Dassault Systemes SE

Governance roles

Reference: pages 62-65.

As of December 31, 2025 the Board of Directors has 14 members (4-year renewable terms), including two employee-representative directors. Independent directors are 50% of the Board excluding employee representatives (42% including them); 50% of Board members are women excluding employee representatives (57% including them).

The Board appointed independent director Genevieve Berger as Lead Director of Sustainability Development: she "reviews the impacts, risks, and opportunities (IROs) identified in the DMA and ensures their consistency with the policies, action plans, and targets implemented," reporting to the Board after preparing a working session with the Chief Sustainability Officer (p.65).

Three Board committees (Scientific, Audit, Compensation and Nomination), composed exclusively of independent directors, each "incorporate sustainability aspects into their missions" (p.65); the Audit Committee specifically reviews sustainability reporting requirements under the CSRD and ESRS and the statutory auditors' assurance work (p.65). An Executive Committee member, the EVP Strategy, Industry, Marketing & Transformation, holds operational responsibility for the sustainability roadmap (p.66), supported by a quarterly Sustainability Steering Committee (pp.66-67).

Information to, and matters addressed by, governance bodies

Reference: pages 67-68.

Communication runs through the Executive Committee (Sustainability Steering Committee reports on progress), independent directors (meeting twice a year on sustainability and ESG risk), and the three Board committees, supported by the Sustainable Development, Sustainable Finance & Procurement, and Audit & Risks departments (p.67).

"In 2025, the Audit Committee received presentations on the results of the first publication of the CSRD-compliant Sustainability Statement, potential developments in this directive, the Company's performance on key environmental metrics, and a review of the DMA" (p.67). Independent directors also reviewed the Company's updated sustainability risk map during dedicated September 2025 sessions (p.65).

The Sustainable Development department's mandate spans Handprint solution development, Footprint carbon-neutrality strategy, EU Taxonomy reporting, internal action plans, training, external relations (World Economic Forum, COP, OECD, IEA) and regulatory monitoring (p.68).

Incentive mechanisms

Reference: pages 68-70.

ESG criteria have applied to the CEO's annual variable compensation since 2020, extended to the Executive Committee in 2021, to People managers (inclusion/engagement criterion) since 2022, and to Long-term incentive plans since 2023 (p.68).

2025 weightings: ESG criteria represent 15% of the CEO's variable annual compensation, 5% of the common ESG criteria for Executive Committee members (up to 25% for the two members directly responsible for sustainability pillars), 20% of Long-term incentive plans, and 15% by default for People managers' annual performance measurement (pp.68-69).

The common "ESG Indicator" splits into a social criterion (employee pride/satisfaction, one quarter), a governance criterion (women on the Board/Executive team/People managers, one quarter), and two climate criteria weighted 50/50 between EU Taxonomy-aligned revenue and GHG reduction against SBTi targets (two quarters) (p.69). Climate criteria alone represent 7.5% of the CEO's variable compensation and 13.3% of 2025 Long-term incentive plan criteria (p.69).

Statement on due diligence

Reference: page 69.

Dassault Systemes maps the core elements of due diligence to sections of the Sustainability Statement:

The mapping is presented as a reconciliation table between "the topics covered by the due diligence process and the material strategic matters identified in the DMA" (p.69).

Risk management and internal controls over sustainability information

Reference: pages 69-71.

The Audit & Risks department leads risk management, coordinated through the Risk Management Steering Committee under the General Secretary, which "ensures consistency between Company risks and CSRD requirements and TCFD recommendations" (p.69).

In 2024 the department implemented an internal control system for sustainability reporting (ICSR) built on four pillars: a reporting chain for data collection/calculation/consolidation, a central metrics-consolidation function, documented accounting/consolidation principles, and ICSR control points integrated into the Company's internal control framework; "in 2025, the ICSR system was completed and its effectiveness assessed" (p.70).

Two main risks are tracked: methodological risk (data collection, calculation, estimation) and integrity risk ("greenwashing ... the misleading presentation of environmental actions"), controlled through methodology validation, data validation, reporting-system control and manager certification (p.70). Internal audits covered electronic waste management (2023), anti-corruption (2024) and certain GEO audits (2025) (p.70).

Strategy, business model and value chain

Reference: pages 71-73.

Dassault Systemes serves three sectors (Manufacturing Industries; Life Sciences & Healthcare; Infrastructure & Cities) across twelve industries through twelve brands on the 3DEXPERIENCE platform (p.72). As of December 31, 2025 headcount was 24,997 (40% in R&D), with IFRS revenue of EUR6,236 million (p.73).

Value chain: upstream purchases concentrate in "IT equipment, data hosting networks and software, real estate leases and numerous professional services," with the professional-services subcontracting chain "considered non-material" (p.72). Downstream, the Company serves more than 390,000 customers through internal teams, a reseller/integrator network of more than 18,000 people, and digital distribution (p.72).

The 3DS Acceptable Use Policy excludes new customers and product development in four segments: coal for energy, tobacco/electronic cigarette production, "universally prohibited" weapons, and oil and gas absent a public carbon-reduction commitment (p.72).

Stakeholder interests and perspectives

Reference: pages 73-76.

Stakeholders are mapped into twelve categories, established in 2023 and "reviewed for relevance in 2025," classified into four engagement quadrants (Manage Closely, Keep Satisfied, Keep Informed, Monitor) using internal influence and expectations/expertise surveys (pp.73-74).

Key channels by group: customers (commercial dialogue on Handprint/Footprint contribution), suppliers (EcoVadis Gold rating, CDP responses), employees (annual satisfaction survey across five dimensions, 3DEXPERIENCE platform communities, ad hoc surveys, dialogue with employee representatives), consumers/end-users including MEDIDATA's Patient Insights Board, and investors (ESG rating questionnaires, La Fondation Dassault Systemes outreach) (pp.74-76).

"Particular attention is paid to ensuring that the strategy and business model do not exacerbate negative impacts, especially in terms of data protection, discrimination, or harassment" (p.76).

Material IROs and their interaction with strategy

Reference: pages 76-80.

The 2024 DMA identified 30 material Impacts, Risks and Opportunities, grouped into twelve strategic matters; "the 2025 DMA review concluded that the IROs remained stable compared to 2024," with only strategic matter 10's wording adjusted for Generative AI (p.76).

Material topics are E1, E3 (upstream value-chain water only), E5, S1, S2, S3, S4 and G1; E2 (pollution) and E4 (biodiversity) were excluded as not material (pp.84-85).

Three resilience risk factors were identified: climate-change adaptation (strategic matter 4), talent attraction/retention (strategic matters 5-6), and cybersecurity/data protection (strategic matter 9) (p.80). "None of these analyses revealed any risks with a significant financial impact on the Company in the short, medium, or long term, demonstrating the resilience of its business model" (p.96, cross-referenced from SBM-3, p.80).

Process for identifying and assessing material IROs

Reference: pages 80-86.

Time horizons follow EFRAG guidance: short term is one year, medium term one to five years, long term beyond five years (p.62, applied throughout). The DMA process identifies material matters by ESRS topic and assesses IROs against thresholds calibrated to the Company's Enterprise Risk Management approach.

Climate (D.1, pp.82-85): physical risk used IPCC scenarios SSP1-2.6 and SSP5-8.5 across short/medium/long horizons with MunichRe and Aqueduct Water Risk Atlas data, finding "an overall low level of risk... regardless of climate hazards, period, or scenario," with potential financial impact "less than EUR20 million per year for all scenarios," rising to EUR40 million in the most pessimistic long-term case before mitigation (p.84). Transition risk used the IEA Sustainable Development Scenario across 17 segments in 7 industries, concluding "transition opportunities outweigh its transition risks" (p.85).

Pollution (E2), Water (E3), Biodiversity (E4) and Resource use (E5) (D.2-D.5, pp.85-86): pollution and biodiversity were excluded as not material based on SASB/GRI frameworks given the Company's non-industrial, software-based operations; water materiality was confined to the upstream IT-equipment/data-hosting value chain; E5 identified three IROs (R1 negative impact on natural-resource extraction; R3/R4 positive impact and opportunity from circular-economy solutions) (pp.85-86).

DRs covered by the sustainability statement

Reference: page 86; Appendix, section 2.2.5.3 (pp.179-183); Appendix B, section 2.2.5.2 (pp.176-178).

The statement carries a full ESRS content index at section 2.2.5.3 listing each disclosure requirement covered, with the section of the statement it corresponds to. ESRS 2 (BP-1/2, GOV-1 to 5, SBM-1 to 3, IRO-1/2) is covered in full. Topical coverage follows the DMA: E1 (all core DRs except E1-9), E3 (E3-1 to E3-4, scoped to the upstream value chain), E5 (E5-1, E5-3, E5-4, E5-5), S1 (policies, processes, actions, targets, and a subset of metrics), S2 (S2-1, S2-2, S2-4, S2-5), S3 (all of S3-1 to S3-5), S4 (S4-1, S4-2, S4-4, S4-5) and G1 (G1-1 to G1-6).

Appendix B cross-references the SFDR/Pillar 3/Benchmark Regulation/EU Climate Law datapoints, marking several as "Not material," "Not significant" or "Not important" where the underlying topic or sub-topic was excluded by the DMA (E1-9's benchmark-exposure datapoints, E2-4, several E3 water datapoints, and specific S1-14 health-and-safety datapoints) (pp.176-178). "We have not omitted any specific information corresponding to intellectual property, know-how, impending developments or matters in the course of negotiations" beyond the declared Life Sciences quantitative-target omission (p.62).

Transition plan for climate change mitigation

Reference: pages 93-97, 116.

The plan rests on two pillars: Handprint (customer decarbonization/circularity, measured by EU Taxonomy eligible/aligned revenue) and Footprint (own operations and value chain, Scopes 1-3), targeting carbon neutrality by 2040 "by applying a strict mitigation hierarchy: absolute priority is given to reducing gross emissions before resorting to carbon credits for residual emissions" (p.93).

Near-term SBTi-validated targets for 2027 (base year 2019): -35% Scope 1&2, -20% Scope 3 business travel/commute, 50% of suppliers by emissions with science-based targets; all three were already exceeded in 2025 at -78.3%, -35.7% and 50.4% respectively (pp.94, 96-97).

Locked-in emissions for Scopes 1-2 are assessed as "not significant" given renewable-energy and efficiency efforts; Scope 3 purchases (3-5 year IT/hosting contracts) are managed via supplier decarbonization levers (p.96). Financing is embedded in departmental budgets rather than a separate line; EU Taxonomy-aligned CapEx reached EUR15 million in 2025 versus EUR0.3 million in 2024 (p.96). The Company "is not excluded from the Paris Agreement aligned benchmarks" (p.96) and states it is "currently preparing its new carbon trajectory, aligned with SBTi requirements" to replace the 2027 commitments (p.93).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 82-85). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk used two IPCC scenarios: SSP1-2.6 ("optimistic ... limiting the increase in global temperature to 1.8C by 2050") and SSP5-8.5 ("business as usual ... leading to a 4.4C increase by 2100"), applied to own sites/data centers and the value chain over short (to 2030), medium (2031-2050) and long (2051-2100) horizons using MunichRe and Aqueduct Water Risk Atlas data (p.83). Result: "an overall low level of risk... regardless of climate hazards, period, or scenario," with the main exposures being drought, heat and heavy precipitation in India, China, Korea, Japan and the Americas (p.84). The 2022 financial assessment was not updated in 2025 as "no significant changes in location or developments in the scenarios" were observed (p.84).

Transition risk used the IEA Sustainable Development Scenario across 17 segments in 7 of 12 served industries (about 73% of 2023 software revenue), plus an internal carbon-price approach to operations/upstream value chain using the IEA STEPS scenario (USD120/tCO2-eq by 2030 rising to USD135 by 2050) (p.85). Conclusion: "transition opportunities outweigh its transition risks" in end markets (p.85).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and E1-1, where this content is disclosed in the FY2025 report (pages 80, 96-97). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Dassault Systemes conducted an in-depth resilience analysis of its value chain in relation to climate change," covering physical risks (own sites and key suppliers) and transition risks (end markets and own operations) (p.96). "None of these analyses revealed any risks with a significant financial impact on the Company in the short, medium, or long term, demonstrating the resilience of its business model," though "these projections are based on assumptions that are considered reasonable, but remain subject to uncertainty" (p.96).

Climate-change adaptation is named as one of three Company-wide resilience risk factors identified by the DMA, covered by strategic matter 4 and monitored by the Risk Management Steering Committee (p.80). Resilience is also reinforced structurally through the Transition plan's two pillars (Handprint and Footprint) and associated decarbonization levers (p.97).

Policies related to climate change mitigation

Reference: pages 98-108.

Five named policies/charters underpin climate management: the "Handprint" strategy (customer-facing decarbonization and circularity offerings, four focus areas), the "Responsible digital" charter (IT equipment lifespan extension, e.g. laptops at five years, servers seven-eight years), the "Responsible procurement" policy (supplier selection on SBTi commitment and carbon/energy criteria), the "Responsible data centers" policy (renewable-energy sourcing, closed-loop cooling, PUE/WUE tracking) and the "Responsible real estate" and "Responsible mobility" policies (ISO 50001 certification, travel/commute reduction) (pp.99-108). All apply Company-wide except CENTRIC entities (pp.104, 107).

The "Supporting innovative startups" and "Environmental training and awareness" policies (mandatory "Be a SWYMER" training plus advanced modules) complement these by building internal and ecosystem climate expertise (pp.99-101).

Actions and resources related to climate change

Reference: pages 99-109, 115-116.

Key 2025 actions: development of 32 cumulative "avoided emissions" use cases (9 new in 2025) under the Handprint strategy (p.101); data centers powered 100% by renewable energy in France and >91.5% worldwide (p.104); a 5.6-point year-on-year rise to 93.9% renewable electricity for Scopes 1-2, aided by the Company car fleet's shift toward electric/hybrid models (approximately one-third fully electric, ~85% electrified) (pp.105, 111); and 91.4% of employees now working at ISO 50001-certified sites, five years ahead of the 2030 target (p.111).

Resources: action plans are funded through annual departmental budgets and the medium-term strategic plan rather than a ring-fenced climate budget; R&D expenditure aligned to the EU Taxonomy's climate-change-mitigation objective reached EUR395 million in 2025 (EUR334 million in 2024), while aligned CapEx ("particularly demanding" data-center/real-estate criteria) was EUR15 million (p.96). An internal carbon price of EUR100/tCO2-eq, set in 2023, differentiates investment choices and feeds goodwill-impairment testing (p.115-116).

Targets related to climate change mitigation

Reference: pages 93-97, 116.

SBTi-validated near-term targets (2027, base year 2019): -35% Scope 1&2 GHG emissions, -20% Scope 3 business-travel/commute emissions, 50% of suppliers by emissions with science-based targets (maintained internally to 2027 beyond the 2025 SBTi deadline) (p.94). 2025 performance already exceeds all three: -78.3%, -35.7% and 50.4% respectively (p.96-97). Long-term target: carbon neutrality by 2040, prioritizing gross-emission cuts over offsetting (p.93).

Supporting entity-specific targets: at least 90% of employees at ISO 50001-certified sites by 2030 (achieved early at 91.4%), a weighted-average data-center PUE of 1.4 by 2030 then 1.3 by 2035, and 100% renewable energy for European data centers by 2030 (p.116). The Company states it "is currently preparing its new carbon trajectory, aligned with SBTi requirements," including, for the first time, the "use of solutions sold" Scope 3 category, to replace the current commitments (p.93).

Energy consumption and mix

Reference: page 111-112.

Total energy consumption in 2025 was 72,300 MWh, up 5.9% on 2024 (new US/France sites), of which 84.6% came from renewable sources (+1.7 points), 14.7% from fossil sources (down from 15.6%) and 0.7% from nuclear sources. Fossil fuel consumption fell in absolute terms (natural gas -10.4%, coal products -18.0%) despite overall growth (p.111).

Renewable consumption totalled 61,166 MWh, entirely from purchased/acquired electricity, heat, steam and cooling from renewable sources; self-generated non-fuel renewable energy is reported at nil. "As the Company does not operate in sectors with a high climate impact, it is not subject to the obligation to publish energy intensity. Consequently, this metric is not presented" (p.112).

Energy Attribute Certificates covering India, the US and Canada totalled 28,704 MWh in 2025, contributing to a Scope 2 contractual-instrument coverage of 85.9% of electricity (p.110-111).

Gross GHG emissions, Scopes 1-3 and total

Reference: pages 109-114.

2025 gross emissions (tCO2-eq): Scope 1: 3,110 (-42.4% vs 2019); Scope 2 market-based: 2,339 (-88.1% vs 2019); Scope 3: 309,750 (-4.1% vs 2019), of which upstream 191,519 and downstream 118,231 (use of solutions sold). Total market-based carbon footprint: 315,200 tCO2-eq (-9.4% vs 2019, -3.0% vs 2024); location-based total 332,680 tCO2-eq (p.113-114).

Scope 3 breakdown by category: goods and services 105,830; capital goods 31,750; business travel 49,899; employees' commute 42,859; use of solutions sold 118,231 (categories 8-10, 13-15 reported as not applicable/non-significant) (p.114). Carbon intensity: 12.6 tCO2-eq per employee (-38.1% vs 2019) and 50.5 tCO2-eq per EUR million of IFRS revenue market-based (-41.6% vs 2019) (pp.110-111).

Methodology: emission factors are sourced from Defra and ADEME; Scope 3 "goods and services" uses a hybrid monetary/physical-data approach incorporating supplier-specific factors since 2025; employees' commute is estimated from a triennial survey covering 100% of employees, with "limited" reliability (pp.114-115).

GHG removals and carbon-credit-financed mitigation projects

Reference: page 115.

"Dassault Systemes is not involved in any GHG absorption or storage projects as part of its own activities or in its value chain, and does not operate in the carbon credit markets." It does, however, ask some event service providers to offset related emissions: in 2025, all emissions from the Company's major events were offset, 2,488 tCO2-eq, "assessed by an independent third party" with credits "certified by recognized standards, such as VCS." These purchased credits are explicitly excluded from the Company's own carbon footprint (p.115). The Company states it "will also continue its decarbonization efforts beyond 2027 in order to minimize the volume of emissions requiring offsetting" (p.115).

Internal carbon pricing

Reference: pages 115-116.

Dassault Systemes implemented an internal carbon price (ICP) of EUR100/tCO2-eq in 2023, "with the target of integrating the cost of CO2 into its strategic decisions and encouraging internal functions to take decarbonization actions, regardless of the risk of the regulatory carbon tax being implemented within the European Union." The ICP differentiates investment choices (new equipment, real-estate tenders) toward lower-carbon options and "also serves as a reference for goodwill impairment tests in the financial statements." The EUR100/tCO2-eq level is stated to be aligned with peer internal prices and with the EUR109/tCO2-eq assumption used for 2030 in the Company's own transition scenarios (p.116).

Policies related to water and marine resources

Reference: pages 117-119.

Water is material only through the upstream value chain: "the DMA concluded that only the impacts on water in the upstream value chain related to the manufacture of IT equipment and data hosting in data centers are material... even though its own operations have no material impact on water" (p.117-118). Two policies manage this: the "Responsible procurement" policy, which factors supplier water consumption into selection criteria "although data on this is scarce" (p.118), and the "Responsible data centers" policy, covering "analyzing water stress in potential locations, choosing the most efficient cooling technologies," and favoring closed-loop infrastructure "where possible" (p.118). Both exclude CENTRIC entities.

Actions and resources related to water

Reference: pages 118-119.

Two levers are implemented: dialogue with data center providers (monitoring Water Usage Effectiveness (WUE) as part of reporting, weighting WUE in tender evaluations, preferring closed-water-circuit/adiabatic cooling designs, "particular attention... paid to data centers located in areas of water stress") and dialogue with IT equipment suppliers (water conservation embedded in the Sustainable Charter with Suppliers) (p.118). In France, partner data centers "mainly use air cooling technologies, such as free chilling and free cooling, to limit water consumption" (p.118). Resources for these actions flow through the same budgets as the "Responsible procurement" and "Responsible data centers" policies; no separate water budget line is disclosed.

Targets related to water and marine resources

Reference: page 119.

No quantitative target is set. "Dassault Systemes is not in a position at this stage to publish a quantitative target for weighted average WUE, nor to communicate on the timeframe in which it will be able to do so," citing data-quality uncertainty, a response rate from hosting providers of only 75% in 2025, geographic disparities and data-center churn. "Nevertheless, the Company continues to reflect on setting medium-term ambitions and monitors the efficiency of its policies and actions through the evolution of this metric" (p.119). Within the 75% response scope, weighted-average WUE stood at 0.4 l/kWh in 2025 (p.118).

Water consumption

Reference: page 119 (upstream WUE metric); section 2.2.5.6.1, page 192 (voluntary own-operations metric).

The Company's value-chain water metric is weighted-average Water Usage Effectiveness of 0.4 l/kWh in 2025, covering the 75% of hosting providers that responded to its data request (p.119).

Own-operations water consumption is disclosed as a voluntary, non-material metric: 239,189 m3 in 2025, down from 279,764 m3 in 2024, reported "in particular to meet the requirements of ESG rating agencies such as the Carbon Disclosure Project," for activities that "consume little water, mainly for sanitary purposes and watering certain green spaces" (p.192). Consumption excludes data centers and is extrapolated per-employee for sites where direct metering is unavailable (p.192). Dassault Systemes itself frames this as disclosed despite being "not linked to any material IRO" (p.85).

Policies related to resource use and the circular economy

Reference: pages 119-121.

Circularity IROs sit under two strategic matters. Strategic matter 1 (positive impact R3, opportunity R4 from customer-facing circular-economy solutions) draws on the "Handprint" strategy, the "Supporting innovative startups" policy, and the "Environmental training and awareness" policy (p.120). Strategic matter 3 (negative impact R1, from the digital industry's resource/waste lifecycle) is managed through the "Responsible digital" charter (IT-equipment lifespan extension, IT Asset Disposal sub-policy), the "Responsible procurement" policy (ESG criteria, preference for second-hand equipment) and the "Environmental training and awareness" policy (p.121). All apply Company-wide except CENTRIC entities.

Targets related to resource use and the circular economy

Reference: page 121.

"The Company has not separated its targets between Climate and Circularity sub-objectives, as its solutions often contribute to both simultaneously." The single combined target is 70% of revenue eligible and 45% aligned to EU Taxonomy criteria by 2027, covering both climate and circularity objectives; 2025 performance for the circular-economy EU Taxonomy objective specifically stood at 65.6% eligible / 35.7% aligned revenue, up 15.1 points on alignment versus 2024 (p.121). No separate quantitative target is set for the resource-outflow/waste IRO (R1); the Company monitors efficiency through the waste metrics at section 2.2.2.4.3.

Resource inflows

Reference: page 123.

"Due to a lack of sufficiently accessible data and reliable extrapolation methods, the Company is unable to collect or estimate, through sector studies, the total weight of incoming resources, in particular information on raw materials." Instead, it "strives to collect data on the weight, carbon emissions, and repairability index of its IT equipment, such as servers and network equipment, as well as its data hosting and storage infrastructure," recorded in a dedicated internal equipment catalog (p.123). No total-inflow-weight figure is therefore disclosed; this is a stated data-availability limitation rather than an omission of a figure that exists.

Resource outflows

Reference: pages 123-125.

"Dassault Systemes exclusively develops digitally distributed software, which does not generate any physical resource outflow." The main outflows are everyday employee waste and end-of-life IT equipment, tracked since 2024 via supplier data on treatment type, volume and location (p.124). Almost all laptops are TCO-certified, supporting circularity, energy efficiency and compliance standards (p.124). A reference laptop-composition breakdown (2022 ADEME study) is cited: ferrous metals 15% (recyclable), non-ferrous/rare earths 11.5% (recyclable), plastic 40% (partly recyclable), electronic cards 15%, regulated components (batteries) 17% (partly recyclable), other materials 1.5% (p.124). See also the dedicated waste metrics at the E5-5-Waste entry.

Waste

Reference: pages 124-125.

Total waste: 819.8 tonnes in 2025 (up 15.9% on 707.5 tonnes in 2024), comprising electrical/electronic waste of 64.1 tonnes (+3.8%) and ordinary waste of 755.7 tonnes (+17.0%). Recycled waste: 92.2% of total (+0.9 points); electronic waste is 100% recycled; non-recycled waste fell to 15.2% of ordinary waste (down 21.0 points) (p.125).

By treatment: waste diverted from disposal totalled 744.4 tonnes (reuse/reconditioning 11.1t, other recovery/donation 0.2t, recycling 744.2t electronic-waste-equivalent categories), while waste directed to disposal totalled 744.5 tonnes (destruction, incineration, landfill and other elimination) (p.125). "The Company entrusts all of its electrical and electronic waste to trusted third parties so that this equipment can be incorporated into the circular economy circuits" (p.125). Waste data collection is "local and complicated by the multiplicity of intermediaries," with ordinary-waste volumes estimated rather than weighed (p.125-126).

Policies related to own workforce

Reference: pages 125-137.

"The DMA was performed covering the entire workforce." Non-employee workers are "less than 2% of the employee and non-employee workforce... As no topic has been identified as material with regard to the non-employee workforce, the information disclosed in this paragraph covers the Company's employees" only (p.127).

Core workforce policies include the "Total rewards" policy (fixed/variable pay, benefits, social protection), the Corporate Social Responsibility Principles (prohibiting child/forced labor and all discrimination, guaranteeing safe working conditions, respecting freedom of association and collective bargaining, p.136), and the Code of Business Conduct (anti-discrimination/harassment rules). A 2025 DMA review found "Dassault Systemes has not identified any material impact, risk, or opportunity for its employees arising from the implementation of its environmental Transition plan" (p.127).

Engaging with own workforce and representatives

Reference: pages 127, 136-137.

Employees access four channels: an annual satisfaction survey covering five dimensions (meaning at work, management quality, competitiveness of the working environment, community life, pride), 3DEXPERIENCE platform communities, ad hoc topical surveys, and "dialogue with employees' representatives... in the form of information or consultation" (p.127).

Representative structures: local elected representatives or union delegates; a Committee of the European Company (25 full and 25 alternate members, meeting at least four times yearly, five times in 2025) covering the EEA and the UK; and two employee-elected directors on the Board (p.137). "The Sustainability Statement was presented to the Committee of the European Company and consulted on by the Works Council of Dassault Systemes SE" (p.137).

Remediation processes and channels for own workforce

Reference: pages 136, 141.

"Any breach of applicable laws and regulations and the Code of Business Conduct may be reported through the Dassault Systemes Whistleblowing procedure" (p.136), available in 18 languages via email (people.ethicscommittee@3ds.com), an online form, a dedicated voicemail per country, or a meeting request with ethics officers (p.171, cross-referenced to the employee-facing process at p.136). "All breaches related to discrimination and harassment are assessed on a case-by-case basis... Substantiated cases result in disciplinary sanctions, proportional to the severity of the incidents" (p.141). Employee representatives "have been informed or consulted about the Code of Business Conduct and the applicable Whistleblowing procedure" (p.141).

Actions on material impacts on own workforce

Reference: pages 130-144.

Actions are organised by strategic matter: matter 5 (talent attraction, OW3/OW5/OW6) through proactive sourcing, a referral program, and the "Learning and certification" policy's 7,000+ training contents (pp.130-133); matter 6 (engagement/retention, OW1/OW4/OW8) through the "Total rewards" policy, a third employee-shareholding plan (99% workforce coverage), and long-term incentive grants (pp.135-137); matter 7 (inclusion, OW2/OW7) through mandatory discrimination/harassment training revised in 2025, the Diversity Fresco workshop (500+ participants since April 2025), and the Rise Up! leadership program (62% women participants in 2025) (pp.140-142). The Company "has not identified any material impact, risk, or opportunity for its employees arising from the implementation of its environmental Transition plan" (p.127).

Targets related to own workforce

Reference: pages 139-140, 142, 144.

Quantified targets: employee pride/satisfaction 74-78% by 2027 (76.2% achieved in 2025, down 2.2 points); women on the Executive team 40% by 2027 (41.7% achieved); women among People managers 30%, postponed from 2027 to 2029 (25.8% in 2025); 95% of employees trained in ethics and compliance by 2027 (98.0% achieved) (pp.139-144).

"The Company has not yet set quantitative targets for the other topics related to [strategic matter 6, engagement]. Nevertheless, it monitors the efficiency of its policies and actions using the metrics listed above" (p.140). Likewise for strategic matter 5 (talent), targets exist only for job-offer fill rate proxies, not a headline quantitative commitment.

Characteristics of employees

Reference: pages 137-139, 73.

Total headcount 24,997 (2024: 25,000), of which 98.0% permanent and 2.2% part-time; 491 temporary employees (75% on apprenticeship contracts). By region: Europe 10,472 (42%), Americas 6,518 (26%), Asia 8,007 (32%), covering 45 countries (p.73, 138). By gender: 17,373 men, 7,459 women, 60 "other," 105 not disclosed (p.138). By function: 40% R&D, 47% Sales/Marketing/Services, 13% General Administration (p.73). Total turnover was 8.4% (voluntary turnover 6.0%) (p.139). Methodology notes: "the reporting scope covers the total workforce," each employee counted as one unit "regardless of the applicable labor hours" (p.130).

Collective bargaining coverage and social dialogue

Reference: pages 137-139.

"Employees are covered by independent employees' representatives in 19 countries, including one non-EEA member, and benefit from collective bargaining agreements in 11 countries, including one non-EEA member." Percentage of employees covered by collective bargaining agreements: 33.9% in 2025 (up 0.7 points on 2024). 100% of headcount in EEA member countries has employees' representatives, covering 41.2% of the total workforce (p.139). Dialogue frequency with representatives "may be held on a weekly, bi-monthly, or monthly basis" depending on country and topic (p.137). "Dassault Systemes is committed to respecting its employee's right to associate freely, form and join unions... and bargain collectively as permitted by and in accordance with applicable laws and regulations" (p.137).

Diversity metrics

Reference: pages 141-143.

Gender: women 29.8% of total workforce (+0.2 points); by function, 23.4% in R&D, 30.3% in Sales/Marketing/Services, 47.9% in General Administration (p.143). Top management: 41.7% women (12 members, 5 women) (p.143). People managers: 25.8% women (-0.5 points) (p.142-143). Age: 19.2% under 30, 58.5% aged 30-50, 22.4% over 50 (p.142). Board of Directors: 50% women excluding employee representatives, 57% including them (cross-referenced from GOV-1, p.62).

Disability reporting: "the percentage of employees with disabilities requiring specific reporting covering all countries of operations... will be disclosed in 2026" (p.144) - a stated methodological gap, not a current datapoint.

Training and skills development metrics

Reference: pages 131-134.

Percentage of employees receiving a learning action: 99.1% (2024: 98.5%) (p.134). Annual performance review participation: 96.0% men, 95.5% women (2024 split not fully disaggregated) (p.134). The 3DEXPERIENCE University offers "over 7,000 training contents," comprising 134 role-related, 163 brand-related and 235 industry-segment-related programs, maintained by more than 270 employees (p.133). Recruitment-adjacent training metrics: 2,242 job offers filled (94.4% under permanent contracts), 2,368 new joiners, of which 88.3% through recruitment and 11.7% through acquisition (p.134).

Compensation metrics (pay gap and total compensation)

Reference: pages 143-144.

Unadjusted gender pay gap: 9.7% in favor of men (down 0.4 points), "explained by the lower representation of women in certain positions... particularly in Research and Development and Sales, Marketing and Services functions" (p.144). Adjusted pay gap (comparative-ratio methodology, like-for-like roles): 1.4 percentage points in favor of women (down 0.3 points) (p.143-144). CEO pay ratio: 159.4x the median annual total compensation of all employees (2024: 189.6x) (p.143-144).

Methodology: the adjusted pay gap "excludes employees from CENTRIC entities and covers 95.2% of employees"; CENTRIC compensation data is estimated via peer comparison (p.144).

Incidents, complaints and severe human rights impacts

Reference: pages 138, 143-144.

Severe human rights issues and incidents: 0 in both 2025 and 2024, including zero cases of non-respect of the UN Guiding Principles/OECD Guidelines, and zero National Contact Point complaints (p.138). Substantiated cases of discrimination (including harassment): 10 in 2025 (unchanged from 2024), resulting in "disciplinary sanctions, proportional to the severity of the incidents"; no fines, penalties, or compensation for damages were paid in relation to these incidents (p.143-144). A stated data gap: "the number of work-related complaints or incidents requires to adapt the internal communication channel to all the topics listed by the standards. As a result, this metric could not be published in 2025 and will be included in 2026" (p.139).

Policies related to value chain workers

Reference: pages 144-147.

Upstream, "Dassault Systemes has not identified any material IROs related to these workers," but relies on a contractual framework and the Sustainable Charter with Suppliers "to minimize its potential social impacts" (p.145). Downstream, the material scope is the reseller/integrator network (more than 18,000 employees), managed through the "Supporting indirect sales networks for Dassault Systemes' solutions" policy (partner integration, commercial alignment, coaching, certification) and the "Training and certification of sales ecosystems for Dassault Systemes' solutions" policy, both overseen by the EVP, 3DS Global Brands, and excluding CENTRIC and MEDIDATA brands (pp.145-146).

Engaging with value chain workers

Reference: page 146.

"Dassault Systemes maintains constant dialogue with its resellers and integrators to assess training needs and assess the positive impact of certification programs on their business," through dedicated events including 3DEXPERIENCE World (around 3,600 attendees in 2025), three regional forums (approximately 1,300 employees from 500 partner companies) and a Technical Partner Forum (p.146). "These discussions, led by network managers under the supervision of the Executive Vice President, 3DS Global Brands, are assessed by measuring participation rates in events and training courses" (p.146).

Actions on material impacts on value chain workers

Reference: pages 145-146.

2025 actions under the two policy levers: integration sessions for new partners; quarterly teleconferences between management and partner employees; cybersecurity certification requirements for partner sales staff; coaching on sales methodology; a role-based development plan; 184 webinars on systems engineering, modeling/simulation and manufacturing organization; and invitations to partner employees for technical training alongside new Dassault Systemes hires (p.146). Share of sales engineers certified or trained on the Company's solutions: 71% in 2025 (down from 80% in 2024, "due to changes in the certification criteria for sales partners"); 5,407 system integrator employees certified, up from 4,400 (p.146).

Targets for value chain workers

Reference: page 146.

No quantitative target is set. "Dassault Systemes is not in a position to publish a quantitative target given the diversity of stakeholders involved, nor to communicate on the timeframe in which it will be able to do so. Nevertheless, the Company continues to reflect on setting medium-term ambitions and monitors the efficiency of its policies and actions through the metrics presented above" (i.e., the 71% certification rate and integrator-employee count) (p.146). Methodology: these metrics depend on data collected from commercial partners and so "have a limited degree of reliability" (p.146).

Policies related to affected communities

Reference: pages 147-150.

Affected communities include employees, job applicants, business-relationship employees, solution users "including patients participating in clinical trials managed on the MEDIDATA platform" (AC1/AC2), and civil society/patients benefiting from medical-research acceleration (AC3/AC4); patients are flagged as "a category that should be considered more vulnerable due to the particularly sensitive nature of health data" (p.147).

The core policy is "Personal data protection," built on risk assessment, prevention/security, incident responsiveness (including an online form to the Group Data Protection Officer), and continuous improvement via the Trust Center; it covers all legal entities except CENTRIC and OUTSCALE, proposed by the Group Data Protection Officer and approved by the EVP, CFO (pp.149-150). It complies with GDPR and is structured in three parts: compliance, certifications (ISO 27701) and awareness/training (p.150).

Engaging with affected communities

Reference: page 150.

Data subjects "may exercise their rights via an online form; access user communities; contact support services." The Company "adopts the Privacy by Design and Privacy by Default approaches," obtains "explicit consent, where required," and conducts impact assessments "particularly on sensitive data such as health data" (p.150). Commitments are verified by "regular... internal and external audits" (p.150). For strategic matter 10 (patient health), engagement runs through the Patient Insights Board (created by MEDIDATA in 2019, patients who have participated in clinical trials) and a 2025-created advisory committee dedicated to the MEDITWIN project (p.152/156).

Remediation processes and channels for affected communities

Reference: page 150.

"To ensure the protection of personal data, Dassault Systemes has implemented rigorous internal processes, particularly in the event of a security breach... an incident log is maintained." The Trust Center provides detailed documentation on cybersecurity risk, and "users can also share their concerns or complaints through public forums (such as Swym communities), support services, and dedicated contact forms" (p.150). "For the year 2025, no complaints from data subjects were forwarded by a public authority, and no cross-border requests for the transfer of personal data were sent to the Group Data Protection Officer's teams" (p.150).

Actions on material impacts on affected communities

Reference: pages 150-156.

Strategic matter 9 (AC1/AC2, data protection): new/revised personal-data certifications published in the Trust Center, a reviewed incident-management/breach procedure, and mandatory annual personal-data-protection training (p.150-151). Strategic matter 10 (AC3/AC4, patient health): MEDIDATA's clinical-trial transformation strategy (decentralized trial monitoring via wearables), the MEDITWIN consortium (300+ doctors, researchers and patients across 7 university hospitals), and continued philanthropic research support via La Fondation Dassault Systemes in the US, India and Europe (pp.154-156). "The 3DEXPERIENCE platform is used to model 50% of the world's drugs and medical devices" and MEDIDATA "has enabled 37,000 clinical trials... involving approximately 11 million patients" since 1994 (p.152).

Targets for affected communities

Reference: pages 151, 155.

Data-protection target (strategic matter 9): "at least 95% of its employees must complete and pass annual training on Personal Data Protection," achieved at 97.3% in 2025 (+1.9 points); "mandatory cybersecurity training will be integrated into this indicator starting in 2026" (p.151).

Patient-health target (strategic matter 10): "Dassault Systemes does not publish quantitative targets on the impact of its activities in the Life Sciences & Healthcare sector for reasons of confidentiality vis-a-vis the competition. The Company also does not involve patient communities in setting these targets" (p.155), consistent with the stated intellectual-property/confidentiality omission declared at section 2.2.1.1.4 (p.62).

Policies related to consumers and end-users

Reference: pages 157-165.

Consumer/end-user impacts split into: EU1 (cybersecurity/intrusion risk, strategic matter 9) and EU2 (positive impact on engineer lifelong learning and innovation ecosystems, strategic matter 8) (p.157). Key policies: the "Cybersecurity" policy, aligned with ISO standards, NIST guidelines, ANSSI/EBIOS and the MITRE ATT&CK Enterprise Framework (p.158-159); the AI Ethics Charter, adopted in 2025, covering "transparency, explainability, sustainability, security, human oversight, intellectual property protection, and privacy" (p.159); and the "Education" strategy and "Philanthropy" policy run through the 3DEXPERIENCE Edu organization and La Fondation Dassault Systemes (pp.162-163).

Engaging with consumers and end-users

Reference: pages 158-159, 164.

For cybersecurity/data matters, the Company communicates through "its Trust Center and user communities," with users able to "share their concerns or complaints through public forums (such as Swym communities), support services, and dedicated contact forms" (p.158-159). For the academic/innovation-ecosystem impact (strategic matter 8), engagement runs through "dedicated collaborative platforms" linking students/professors with Dassault Systemes experts and "communities of excellence for teachers and Company employees" that co-develop educational content incorporating teacher feedback (p.164).

Actions on material impacts on consumers and end-users

Reference: pages 159-165.

Cybersecurity (EU1): "Security in Depth" architecture, AI-enabled solution security features, a partnership with Mistral AI via OUTSCALE's sovereign cloud for secure Generative AI, a complete Trust Center overhaul (CSIRT presentation, vulnerability advisories, a Private Bug Bounty program), and new/renewed certifications (TISAX, SOC2, ISO 27001/27701/27017/27018) (p.160-161). Share of cybersecurity incidents managed per the Incident Response plan: 100% (unchanged); share of employees trained on cybersecurity: 99.1% (+2.6 points) (p.161).

Education/innovation (EU2): more than 230 academic-partnership initiatives across a network of 450+ institutions; more than 10 million students supported cumulatively by end-2025 (p.165).

Targets for consumers and end-users

Reference: pages 159-165.

Cybersecurity targets (strategic matter 9): "handling 100% of incidents in accordance with its Incident Response plan" (achieved) and "train at least 95% of its employees in cybersecurity" (achieved at 99.1%); set internally without stakeholder consultation because "the target of handling incidents... is already at its maximum" and "the training is mandatory" (p.161).

Education/innovation (strategic matter 8): "Dassault Systemes has not set a quantitative target for the positive impact of academic, innovation, and research ecosystems given the diversity of stakeholders involved. Nevertheless, the Company is monitoring the efficiency of its policies and actions through [the >10 million cumulative student] metric" (p.165).

Business conduct policies and corporate culture

Reference: pages 169-171.

Core documents: the Code of Business Conduct (implemented 2004, last revised 2024, covering regulatory compliance, ecosystem interactions, asset/IP protection) and the Corporate Social Responsibility Principles (prohibiting child/forced labor, all discrimination, guaranteeing safe working conditions, minimum-wage compliance, freedom of association, zero tolerance for corruption/influence peddling, and environmental/data-protection compliance), both proposed by the Director of Business Ethics and Compliance and approved by the EVP, CFO (p.170). The Ethics Committee meets monthly and comprises senior management including the General Secretary, EVP/CFO, General Counsel, Internal Audit Director and People Ethics Director (p.171). Training: all employees undergo mandatory annual Code of Business Conduct training, available in 17 languages (p.171).

Management of relationships with suppliers

Reference: pages 167-169.

Strategic matter 11 (negative impact G1, on supplier treasury from late payment) is managed through the "Responsible procurement" policy (20% ESG weighting in major tenders, decarbonization focus) and the Sustainable Charter with Suppliers, which sets "reciprocal commitments" on environment, human rights and anti-corruption and is a prerequisite for supplier registration (excluding CENTRIC) (p.168). The RFAR (Responsible Supplier Relations and Purchasing) label, renewed in 2025, "confirmed that Dassault Systemes' purchasing practices remain aligned with the ISO 20400 standard" (p.168). A supplier-risk mapping exercise combining EcoVadis sector/country data with internal criticality/spend criteria is "currently being updated" (p.169).

Prevention and detection of corruption and bribery

Reference: pages 171-175.

Zero-tolerance anti-corruption program, compliant with the FCPA, UK Bribery Act and France's Sapin II law, run by the Business Ethics & Compliance department with a Compliance Ambassadors network (p.172). Prevent: Code of Business Conduct, "Anti-corruption" policy, Sustainable Charter with Suppliers, Whistleblowing procedure, and recommendations on intermediaries, conflicts of interest and gifts; functions most exposed to corruption risk (under 2% of the workforce, identified via a 2025-updated risk map) receive in-depth sessions, with 100% of the most-exposed roles covered (p.173). Detect: Whistleblowing alerts, internal accounting controls, and Internal Audit reviews (p.174). Remediate: the Ethics Committee reviews non-compliance cases and issues corrective measures/sanctions (p.174). 2025 metrics: 99.8% of employees trained on anti-corruption; 430 third-party due-diligence checks; 60 cases examined by the Ethics Committee (up from 46) (p.175).

Targets related to business conduct

Reference: page 175.

"The target percentage of employees trained in ethics and compliance is 95% for 2025." Achieved performance was 98.0% (average of Code of Business Conduct, Personal Data Protection and Anti-Corruption training completion), up 1.4 points on 2024's 96.6% (p.175, cross-referenced p.144). This single combined ethics-and-compliance training target is the company's stated MDR-T target for the business-conduct topic; no separate quantitative target is disclosed for the individual G1 sub-topics (supplier payment practices, political lobbying) beyond this training metric.

Incidents of corruption or bribery

Reference: pages 174-175.

Number of convictions for violation of anti-corruption and anti-bribery laws: 0 (2025 and 2024); amount of fines for violation of anti-corruption and anti-bribery laws: 0; amount of financial political contributions made: 0 (p.174-175). 60 cases were examined by the Ethics Committee following suspicions of non-compliance in 2025 (up from 46 in 2024, +30.4%), with 100% of disciplinary-sanction cases resulting in proportionate sanctions where non-compliance was confirmed (p.175). "Dassault Systemes conducts limited lobbying activities, mainly in Europe. The estimated annual cost of these activities, as reported to the European Union, is between EUR500,000 and EUR599,999" (p.174).

Political influence and lobbying activities

Reference: pages 172-174.

"As a scientific company specializing in the research and development of innovative software, lobbying activities are limited to a few strategic topics such as industrial and digital sovereignty, sustainable innovation, and policies related to Life Sciences & Healthcare. Dassault Systemes does not make any political contributions or grant any benefits to promote or support any political party or public officials" (p.173).

Registrations: EU Transparency Register (number 454608238523-04), where budgets and activities are published, and the French HATVP (Haute Autorite pour la Transparence de la Vie Publique), with an annual activity report published on the HATVP website (p.173). Estimated EU lobbying cost: EUR500,000-EUR599,999 (p.174). "No member of the administrative, department, or supervisory bodies appointed in 2025 has held a comparable position in a public administration during the two years preceding their appointment" (p.173).

Payment practices

Reference: pages 168-169.

Average number of days to pay an invoice from invoice date: 37 days in 2025 (unchanged from 2024); contractual payment terms are set "without distinction between supplier categories... [varying] from 30 to 60 days depending on the country" (p.169). Percentage of payments made on-time: 86.0%, down 3.0 points from 89.0% in 2024. Number of outstanding legal proceedings for late payments: 0 (both years) (p.169). Methodology: these metrics "cover the entire scope of Dassault Systemes, with the exception of newly acquired companies or those in process of being integrated, which account for 11% of the Company's purchases" (p.169). The Company states it has, on an exceptional basis, "implemented early payment cycles" for suppliers facing liquidity difficulty (e.g. during COVID-19) (p.168).