024 (implemented)

Scope: All CUF units (Own Operations)

Description: Adaptation of jobs for people with disabilities before the start of their duties in all CUF units. Appropriate adjustments to the space (equipment or work tools) to eliminate physical and technological barriers and create a more inclusive and accessible environment.

Outcomes: This initiative enabled better adaptation to the job and resulted in a higher success rate in hiring and retention. More than 30 people with disabilities were hired in 2024.

Inclusion Scholarships

Scope: Own Operations

Description: CUF provides support towards the costs of social, educational or training responses for inclusion, relating to the children/dependents of CUF employees with disabilities, in order to contribute to their inclusion.

Resources (non-financial): Partnerships with social economy entities contributing to social causes that improve the lives of people with specific needs.

Work-life balance measures

Scope: All CUF employees (Own Operations)

Description: Wide range of measures including:

• Extension of the gestational bereavement period to five consecutive days (vs. three days legally provided)
• Time off on the first day of school, kindergarten or nursery for employees with children up to the 1st year of primary school, with extension to the 5th year for children with special educational needs and up to the 12th year for children with multi-purpose medical certificate of over 60%
• Access to a 7-seater car for employees with a working car, whose immediate family is made up of more than 5 people
• Creation of social activities for employees such as festive events and sports tournaments
• More partnerships with offers and/or discounts for employees, especially in "Sports", "Health and well-being" and "Education and school vacations"

Link to policy: Policy to promote reconciliation between personal, family and professional lives; Family-Responsible Company Certification (FRC) - renewed in 2024 with increase from C to C+

CUF Inspira Program

Scope: Own Operations

Description: Support to employees and their families including:

• Gift to celebrate the birth of employees' children and grandchildren, with a savings account
• Contribution to the payment of birth costs of employees' children whose clinical act has taken place in a CUF unit
• Contribution to the payment of expenses associated with leisure activities for employees' dependents during school holidays in summer months, with increase for disabled dependents
• Support for the cost of school materials for each child of compulsory school age (€60)
• Award of scholarships to employees attending higher education
• Award of scholarships to employees' children obtaining Bachelor's or Master's degree
• Creation of an Employee Support Network for employees and their families, with free consultations/sessions in psychology, finance, legal support, social counselling, coaching, retirement, domestic violence, among others

Training and Skills Development

Scope: Own Operations

Description: CUF Academic Centre manages comprehensive training programmes ensuring employees remain prepared for demands of the healthcare sector.

Mandatory training

Platform: SIGA (Integrated Learning Management System)

Description: Series of mandatory training courses for each Professional Group covering company values, culture and legally binding programmes.

Medical Training

Description:

• Undergraduate: Partnerships with educational establishments to receive medical students, creating specific programmes
• Postgraduate: Courses with and without simulation with high level of technicality; streamlines process of granting suitability for postgraduate teaching with possibility of undertaking Medical Internship at CUF units

Nursing Training

Description: Development and improvement of skills of professionals in Nursing Care Area (AAE), through training programmes based on best practices, nursing reference framework and CUF values.

Life Training Centre

Description: Provides CUF employees with technical skills to carry out high-quality cardiopulmonary resuscitation manoeuvres.

Research and Innovation

Resources (financial): Doctoral scholarships and grants for publication of scientific articles

Description: Encourages research by employees. In 2024, developed 133 clinical trials and observational studies.

ForMe Programme

Resources (financial): Financial support for external training identified by employees

Description: Contributes to professional development of employees.

Future Training Actions (planned)

E-learning training "Unconscious Biases"

Time horizon: Implementation in 2025

Target: All managers by end of 2025

Description: Training designed to enable managers and employees to identify and understand automatic judgements that influence decisions and behaviour in the workplace. Developed in 2024.

Leadership Training for Middle Management

Time horizon: Start in 2025

Participants: Around 75 professionals

Description: Creation of a Leadership Academy ("Leadership Academy") to consolidate and streamline access to training experiences. Programme designed and adjusted to internal needs to empower the way people lead and collaborate, implement culture of rigour and concern for well-being of employees, fostering more agile and effective organisation.

Working Conditions and Health & Safety

Scope: Own Operations

Description: CUF recognises negative impacts associated with shift work. To mitigate these impacts:

Prevention and Well-being Programme

Description: Focused on employees' physical and mental health, including medical monitoring and health insurance.

Link to policy: Occupational Health Service works to prevent occupational illnesses and mitigate psychosocial risks.

Mechanisms: Event reporting platform allowing employees to report labour risks, incidents and dangerous situations anonymously. Reports analysed by Occupational Safety team, which implements corrective measures.

2024 Specific Actions

Study on stress and burnout

Scope: CUF Torres Vedras Hospital and CUF Santarém Hospital

Description: Detailed assessment to find out about stress and burnout to better intervene with focus on promoting health and well-being of hospital staff.

Study on psychosocial factors

Scope: CUF Cascais Hospital and CUF Tejo Hospital

Description: Sessions held with focus groups, ensuring participation of employees in identifying challenges and formulating solutions to improve working environment.

Special prices for medical procedures at CUF

Description: Price list similar to +CUF Plan available to all employees and their families (including parents of employees). No membership costs, no usage limit and no minimum seniority.

Annual consultation on Occupational Health and Safety

Scope: All employees

Health and safety campaigns

Resources (financial): Operating costs of approximately €43,630 in 2024 (included under Inventories in Consolidated Financial Statements, Note 27)

Description: Prevention of wounds caused by perforating medical devices (aimed at doctors and nurses) and extension of seasonal flu vaccination to all employees, regardless of contractual relationship.

Talent Management and Retention

Approach: Internal recruitment prioritised - vacancies first made available to employees before being advertised externally.

Description: Strengthens talent retention and values internal growth of team.

Sustainable Transition

Description: Promoting continuous training and retraining, enabling employees to keep up with demands of environmental and technological practices.

Targets related to own workforce

1. Training for middle management

• Target metric: Percentage of employees in functional group of leaders and managers (excluding clinical coordinators and nursing managers) completing training
• Target value: 100% completion
• Target year: 2026
• Intermediate target: 40% by 2025
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own operations - functional group of leaders and managers (measured in Full-Time Equivalent)
• Type: Absolute
• Validation: Internally structured training developed by CUF Academic Centre in collaboration with People Management Department, implemented through partnership with Nova Business School
• Progress: Implementation ongoing in 2024

2. Succession plans for corporate officers

• Target metric: Development and implementation of succession plans for corporate officers
• Target value: Drafting of plans completed; implementation of development programmes to start
• Target year: Drafting completed by 2025; implementation starts 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own operations - corporate officers/top leadership
• Type: Qualitative target
• Validation: Methodology established by Executive Committee in conjunction with José de Mello
• Progress: Criteria defined; conversations held with potential successors in 2024

3. Restructuring role of clinical coordinator (doctor)

• Target metric: Percentage of clinical coordinators with formalized mandates under new contract structure
• Target value: 100%
• Target year: 2027
• Intermediate targets:
  • 20% by end of 2025 (contract structure defined in 2025)
  • 70% by 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own operations - clinical coordinators (doctors)
• Type: Absolute
• Validation: Internal; developed with contribution from healthcare unit teams and debated with CUF Medical Council
• Progress: Plan under development in 2024

4. Artificial Intelligence - retraining programme

• Target metric: Percentage of affected employees retrained for AI impact
• Target value: 100% of people affected retrained
• Target year: 2027
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own operations - functions affected by artificial intelligence, with particular focus on administrative services
• Type: Absolute
• Validation: Internal; CUF Academic Centre developing market consultation
• Progress: Diagnosis of affected functions planned for 2025; retraining to begin 2026

5. Review of conditions and remuneration

• Target metric: Not fully specified in excerpt
• Target value: Not disclosed
• Target year: Not disclosed
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own operations - team retention
• Type: Not specified
• Validation: Internal
• Progress: Target implemented (excerpt ends mid-sentence)

Characteristics of the undertaking's employees

Total headcount and FTE

CUF ended 2024 with 7,862 employees, 84% of whom were female.

Headcount by region

As CUF is a company that operates exclusively in Portugal, its employees also work only in the country, spread between the mainland and the islands.

Headcount by gender, contract type and employment type (2024)

(*) Gender specified by the employees themselves

Note: The value 24,421 for total full-time employees appears to be a data error in the original source, as it does not match the sum of female and male employees.

Headcount by region and contract/employment type (2024)

Employee turnover

In 2024, 1,043 people left CUF, giving rise to an employee turnover rate of 14%. The denominator for this rate corresponds to the average of the Headcount using the start of the period (December 2023) and the end of the period (December 2024).

Non-salaried employees

The number of employees reported was calculated by counting TINs with employment contracts exclusively for self-employed service providers and clinical acts, exported from the database with reference to 31 December 2024. This figure does not include service providers with companies.

Measurement policies

All the data presented corresponds to real data that was exported from the CUF database on 31 December 2024. This information was exported by employee, by type of contract and company for all individual labour contracts, regardless of workload, and then compiled using a dynamic table.

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

Non-salaried employees in the company's workforce

Measurement Policies

The number of employees reported was calculated by counting TINs with employment contracts exclusively for self-employed service providers and clinical acts, and the number was exported from the database with reference to 31 December 2024. This figure does not include service providers with companies.

Collective bargaining coverage and social dialogue

92% of CUF employees are covered by collective bargaining agreements and social dialogue, falling within the range of between 80% and 100% of the coverage rate shown in the table below. All employees work in Portugal territory.

Coverage rates

Employees who are not covered by collective labour agreements are subject to CUF's Remuneration Policy, which is defined in accordance with Portuguese legislation and the principles of internal equity that guide CUF. This policy is also aligned with market benchmarks, measured through salary studies.

Diversity metrics

Age band distribution of total workforce

Gender split at senior management level

Note: Senior Managers and top management, who are the first and second line in CUF's structure, were considered.

Adequate wages

S1-10

Benchmark used: CUF does not apply a living wage benchmark. The company states:

"For the purposes of this report, an adequate salary is considered to be one that complies with the applicable collective bargaining agreements and Portuguese labour legislation, namely that which protects minors and people with disabilities."

Coverage: CUF reports that all employees receive an adequate salary as defined by compliance with collective bargaining agreements and Portuguese labour legislation.

"It is therefore our understanding that all CUF employees receive an adequate salary."

No percentage figures or assessment methodology against a living wage benchmark are provided.

Geographic scope: Portugal only. CUF states it "only operates in Portugal" in the context of social protection disclosures.

Targets and commitments: No forward-looking targets or commitments to implement living wage benchmarks are disclosed.

Methodology: No methodology for assessing wages against living wage standards is disclosed. The company relies on compliance with collective bargaining agreements and national labour law.

Social protection

CUF only operates in Portugal, where all employees are registered with Social Security and therefore benefit from social protection.

Additional context on retirement pension benefits

The subsidiary Hospital CUF Tejo, S.A. has the liability of topping-up the retirement pensions of some of its employees with whom this liability was agreed. According to the valuation report prepared by CFPO Consulting – Soluções Atuariais e Financeiras, as of the statement of financial position date:

Scheme type: Public scheme (Social Security) for all employees; private supplementary scheme (pension top-up) for specific legacy employees at Hospital CUF Tejo.

Coverage: 100% of employees covered by public social protection through Social Security registration in Portugal.

Measurement policy: The pension top-up liability is evaluated using the Projected Unit Credit method with a 3.00% discount rate (2024 and 2023) and LF 88/90 mortality tables.

Persons with disabilities

Employees with disabilities

Methodology: The data was exported with reference to 31 December 2024 and includes all employees with a disability of 60% or more.

Qualitative initiatives

CUF has implemented workplace adjustments (equipment and work tools) to eliminate physical and technological barriers and create a more inclusive and accessible environment, resulting in higher success rates in hiring and retention of professionals with disabilities.

CUF launched Inclusion Scholarships, providing support towards the costs of social, educational or training responses for inclusion relating to the children/dependents of CUF employees with disabilities.

In 2024, CUF hired more than 30 people with disabilities.

Training and skills development metrics

Training hours

Overall: 120,000 hours of training (more than 120,000 hours of training mentioned in the report)

Average training hours per employee:

Performance and career development reviews

Methodology note: In 2024, 81% of salaried employees had received a performance appraisal. On December 31, 2024, employees with less than 6 months' seniority and employees from the acquisition of Clínica Médica Arrifana de Sousa, SA were not included in the performance appraisal cycle. Non-salaried employees do not take part in performance appraisal processes.

Total investment in training

Not disclosed.

Health and safety metrics

Coverage of health and safety management system

100% of CUF employees are covered by the health and safety management system. Coverage extends to all salaried and non-salaried employees under the safety management system. In the area of occupational medicine (health), coverage extends to 100% of salaried employees and 47% of non-salaried employees.

Fatalities

There were no fatalities related to occupational diseases or accidents in 2024.

Work-related accidents and injury rate

Work-related illnesses

Days lost

8,481 days lost due to work-related injuries/accidents were recorded among salaried employees in 2024.

Measurement methodology

CUF estimated the number of hours worked based on the following formula: hours per week × FTE count × 48 weeks. This estimate resulted in a total of 14,246,681 hours worked.

Work-life balance metrics

100% of CUF employees are entitled to family leave, with 20% of them taking advantage of this right in 2024.

Measurement note: These figures exclude the employees of the companies belonging to the new group of units acquired from Clínica Médica Arrifana de Sousa, SA, as it was impossible to obtain data.

No return-to-work rates after parental leave are disclosed.

Compensation metrics

Pay gap

CUF discloses the gender pay gap on an unadjusted basis, calculated by professional category:

*includes Governing Bodies.

Remuneration ratio

The ratio of CUF's total annual remuneration between the highest paid individual, including the governing bodies, and the median of all employees excluding the highest paid individual is 35.0 in 2024.

Methodology

To calculate the disparity between men's and women's salaries, the governing bodies and the annual base salaries of active employees on 31 December 2024 were taken into account, with reference to a 40-hour workload.

The formula for calculating the gender pay gap was:

D = ((Average salary level of male employees - Average salary level of female employees) / Average salary level of female employees) x 100%

The Gender Pay Gap is an indicator influenced by several factors, including the existing job structure and the distribution of CUF employees by different levels of qualification and seniority in the job.

To calculate the annual total remuneration ratio, the theoretical fixed and variable remuneration of active employees on 31 December 2024 was taken into account.

All the metrics presented were drawn up internally without external validation.

No phase-in provisions were used for S1-16 disclosures.

Incidents, complaints and severe human rights impacts

In 2024, no incidents of work-related discrimination were identified. However, 29 complaints were filed by employees for alleged harassment at work. Some of these complaints did not provide a factual description compatible with the harassment scenario, so they did not result in investigation procedures. As for the complaints that were the subject of investigation procedures, none of them proved that harassment had taken place.

CUF is not aware of any serious human rights incidents related to the company's own labour.

Grievance mechanism

CUF has a Whistleblowing Channel, created by the company, which is available on CUF's intranet and website, for all employees, and which ensures the confidentiality of the information reported, as well as the employee's anonymity. The management of the Whistleblowing Channel, namely the receipt and forwarding of reports of concerns or offences, is the responsibility of the Internal Audit Department. Any complaints that fall into the category of incidents of discrimination and harassment are forwarded to the Legal Consulting Department.

The whistleblower submits the complaint using the form available on the CUF website, whether or not they can identify themselves. The status of the process of analysing the complaint is updated automatically, on the website and via email, which allows whistleblowers to follow the process.

In addition to the Whistleblowing Channel, CUF has e-mail addresses where employees can send their concerns, questions, complaints and suggestions: denuncia.assedio@cuf.pt, codigodeconduta@cuf.pt and apoio.social@cuf.pt.

In the process of processing and analysing the complaints received, CUF ensures confidentiality, data protection, secrecy and the absence of conflicts of interest. In any situation, the whistleblower and the witnesses are protected against any form of retaliation, and the ability to submit an anonymous complaint is provided, in accordance with the law.

Policies related to value chain workers

CUF has one policy addressing value chain workers.

Code for Service Providers, Suppliers and Partners

Scope:

• Applies to CUF's upstream value chain
• Transversal application to all locations where suppliers operate

Key content and principles:

The Code includes Article 3 on "Labour Practices and Human Rights":

• Commitment to human rights and equal opportunities at work
• Alignment with OECD guidelines
• Compliance with labour legislation applicable in Portugal and countries where suppliers operate
• Prevention of harassment (sexual, bullying, etc.), coercion (physical or moral), discrimination (race, colour, sex, religion, nationality, age, disability, political affiliation, union membership, pregnancy, marital status, sexual orientation, etc.)
• Prohibition of forced labour and child labour
• Provision of safe and healthy working environment
• Integration of good health and safety management practices
• Mitigation measures for occupational accidents
• Respect for workers' rights to freedom of association and collective bargaining

Public availability:

• Available to all stakeholders via CUF's website

Links to international standards:

• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• Principles and rights set out in the eight fundamental conventions identified in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work
• International Bill of Human Rights

Monitoring and enforcement:

• If situations of non-compliance are detected, measures are implemented to mitigate their occurrence
• In the most serious cases, CUF will take appropriate measures, such as terminating the partnership contract
• To date, no cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises have been reported in CUF's upstream and downstream value chain
• In 2024, an improvement was implemented in the supplier management process, reinforcing the application of sustainability criteria in selection, assessment and monitoring of suppliers through an ESG questionnaire

Taking action on material impacts on value chain workers

CUF recognises the importance of promoting fair, safe and dignified conditions for all workers throughout its value chain. The company implements actions and initiatives aimed at protecting labour rights, worker welfare and promoting responsible practices to ensure compliance with ethical and legal standards.

Actions implemented during 2024

1. Acquired new supplier management platform to identify and assess ESG risks

• Scope: Upstream value chain (national level)
• Resources allocated: €40,000 to €50,000 per year for platform maintenance, included under External Supplies and Services in the Consolidated Financial Statements (OpEx)
• Outcomes: More than 40% of CUF's suppliers registered in just three months. Provides more objective and systematic analysis of all suppliers through comparison based on predefined criteria (certifications, market experience, production capacity, ESG compliance)
• Link to policy: Contributes to CUF's commitment to establish relationships only with suppliers and partners who maintain high standards of ethical conduct and share the same ethical principles and values

2. Revision of the Code for Service Providers, Suppliers and Partners

• Scope: Upstream value chain (national level)
• Time horizon: Revision completed end of 2024, implementation planned for 2025
• Resources: Own resources allocated to operating expenses (OpEx)
• Link to policy: Aligned with CUF's values and ESG principles

3. Review of the Supplier Management Process

• Scope: Upstream value chain (national level)
• Time horizon: Revision completed end of 2024, implementation planned for 2025
• Purpose: Define procedures, criteria and responsibilities associated with supplier management in qualification, selection and monitoring activities to ensure suppliers can provide products and services in accordance with CUF's values and ESG principles
• Resources: Own resources allocated to operating expenses (OpEx)
• Expected outcome: Ensures suppliers are technically qualified and aligned with company's values and strategic requirements, promoting a more efficient and sustainable value chain

Future action

Definition of action plans together with suppliers to improve their ESG practices

• Scope: Upstream value chain (national level)
• Time horizon: Implementation from 2025
• Target group: Suppliers with lower ratings
• Expected outcome: Improve suppliers' ESG practices, ensuring they are technically qualified and aligned with company values, promoting a more efficient and sustainable value chain

Overall approach

All actions (implemented and future) are:

• Directly related to CUF's upstream value chain
• Implemented at national level
• Financed with own resources allocated to operating expenses (OpEx)
• Aimed at generating positive impacts for workers along the value chain

Status of incidents

To date, CUF has not been informed of any incidents related to human rights, either upstream or downstream in its value chain.

Targets related to value chain workers

CUF has not disclosed specific quantified targets relating to workers in the value chain.

The company states that the supplier assessment process will enable a joint improvement plan to be defined whenever inadequate responses are identified. This plan will be implemented and reassessed after a year to check its effectiveness.

The company has created initiatives in line with the 2030 Agenda and the UN Sustainable Development Goals (SDGs), but no specific targets with metrics, values, or timelines are provided for value chain workers.

Policies related to consumers and end-users

CUF has developed and implemented several policies to reconcile the quality of healthcare provision with responsible behaviour, based on ethics, transparency, integrity and compliance with the law and good practices. The company defends respect for and protection of the human rights of its employees, value chain, and customers.

Policy on the Rights and Duties of Patients and Families

• Scope: All CUF units and employees
• Key content: Promotes respect for the legal, cultural, psychosocial and spiritual rights of customers and family members; strongly condemns any kind of abuse; defines the process for recognising, respecting and implementing the rights and duties of customers and their families; covers respect for privacy, confidentiality of information, citizenship, individuality and dignity of customers and their families

Patient Safety Policy

• Scope: All CUF units and all aspects of care provision
• Governance: Drawn up internally by the Technical Cross-cutting Committee for Patient Safety; approved by CUF's Executive Committee
• Key content: Integrates the culture of safety as an essential element in the provision of excellent healthcare services; reinforces clinical safety
• Link to international standards: Aligned with the National Patient Safety Plan 2021–2026, which is part of the World Health Organisation's Global Patient Safety Plan 2021–2030

CUF Customer Data Privacy Policy

• Scope: All CUF employees; directly affects CUF customers
• Governance: Drawn up internally by the Data Protection Officer (DPO); approved by CUF's Executive Committee
• Key content: Defines CUF's approach to personal data protection; includes technical and organisational measures for the protection of personal data; integration of customer's external clinical information into the electronic medical record (subject to consent); capture of customer's image when reading ID card (with consent); transparency concerning the capture and use of image and voice for institutional communication; video and voice recording in electroencephalogram monitoring; soundless filming of customers in situations of clinical fragility (with consent); sharing of administrative data on occupational accidents with authorised entities; sharing data among clinical staff to evaluate and improve services; data collection and use in Telemedicine; differentiation of data collection times for safety of people and property; integrated healthcare provision via human or digital voice
• Public availability: Available through CUF website, intranet and/or document management platform
• Link to international standards: In accordance with the General Data Protection Regulation (GDPR) 2016/679 of the European Parliament and of the Council of 27 April 2016
• Monitoring: Mandatory data protection training for all employees; training considered as a criterion for bonus; welcome kits sent to those responsible for data management; regular meetings between the DPO team and those responsible for data management

Data Protection Governance Model

• Scope: All CUF employees; directly affects CUF customers
• Governance: Drawn up internally by the Data Protection Officer (DPO); approved by CUF's Executive Committee
• Key content: Defines CUF's approach to personal data protection; ensures compliance with applicable Portuguese and European regulations
• Link to international standards: In accordance with the General Data Protection Regulation (GDPR) 2016/679
• Public availability: Available through CUF website, intranet and/or document management platform
• Monitoring: Mandatory training; regular meetings; DPO oversight; risk management by Risk Management Department; monitored on annual agenda of Executive Committee

Policy for Notification of Personal Data Breaches to the Supervisory Authority and Data Subjects

• Scope: All CUF employees; directly affects CUF customers
• Governance: Drawn up internally by the Data Protection Officer (DPO); approved by CUF's Executive Committee
• Key content: Formalised system for recording and handling incidents related to personal data; all data subjects are contacted whenever an event involving their data occurs; risk and impact analysis carried out by the DPO and Executive Committee Director to determine need for communication to the Portuguese National Data Protection Committee (CNPD)
• Link to international standards: In accordance with the General Data Protection Regulation (GDPR) 2016/679
• Public availability: Available through CUF website, intranet and/or document management platform
• Monitoring: Case-by-case analysis of all interactions; assessment includes risk management; transparency and accountability in protection and provision of information; monitored as top risk on annual Executive Committee agenda

Code of Conduct

• Scope: All CUF professionals
• Governance: Drawn up and monitored by the Code of Conduct Monitoring Committee; ultimately under the responsibility of the Executive Committee
• Key content: Addresses respect for fundamental rights, teamwork, integrity and loyalty to the company, active collaboration, career path, health and well-being, reconciliation of personal and professional lives, prevention of corruption, harassment in the workplace and environmental responsibility
• Link to international standards: Relates to the Code of Ethics, which requires all professionals to know and respect the Declaration of Human Rights (UN, 1950), the Convention for the Protection of Human Rights and Fundamental Freedoms and the Convention for the Protection of Human Rights and Human Dignity

Note on Digital Transformation: Currently, CUF's policies do not directly address the issue of Digital Transformation from the perspective of customers and end-users.

Overall governance: The Executive Committee is responsible for approving the policies and their successive revisions. Monitoring implementation differs according to the scope of the policies, with specificities indicated in the text of the respective policies.

Taking action on material impacts on consumers

a) Social inclusion of consumers and/or end users

With the goal of preventing, mitigating and remedying material negative impacts on customers, CUF carried out several initiatives in 2024, which are expected to continue in the long term:

Customer Support Centre

Consists of a page on the CUF website that centralises and consolidates information for customers, such as clarification forms and quick access to information on agreements, clinical analyses, surgeries, among others, with an optimised response flow to direct requests to the relevant internal areas.

Scope: Own operations (website)

Time horizon: Long term (expected to continue in the long term)

Resources: Not quantified

Expected outcomes: Centralised customer information and optimised response flow

Improvements to the accessibility of the CUF website

CUF has improved website accessibility through an advanced Artificial Intelligence solution. Using a widget, this solution available on the website's homepage allows access to various profiles that enable many options including smart browsing, voice commands, changing colour contrast and colours, changing font, and enlarging the display to 200%. The accessibility profiles are segmented according to each user's abilities (e.g., blindness, motor skills disorders, low vision, epilepsy, or dyslexia).

Scope: Own operations (website)

Time horizon: Long term (expected to continue in the long term)

Resources: Not quantified

Expected outcomes: In 2024, 40,962 users accessed this widget and used the new accessibility features. CUF is the first private healthcare provider in Portugal to make this web tool available, moving ahead of the European standard.

Inclusive Service Training and Employee Awareness of Inclusion

Training in Inclusive Care to raise employee awareness regarding the inclusion of people with some form of disability. This training is aimed above all at professionals with a direct relationship with the customer and covers topics such as: concepts and types of disability and special needs; the importance of empathy and understanding in inclusive care; recognising and acting on signs of discomfort; communication strategies; and legal and ethical aspects.

Scope: Own operations

Time horizon: Long term (expected to continue in the long term, started Q4 2024)

Resources: Non-financial - 90 employees trained by the end of 2024

Expected outcomes: Improved inclusive care capabilities

Optimisation of Permanent Care (PC)

To improve the customer experience, the Permanent Care has been optimised to reduce waiting times and increase satisfaction through:

• Waiting Room Manager – introduction of this function in four units, resulting in a 6% reduction in the weight of detractors (dissatisfied customers who can share negative experiences) in the "waiting times" item

• Revision of the Waiting Calculation Algorithm – standardisation of the communication of estimated waiting times on various channels, ensuring greater predictability for customers

• Explanatory Videos – development of informative content on the customer journey in Permanent Care

• More pleasant waiting times – by making digital newspapers and magazines available free of charge in the Permanent Care units

Scope: Own operations

Time horizon: Long term (expected to continue in the long term)

Resources: Not quantified

Expected outcomes/KPIs: 6% reduction in the weight of detractors in "waiting times" item; increased customer satisfaction; reduced waiting times

Link to policy: These initiatives have been developed with the goal of generating positive impacts for customers, promoting well-being, increasing access to health services and improving people's quality of life.

b) Privacy and Data Protection

[Section referenced but content not provided in excerpts]

Targets related to consumers

CUF has established company-wide targets related to quality of service and patient safety:

Target 1: Training employees in Inclusive Care

• Target metric: Training administrative and auxiliary staff in Inclusive Care
• Target value: 75% of administrative and auxiliary staff
• Target year: 2028
• Baseline year: 2023
• Baseline value: 1%
• Scope: Company-wide (own operations)
• Type: Intensity-based (percentage of employee group)
• Validation: Internal initiative; selected as indicator for CUF Sustainability Linked-Financed Framework (2024)
• Progress to date (2024): 90 employees trained by end of 2024, of which 48 were administrative and auxiliary staff (1% of total employees in these roles). Training commenced in Q4 2024. Over the next four years, training will cover more than 600 employees per year.

Target 2: International Patient Safety Goals compliance

• Target metric: Rate of compliance with International Patient Safety Goals
• Target value: ≥95%
• Target year: Annual target (2025 and ongoing)
• Baseline: International benchmark establishes minimum compliance interval of 95%
• Scope: Company-wide (own operations)
• Type: Absolute percentage
• Validation: Aligned with National Patient Safety Plan
• Progress to date (2024): Target achieved in 2024 (≥95%)

Additional information: Monitoring and reporting of targets relating to adverse events and International Patient Safety Goals are carried out quarterly. These goals are intrinsically linked to the Patient Safety Policy. No intermediate goals have been defined, nor changes made to values, years, methodology, calculation or data collection. CUF did not contact customers directly or their legitimate representatives to define these goals.

Business conduct policies and corporate culture

CUF has developed various codes, channels and internal policies to ensure a serious and responsible commitment to its employees and stakeholders. These policies apply to all companies fully owned, directly or indirectly, by CUF, S.A.

Code of Conduct

Purpose and scope: The Code of Conduct is the guiding principle in the performance of CUF's activity and contains the necessary resources to act in accordance with the company's ethics. It applies to all employees who work at CUF, regardless of the type of employment relationship and the position they occupy in the company's hierarchy.

Key content: The Code addresses various issues including:

• Respect for fundamental rights
• Teamwork, integrity and loyalty to the company
• Active collaboration, career path, health and well-being
• Reconciliation of personal and professional lives
• Prevention of corruption
• Harassment in the workplace
• Environmental responsibility
• Business ethics and interaction with stakeholders
• Labour practices and human rights
• Anti-corruption
• Conflicts of interest
• Fair competition
• Environmental protection

The Code relates to the Code of Ethics, which requires all professionals to know and respect the Declaration of Human Rights (UN, 1950), the Convention for the Protection of Human Rights and Fundamental Freedoms and the Convention for the Protection of Human Rights and Human Dignity.

Governance: Drawn up and monitored by the Code of Conduct Monitoring Committee, with ultimate responsibility resting with the Executive Committee and approved by the Board of Directors.

Public availability: Available on the CUF website and on the company's intranet through the document management platform.

Link to international standards: The Code emphasizes scrupulous compliance with the law and respect for human rights, environmental standards, the fight against corruption and other relevant matters related to sustainability, namely:

• Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
• United Nations Guiding Principles on Business and Human Rights
• Principles and rights established in the fundamental conventions identified in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work
• International Bill of Human Rights

Monitoring: The Code of Conduct Monitoring Committee is responsible for:

• Promoting the dissemination, application and compliance with the Code of Conduct
• Monitoring the implementation of the Code of Conduct, creating an appropriate internal control system
• Preparing implementation policies for the matters covered by the Code of Conduct
• Promoting and establishing training actions for all employees
• Proposing changes to the Code of Conduct to the Board of Directors
• Monitoring and clarifying doubts about the application of the Code of Conduct
• Receiving, managing and appreciating communications sent to codigodeconduta@cuf.pt
• Receiving and processing complaints sent to codigodeconduta@cuf.pt
• Reporting periodically on their activity to CUF's Executive Committee

All employees receive mandatory training on the Code of Conduct. In 2023, an e-learning training course was launched with compulsory content for the entire company, along with face-to-face training sessions for employees with lower digital literacy.

Code for Service Providers, Suppliers and Partners

Purpose and scope: Applies to CUF's upstream value chain, and its application is transversal to all locations where suppliers operate.

Key content: Article 3 includes legal compliance with "Labour Practices and Human Rights":

• Commitment to human rights and equal opportunities at work
• Alignment with OECD guidelines
• Compliance with labour legislation applicable in Portugal and countries where they operate
• Practices that prevent harassment, coercion, discrimination, forced labour and/or child labour
• Provision of a safe and healthy working environment
• Integration of good health and safety management practices
• Respect for workers' rights to freedom of association and collective bargaining

Public availability: Available to all stakeholders via CUF's website.

Link to international standards: Reflects CUF's commitment to:

• United Nations Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises
• Principles and rights set out in the eight fundamental conventions identified in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work
• International Bill of Human Rights

Monitoring: The Code is an integral part of all contracts or protocols signed. If situations of non-compliance are detected, measures are implemented to mitigate their occurrence. In the most serious cases, CUF will take appropriate measures, such as terminating the partnership contract. Since 2021, new contracts include a contractual clause covering labour practices and human rights, anti-corruption, conflicts of interest, fair competition and environmental protection.

Anti-Corruption Policy

Purpose and scope: Part of CUF's Regulatory Compliance Programme. CUF has made a serious and responsible commitment to customers, partners, suppliers, Government and society in general in terms of complying with good institutional practices in terms of transparency and integrity.

Key content: CUF disapproves of any conduct that, directly or indirectly, could be related to acts of corruption. The policy binds employees to comply with all national and international rules on combating corruption, tax fraud, money laundering and other financial crimes.

Governance: Approved by CUF's Executive Committee.

Public availability: Available on the intranet through CUF's document management platform, and some on the website.

Link to international standards: Aligns with the General Regime for the Prevention of Corruption and ISO 37001 (Anti-Corruption Management Systems).

Monitoring: The compliance programme is ensured and controlled by the compliance officer, who is appointed by CUF's Board of Directors and carries out their duties independently, permanently and with decision-making autonomy. Training performance indicators on issues related to corruption and bribery are regularly monitored.

Conflict of Interest Management Policy

Purpose and scope: Applies to all CUF employees to promote impartiality in relations between employees and stakeholders.

Key content: Sets out internal rules and procedures, complementary to the Code of Conduct. Employees have a duty of loyalty to CUF and must avoid actions or relationships that constitute, or may appear to constitute, a conflict of interest.

Governance: Approved by CUF's Executive Committee.

Public availability: Available on the intranet through CUF's document management platform.

Support and Donation Policy

Purpose and scope: Establishes rules and procedures that the company must follow in order to allocate financial or material support.

Key content: Seeks to guarantee transparency, fairness and consistency in the allocation of support and ensure that it is aligned with the company's mission, values and strategic objectives.

Governance: Approved by CUF's Executive Committee.

Public availability: Available on the intranet through CUF's document management platform.

Sponsorship Policy

Purpose and scope: Establishes rules and procedures that the company must follow in order to allocate sponsorships.

Key content: Seeks to guarantee transparency, fairness and consistency in the allocation of sponsorships and ensure that they are aligned with the company's mission, values and strategic objectives.

Governance: Approved by CUF's Executive Committee.

Public availability: Available on the intranet through CUF's document management platform.

Policy on Offers

Purpose and scope: Establishes rules and procedures that the company must follow regarding offers.

Key content: Seeks to guarantee transparency, fairness and consistency in offers and ensure alignment with the company's mission, values and strategic objectives.

Governance: Approved by CUF's Executive Committee.

Public availability: Available on the intranet through CUF's document management platform.

Sustainability Policy

Purpose and scope: Published in September 2023 and made available to stakeholders on the CUF website. The policy consolidates the company's identification of 11 ESG commitments in the environmental, social and governance spheres.

Key content: Commitments include:

• Active contribution to the reduction of its ecological footprint
• Identification and management of climate risks, maintaining high standards of quality and safety
• Establishment of contracts or partnerships only with entities that share CUF's principles and ethical values, demanding compliance with environmental, social and governance criteria
• Contribution to the sustainable development of the communities where CUF operates
• Commitment to human rights

Governance: Oversight by the Innovation and Sustainability Committee (with representatives from the Board of Directors). The Corporate Citizenship Department, reporting directly to the Chief Executive Officer, is responsible for defining and developing CUF's sustainability strategy.

Public availability: Available on the CUF website.

Link to international standards: Includes commitment to human rights in line with national and international guidelines.

Fleet Management Policy

Purpose and scope: Applies to employees who use the company fleet. Made available to stakeholders via the CUF intranet and sent individually to each employee who uses the fleet.

Key content: Commitments include:

• Minimising environmental impact by choosing more efficient vehicle makes and models
• Ensuring and optimising the electrical infrastructures installed by CUF, for employees and clients

Governance: Drawn up by the People Management Department and the Means and Assets Department, with final approval by the Executive Committee.

Quality, Environment and Safety Policy

Purpose and scope: Applies to all employees. Developed in accordance with the international standard ISO 9001.

Key content: Defines:

• The identification of environmental aspects resulting from the provision of healthcare
• The promotion of sustainable use of natural resources including energy and water, pollution prevention and reduction, reuse and recycling of waste generated

Governance: Developed by the Quality and Safety Department.

Public availability: Available on the intranet for all employees.

Plan for the Prevention of Risks of Corruption and Related Infractions (RPP)

Purpose and scope: Identifies, analyses and classifies risks related to corruption.

Key content: Identifies risks and situations that could expose CUF to acts of corruption and offences, and presents transversal controls and specific preventive and corrective measures for each risk. CUF has identified the following risks:

• Internal fraud (entities/persons in a situation of conflict of interest for CUF)
• External fraud (from suppliers/partners)

Link to international standards: Based on interviews with stakeholders and relies on the guidelines set out in ISO Standard 37001 "Anti-corruption management systems, requirements and guidelines for their use".

Other supporting mechanisms

Whistleblowing Channel: CUF provides a Whistleblowing Channel, accessible to all on its website, which allows the reporting of complaints associated with human rights, corruption, taxation and fair competition. The Channel ensures:

• Confidentiality and protection against retaliation in accordance with Directive (EU) 2019/1937
• Investigation and follow-up by the Code of Conduct Monitoring Committee or relevant areas
• Communication and regular training

Corporate culture development: CUF's corporate culture is established, developed, promoted and evaluated through:

• The Code of Conduct with internal communication campaigns and training sessions
• Mandatory training programme on ethical conduct and human rights
• Internal Committees including the Code of Conduct Monitoring Committee, the Internal Audit Committee and the Innovation and Sustainability Committee

CEO Guide on Human Rights: The Chairman of CUF's Board of Directors was one of the Portuguese CEOs who signed the CEO Guide on Human Rights, launched by the Business Council for Sustainable Development Portugal (BCSD).

United Nations Global Compact membership: CUF has been a member of the United Nations Global Compact since 2023.

Prevention and detection of corruption and bribery

CUF has specific procedures for preventing, detecting and responding to cases of corruption and bribery, in line with the General Regime for the Prevention of Corruption and ISO 37001 (Anti-Corruption Management Systems).

Anti-Corruption Policy

Scope:

• Part of CUF's Regulatory Compliance Programme
• Applies to all employees who work at CUF, regardless of the type of employment relationship and the position they occupy in the company's hierarchy
• Reinforced through the Code of Conduct

Key content/principles:

• CUF disapproves of any conduct that, directly or indirectly, could be related to acts of corruption
• Binds employees to comply with all national and international rules on combating corruption, tax fraud, money laundering and other financial crimes
• CUF actively promotes the fight against the practice of acts of corruption

Governance:

• Ultimately approved by CUF's Executive Committee

Public availability:

• Available on the intranet through CUF's document management platform
• Some policies available on the website
• Accessible to all stakeholders

Links to international standards:

• ISO 37001 "Anti-corruption management systems, requirements and guidelines for their use"
• General Regime for the Prevention of Corruption

Implementation monitoring:

• Training performance indicators on issues related to corruption and bribery are regularly monitored
• All employees in risk groups have completed training on CUF's Code of Conduct and Internal Policies
• In 2023, an e-learning training course was launched with compulsory content for the entire company
• Face-to-face training sessions organized for employees with lower digital literacy

Plan for the Prevention of Risks of Corruption and Related Infractions (PPR)

Key content/principles:

• Identifies, analyses and classifies the risks and situations that could expose CUF to acts of corruption and offences
• Presents transversal controls and specific preventive and corrective measures for each risk
• Based on interviews with stakeholders
• CUF has identified the following risks in its Risk Dictionary:
  • Internal fraud (entities/persons in a situation of conflict of interest for CUF)
  • External fraud (from suppliers/partners)

Links to international standards:

• Based on guidelines set out in ISO Standard 37001 "Anti-corruption management systems, requirements and guidelines for their use"

Conflict of Interest Management Policy

Scope:

• Applies to all employees
• Complementary to the Code of Conduct

Key content/principles:

• Sets out internal rules and procedures for managing conflicts of interest
• Employees have a duty of loyalty to CUF and must avoid actions or relationships that constitute, or may appear to constitute, a conflict of interest
• CUF promotes impartiality in the relations between its employees and stakeholders

Governance:

• Ultimately approved by CUF's Executive Committee

Public availability:

• Available on the intranet through CUF's document management platform
• Some policies available on the website

Offers Policy

Governance:

• Ultimately approved by CUF's Executive Committee

Public availability:

• Available on the intranet through CUF's document management platform

Sponsorship Award Policy

Key content/principles:

• Establishes the rules and procedures that the company must follow in order to allocate financial or material support
• Seeks to guarantee transparency, fairness and consistency in the allocation of support
• Ensures support is aligned with the company's mission, values and strategic objectives

Governance:

• Ultimately approved by CUF's Executive Committee

Public availability:

• Available on the intranet through CUF's document management platform

Support and Donation Policy

Key content/principles:

• Establishes the rules and procedures for allocating financial or material support
• Seeks to guarantee transparency, fairness and consistency in the allocation of support
• Ensures support is aligned with the company's mission, values and strategic objectives

Governance:

• Ultimately approved by CUF's Executive Committee

Public availability:

• Available on the intranet through CUF's document management platform

Risk Management Policy

Key content/principles:

• Establishes an integrated and effective risk management structure
• Ensures the identification of risks and opportunities associated with the company's operations and business
• Defines relevant risk response strategies

Links to international standards:

• Follows the guidelines of the Committee of Sponsoring Organisations of the Treadway Commission (COSO)
• International Organisation for Standardisation (ISO) 31000 "Risk Management"
• Model of the three lines of defence of the Institute of Internal Audit (IIA)

Detection and Reporting Mechanisms

Whistleblowing Channel:

• Accessible to all on CUF's website
• Allows any stakeholder, whether internal or external, to anonymously report possible breaches of conduct, such as harassment, corruption and conflicts of interest
• Confidentiality and protection against retaliation guaranteed in accordance with applicable legislation, including Directive (EU) 2019/1937
• Complaints analysed by the Code of Conduct Monitoring Committee or forwarded to relevant areas (Legal Department, Internal Audit)
• CUF implements clear and strong procedures for investigating incidents related to business conduct in a prompt, independent and objective manner

Governance and Oversight:

• Code of Conduct Monitoring Committee: composed of autonomous members without any link to the management chain involved in cases under analysis
• Internal Audit Committee
• Results communicated to the Executive Committee and Board of Directors through regular reports
• Executive Committee monitors compliance activities and reports relevant issues to the Supervisory Board
• Continuous monitoring ensures transparency and corrective action when necessary

Risk Groups:

• CUF recognises that certain functional groups are more exposed to potential conflicts of interest: Board of Directors, Executive Committee, Corporate Directors and Unit Directors
• This universe of 38 people is currently being revised to include more functions considered to be at risk
• All employees in this risk group have completed training on CUF's Code of Conduct and Internal Policies

Incidents of corruption or bribery

Confirmed incidents

In 2024, there were no confirmed incidents of corruption or bribery and no convictions for violating anti-corruption and anti-bribery laws.

Investigation and speak-up procedures

CUF has specific procedures for preventing, detecting and responding to cases of corruption and bribery, in line with the General Regime for the Prevention of Corruption and ISO 37001 (Anti-Corruption Management Systems). The main mechanisms are:

• Plan for the Prevention of Risks of Corruption and Related Infractions (PPR): identifies, analyses and classifies risks related to corruption, establishing specific preventive and corrective controls for each situation.
• Anti-Corruption Policy: part of CUF's Regulatory Compliance Programme, which also includes the Code of Conduct.
• Whistleblowing Channel: allows any stakeholder, whether internal or external, to anonymously report possible breaches of conduct, such as harassment, corruption and conflicts of interest.

The Whistleblowing Channel guarantees:

• Confidentiality and protection against retaliation: all whistleblowers and witnesses are protected against reprisals, ensuring a safe environment for reporting in accordance with applicable legislation, including Directive (EU) 2019/1937.
• Investigation and follow-up: complaints are analysed by the Code of Conduct Monitoring Committee or forwarded to the relevant areas of the company, such as the Legal Department and Internal Audit, depending on the nature of the incident. CUF implements clear and strong procedures for investigating incidents related to business conduct in a prompt, independent and objective manner, in compliance with applicable legislation.
• Communication and regular training: CUF promotes communication campaigns and offers regular training to its employees on the Code of Conduct.

The Code of Conduct and Internal Audit Monitoring Committee has members who act autonomously, without any link to the management chain involved in the cases under analysis. These commissions are composed of independent members, who do not have any direct involvement with the managers or operations related to the case in investigation.

Disciplinary framework

Violation by employees of anti-corruption rules may constitute a disciplinary offence, which may result in the application of a sanction that will be graded on a case-by-case basis between a reprimand and dismissal for just cause, under the terms of the Labour Code. The application of disciplinary sanctions to employees is without prejudice to the possible reporting to the authorities of facts that may constitute a criminal offence or administrative offence, which may give rise to legal proceedings and criminal sanctions, including fines or imprisonment.

Compliance oversight

The application of the compliance programme is ensured and controlled by the compliance officer, who is appointed by CUF's Board of Directors and carries out their duties independently, permanently and with decision-making autonomy.

Payment practices

For most of its supplies, CUF has 90-day contractual payment terms. However, according to the average payment period on 31 December 2024, invoices were settled faster (74 days). The percentage of payments that are in line with the established payment terms is 94%, and there are no legal proceedings currently underway for late payment.

Key metrics

Methodology note

These metrics were developed internally and have not been verified by an external entity.