De' Longhi

Reference: pages 46-48.

The Board of Directors (12 members in 2025: 3 executive, 9 non-executive, 42% female) oversees sustainability strategy through three board committees: the Control and Risk, Corporate Governance and Sustainability Committee (CCR), which handles "the identification, approval, and monitoring of impacts, risks, and opportunities identified in the double materiality assessment"; the Remuneration and Appointments Committee (CRN); and the Independent Committee.

Management roles: the Chief Financial Officer (CFO) is "responsible for sustainability reporting and the related certification of compliance with reference standards and regulations"; the Group Sustainability Director (established 2023) reports directly to the CEO and "is responsible for defining, implementing, and supervising sustainability strategies at the Group level"; the Group Sustainability Council (CEO, General Manager, Professional-division CEO, Chief Corporate Services Officer, Group Sustainability Director) "endorses and supports the Group's sustainability strategy"; and Internal Audit provides independent oversight of ESG risk-management systems.

No employee or worker representatives sit on the Board; the company states Italian law and its Articles of Association "do not provide for the representation of employees or other workers within said bodies."

Reference: pages 48-49.

"Sustainability and ESG reporting are standing items" were not stated verbatim for De' Longhi, but the CCR Committee's "specific investigative, propositional, and advisory functions" in evaluations and decisions regarding sustainability are exercised on an ongoing basis, and it "acknowledges the information provided by the delegated bodies and the Manager in charge of preparing the corporate accounting documents" on the adequacy of periodic sustainability information.

At the first available Board meeting, and in any case at least semi-annually, the Chairman of the CCR "informs the Board of Directors about the topics discussed, the observations and recommendations that emerged, as well as the opinions expressed by the Committee." The Group Sustainability Director "provides periodic updates on the company's strategic sustainability guidelines" based on periodic meetings with the CCR. Through the double materiality assessment, "the Group identifies the most relevant issues, allowing the BoD and the responsible committees to make informed strategic decisions, integrating the evaluation of impacts, risks, and opportunities into the oversight process of the corporate strategy and managing any trade-offs."

Reference: pages 49-50, 63.

The 2025 Remuneration Policy provides an annual variable component (MBO) and, as in 2024, a medium/long-term variable component via the De' Longhi 2024-2026 Performance Share Plan for the CEO, General Manager and a limited number of top managers.

"The variable portion paid in 2025 and linked to 2024 performance targets related to Sustainability stands at 15%." The ESG performance targets underlying that portion include: submission of SBTi targets and definition of an emissions reduction strategy; increasing women in senior management; energy-efficiency projects for coffee machines; increasing polystyrene-free packaging (target 70%, achieved 72%) and digital user manuals (target 25%, achieved 31%); and completing at least 30 supplier social audits (achieved 36).

Starting 2025, Board committee members are paid "exclusively attendance fees, without the payment of any fixed amount."

Reference: page 50.

"The De' Longhi Group does not yet have a fully structured due diligence process in place; consequently, it is currently not possible to provide a comprehensive mapping of how the main aspects and phases of the process are integrated into the Sustainability Reporting." The company reports that it launched, in 2025, "an initial assessment exercise along the value chain by administering a questionnaire to suppliers" to identify impacts, risks and opportunities and define corrective actions (see S2-4). "The formalization of the process and the related policy is scheduled for 2026."

This is a direct, negative statement of due-diligence maturity rather than a refusal to disclose: the Group reports plainly that a formal, mapped due-diligence process does not yet exist and gives a target date (2026) for formalising it.

Reference: pages 50-51.

"During 2025, the Group launched the development of an internal control system over sustainability information, with the aim of mitigating the risks of data misstatement." Specific quantitative datapoints were selected based on alignment with the Sustainability Plan, linkage to management incentive systems, and reliance on third-party data or estimates. "Starting from the current financial year (2026), the internal control system over sustainability information is subject to testing activities referring to 2025 annual data, with the objective of verifying the operating effectiveness of the defined controls."

Identified anomalies trigger "the definition and implementation of a remediation plan." Results of testing generate information flows to the relevant Operating Functions on any deficiencies found, with periodic reporting to administrative, management and supervisory bodies. The control system is "integrated with the existing framework for financial reporting."

Reference: pages 51-53.

De' Longhi S.p.A. is the holding company of a group with 10,304 employees (2025), active in small domestic appliances across coffee, food preparation and cooking, air conditioning, heating, and home care. Brands: De' Longhi, Kenwood, Braun, Ariete, Nutribullet, plus Eversys and (from 2024) La Marzocco in professional coffee machines. Listed on Euronext Milan; products distributed in "more than 120 markets worldwide," with production hubs in Italy, China, Switzerland and Romania alongside a network of OEM partners.

The value chain runs from raw-material extraction through transformation, manufacture, outbound logistics, selling, product use, aftermarket services and end-of-life, with upstream and downstream stages shown in a dedicated value-chain diagram (pages 51-52). Three areas of sustainability commitment guide the 2024-2026 strategy: decarbonizing the value chain, embedding sustainability into product design, and promoting awareness among employees, consumers and communities.

Reference: pages 53-55.

Nine stakeholder categories are mapped with role in the value chain and engagement method (Table 3): Employees (training, trade-union dialogue), Suppliers (audits, periodic meetings), Consumers (customer care service), Shareholders (Sustainability Reporting, Sustainability Plan), Trade Associations, Communities and NGOs, Future Generations, Financial Analysts and Media, and Business Partners, Universities and Research Centers.

Key internal stakeholders -- particularly Finance, Internal Audit and Sustainability -- were involved in the double materiality analysis, discussed at Group Sustainability Council meetings attended by the CEO and General Manager. Product issues raised by consumers are shared with the relevant functions and administrative bodies "to ensure alignment between corporate strategy and stakeholder expectations." Suppliers are reached through a dedicated portal carrying the Code of Ethics and Responsible Sourcing Guidelines in Italian, English and Chinese.

Reference: pages 56-60 (Table 4, material IROs).

The double materiality analysis confirmed, without significant change versus the prior year, 7 material ESRS topics: ESRS 2, E1, E5, S1, S2, S4 and G1 (E2, E3, E4 and S3 were assessed and found non-material; see Table 6, pages 63-64). The 45 individually typed impacts, risks and opportunities identified span climate change and energy (E1), resource use and waste (E5), own workforce (S1), value chain workers (S2), consumers (S4) and business conduct (G1); see the iro_counts file for the full breakdown.

"All impacts, risks, and opportunities are covered by the disclosure requirements set out in the ESRS; therefore, no further entity-specific disclosures are required." Per the BP-2 phase-in disclosure (page 45), information on the anticipated financial effects of material IROs otherwise required under this paragraph is omitted under the ESRS 1 Appendix C transitional provisions for 2025 (see E1-9 and E5-6).

Reference: pages 56-60.

The double materiality analysis (impact and financial materiality) was updated from the prior year "with the support of external consultants," confirming the absence of significant changes. Impact materiality used scale, scope and irremediable character for negative impacts (scale and scope only for positive impacts), plus likelihood assessed "gross" (without mitigation); human-rights-related potential negative impacts weight severity over likelihood. Financial materiality considered magnitude and likelihood over short/medium/long term, using the same thresholds as the Group's Enterprise Risk Management (ERM) system, into which the DMA results feed.

Climate-specific IRO identification and scenario analysis is also presented under [E1-2-ScenarioAnalysis]: physical risk was modelled over three time horizons (2030/2050/2085) using IPCC AR6 scenarios RCP2.6/SSP1, RCP4.5/SSP2 and RCP8.5/SSP5 across all Group production plants, producing Annualized Asset Damage Values; transition risk used a single 2030 horizon and a qualitative four-category framework (regulatory/legal, market, technological, reputational).

Reference: pages 60-65 (Table 5, material DRs, pages 61-62; Table 6, non-material topics, pages 63-64; Table 7, other EU legislation, pages 65-82).

Table 5 lists, with page references, the disclosure requirements committed to under the DMA: all of ESRS 2 (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1/IRO-2), E1 (SBM-3, IRO-1, E1-1 to E1-7; E1-9 and SBM-3's financial-effects content flagged "DR subject to transitional provisions"), E5 (IRO-1, E5-1 to E5-5, E5-5-Waste; E5-6 similarly flagged as subject to transitional provisions), S1 (SBM-2/SBM-3, S1-1 to S1-10, S1-13, S1-14, S1-16, S1-17; S1-11, S1-12 and S1-15 flagged as subject to transitional provisions), S2, S4 and G1 (G1-1, G1-3, G1-4 only).

Table 6 lists topics "identified as non-material and/or not applicable to the Group": all ESRS E2, E3 and E4 sub-topics, all ESRS S3 sub-topics, plus the S1 sub-topic "Adequate housing" and the G1 sub-topics "Political engagement and lobbying activities" and "Management of relationships with suppliers, including payment practices."

Reference: page 85 (targets also at pages 88-89).

In 2025 the Group obtained Science Based Targets initiative (SBTi) validation of its near- and long-term targets: -58.8% Scope 1 & 2 emissions by 2034 and -35% Scope 3 emissions by 2034, both vs. a 2023 baseline, with net zero by 2050. "Prior to joining the SBTi, a feasibility analysis of the transition plan was carried out to support the definition of the targets." Operational implementation of the plan began in 2025 and "the Group expects to complete [it] by 2027."

The plan sits within the 2024-2026 Sustainability Plan, whose climate initiatives are detailed under [E1-3]. De' Longhi is not excluded from EU Paris-aligned benchmarks information; no explicit statement on CapEx/OpEx allocated specifically to the transition plan as a whole is given (see the itemised photovoltaic CapEx of €333,629 under E1-3).

Reference: back-filled from ESRS 2 IRO-1 / the E1 climate-risk section, pages 83-85. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk was assessed over three time horizons (2030, 2050, 2085), each representing a ~20-30 year averaging window, across all of the Group's production plants, using three IPCC AR6 scenarios: RCP2.6/SSP1 (low emissions, 1.5-2°C), RCP4.5/SSP2 (intermediate, 2.5-3°C) and RCP8.5/SSP5 (high emissions, >4°C, "Extreme" risk classification by 2030). Transition risk was assessed over a single short-term horizon (2030) using the same three scenarios, via regulatory, benchmark, industry and coffee-market-trend analysis, across four risk categories (regulatory/legal, market, technological, reputational).

Gap: the report itself notes that RCP2.6/SSP1, although "representing a strong mitigation trajectory close to the goals of the Paris Agreement, does not fully correspond to a scenario aligned with limiting global warming to 1.5°C with no or limited overshoot" -- so no scenario meeting ESRS E1-2 ¶17(a)(ii) is used for transition risk. No analysis date or refresh frequency is stated.

Reference: back-filled from ESRS 2 SBM-3 / IRO-1, pages 83-84. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company states plainly: "an in-depth resilience analysis of the strategy and business model with respect to the possible effects of climate change has not yet been carried out" (SBM-3, 19). This follows directly from the physical- and transition-risk analyses described under [E1-2-ScenarioAnalysis], whose results "formed an integral part of the update of the financial materiality analysis," assessing potential impacts on revenues, operating costs, investments and supply-chain continuity -- but stopping short of a formal ESRS-defined resilience assessment of strategy and business model.

No statement is given on areas of uncertainty or on capacity to adjust or redeploy financial resources specifically tied to climate resilience.

Reference: pages 85-87.

The Group's Environmental, Health & Safety (EHS) Policy, approved by the CEO, entered into force 1 September 2025, replacing the previous Environmental Policy; it guides action along three directions -- "Progressing Over Emissions, Designing Tomorrow, and Caring Together" -- covering reduction of the carbon footprint via SBTi-validated targets, gradual replacement of fossil fuels, sustainable product design via the Eco-Design Guidelines, and reduced landfill waste. "The Group also plans to develop a specific policy dedicated to climate change mitigation and adaptation; to date, this activity is still ongoing."

The policy covers the Group's "entire perimeter and all its activities," with ultimate responsibility resting with the CEO, and aligns to SDG 3, 5, 12 and 13. Certifications: ISO 14001:2015 (environmental management) and ISO 45001:2018 (progressively rolled out).

Reference: pages 87-88.

Key 2025 actions: self-production of renewable electricity expanded (new solar panels planned at Satu Mare, Romania, for 2026, alongside existing installations at Mignagola, Treviso, Scarperia, San Piero, Cluj and Sierre); €333,629 of CapEx already incurred in 2025 for photovoltaic systems at Sierre and Cluj; LED lighting conversion completed in China and underway in Romania (target 2026); new electric plastic-injection presses in China cutting energy use 30-32%; progressive fleet electrification (diesel/gas reduction targeted by 2027); and recalibration of coffee-machine testing at Mignagola to cut energy use.

La Marzocco submitted two ENEA energy audits (Scarperia, Accademia del Caffè Espresso sites) in 2025. "For the listed initiatives, aimed at reducing the Group's impact on climate change, present or anticipated GHG emission reductions have not yet been quantified."

Reference: pages 88-89.

Table 2, Climate change mitigation targets, tracks seven initiatives against 2022 baselines. Progress at 31 December 2025: SBTi targets submitted and validated (-58.8% Scope 1&2 and -35% Scope 3 by 2034 vs. 2023, net zero by 2050); 100% of production-plant electricity certified renewable via Guarantees of Origin in both 2024 and 2025 (target achieved); energy-saving calibration changes now applied to 100% of fully-automatic coffee-machine production at Mignagola; travel-policy review completed; energy intensity per unit produced at 5.93 kWh; 57% of the company fleet hybrid/electric (vs. 16% in 2022, target 100% by 2027); and a packaging-footprint reduction pilot "launched in 2025... currently underway."

The 2023 baseline is described as "representative of De'Longhi's operations, as it reflects the entire organizational scope and no exceptional events occurred."

Reference: pages 90-91 (Tables 3-6).

2025 total energy consumption: 141,058 MWh (+5% vs. 133,861 MWh in 2024). Fossil-source consumption: 53,803 MWh (38%), down from 41% in 2024; renewable-source consumption: 86,634 MWh (61%), up from 58%; nuclear: 621 MWh (0.4%). Self-produced renewable energy (without fuels) rose from 3,950 to 5,007 MWh; self-production growth of 27% attributed to new Sierre, Switzerland photovoltaic panels. 100% of grid electricity purchased by industrial plants was covered by Guarantees of Origin in 2025.

Because the Group operates in the high-climate-impact "Manufacture of electrical equipment" sector, energy intensity is calculated at 37.67 MWh/€M of net revenue in 2025 (38.49 in 2024) against net revenues from high-climate-impact activities of €3,744.6M.

Reference: pages 91-93 (Tables 7-8).

2025 gross Scope 1 emissions: 10,796.6 tCO2 (-4% vs. 2024). Scope 2: location-based 38,542.6 tCO2eq (+9%), market-based 2,121.1 tCO2eq (-58%), reflecting 95% of purchased electricity covered by Guarantees of Origin/I-RECs. Scope 3: 7,718,386.0 tCO2eq (+15%), 99% of total emissions; Category 11 "Use of products sold" is 76% of Scope 3, Category 1 "Purchased goods and services" ~19% (+38% y/y on higher purchase volumes). Total GHG (market-based): 7,731,303.7 tCO2eq (+15%); intensity 2.06 tCO2e/€k revenue.

De' Longhi included 13 of the 15 GHG Protocol Scope 3 categories (franchising and transformation of products sold are "not applicable"). A footnoted limitation: Scope 1/2 factors are expressed in tCO2 while the summary reports tCO2e, "an interpretive limitation regarding the full comparability."

Reference: pages 94-95.

In 2024 the Group quantified the Rivelia coffee machine's footprint under PAS 2060 and offset all 2023 emissions (5,100 tCO2e) via a Vietnam water-purifier project; in 2025 it obtained ISO 14067 climate-footprint certification for Rivelia. La Marzocco continued its multi-year Rete Clima partnership (NBS/afforestation under "Foresta Italia") and, in 2025, renewed three new VCS-Verra/Gold Standard-certified projects (Soubré Hydropower, Ivory Coast; Envira Amazonia REDD+, Brazil; Mekong River Delta water purifiers, Vietnam) offsetting its 2024 Scope 1/2 and part of Scope 3 emissions.

Cumulative impact: 600 trees planted in Italy (2,490 tCO2eq at maturity) and "over 37,500 tCO2eq" offset through certified projects across 10 countries. All 2025 credits are biogenic, issued outside the EU, with none subject to or eligible for Paris Agreement Article 6 corresponding adjustment.

Reference: pages 96-98 (Table 1, policies).

Material E5 sub-topics identified by the DMA: resource inflows (including resource use), circular economy and waste, assessed across both own operations and upstream/downstream value-chain stages. Governing tools: the Environmental, Health & Safety Policy and the Handbook of Guidelines to Design Sustainable Products (adopted from 2023), which directs New Product Development to reduce energy consumption, increase durability and recycled-material content, ease disassembly, reduce material volume and toxicity, and improve material conservation.

Products follow a "Local for Global" approach complying with REACH and RoHS. Kenwood's "Build to Last Generations" and Braun's "Sustainable Design That Lasts" campaigns promote durability; a Kenwood Chef, for example, is tested for "more than 15,600 cake mixes and 10,920 pizza doughs," and 12 De' Longhi coffee-machine models (expanded to Kenwood products in 2024) hold the French LONGTIME durability certification.

Reference: pages 98-99.

De' Longhi's first Primadonna Automatic coffee machine (launched early 2025) incorporates over 30% recycled plastic (non-food-contact applications) and removes the second milk-frothing boiler. A 2025 project is replacing cardboard boxes with recycled-plastic containers, with dedicated box-tracking software and supplier engagement. A steel-scrap circularity loop with Acciaierie Venete and the University of Trento, active at the Mignagola plant, reintroduces lathe scraps into new steel-bar production. At Dongguan, China, plastic bags use recycled content and soy-based inks; most plants use recycled-material pallets.

La Marzocco conducted Life Cycle Assessments (e.g., of its best-selling Micra line) supported by a dedicated LCA software license, and a 2024 Ecodesign Manual for coffee machines; in 2025 it began an LCA study on a product prototype under a regional R&D grant.

Reference: pages 99-101 (Table 2, targets).

Table 2 tracks six resource-use targets against 2022/2023 baselines. 2025 progress: landfill waste reduction at 98% of waste reused/recycled/recovered (vs. 93% baseline, target 97% by 2025 -- exceeded); refurbishment pilot for Renova coffee machines concluded for fully-automatic models, launching for pump machines; 26% of aluminium in new models from recycled material (target 30% recycled plastic by 2027, in development); Eco-Design approach applied to 40% of 2025 new products (target 100% by 2028, without LCA for 10 pilot projects in 2023); 86% of products sold with polystyrene-free packaging (target 90% by 2028); 53% sold with digital instruction manuals (target 50% by 2025 -- exceeded).

"These objectives are not based on conclusive scientific data and... stakeholders were not directly involved in the process of defining them" is stated for the S4 targets table, not this one; E5-3's targets derive from the Eco-Design Guidelines and sustainable-product-development policies.

Reference: page 101 (Table 3).

Total weight of materials used (2025): 226,497 tonnes, up from 173,019 tonnes in 2024. Secondary (reused/recycled) components, intermediate products and materials (including packaging): 12,849 tonnes, 6% of the total -- down from 9% (15,547 tonnes) in 2024. Share of biological materials from a sustainable supply chain: 0% in both years.

Main material categories: metals (steel and aluminium for frames; copper for heating coils), plastics (ABS and polypropylene), glass (borosilicate for carafes/kettles), electronic components (PCBs, sensors including rare earths), and packaging (mainly paper/cardboard, with a growing share of FSC-certified and recycled content). A footnote flags that the EU Packaging and Packaging Waste Regulation has not yet finalised its recyclability-calculation methodology, so the reported values "may no longer be representative" once delegated acts are published.

Reference: page 102.

Waste data covers production plants only (offices excluded). 2025 waste directed to disposal: 820 tonnes total (532 incinerated, 25 landfilled, 264 via other methods) vs. 656 tonnes in 2024. Waste diverted from disposal (recycling + other recovery): 12,199 tonnes vs. 12,240 in 2024. "In 2025, the total amount of recycled waste was 9,733 tons, corresponding to 75% of the total waste produced; non-recycled waste amounted to 3,286 tons, equal to 25.0% of the total."

Product recyclability rate fell to 9% in 2025 from 12% in 2024, attributed to assumption changes: a 95% recovery-rate assumption applied to metallic-material purchase volumes for products, and a first packaging-specific recyclability analysis conducted in 2025 on one packaging type only. "Data relating to the expected durability of products... is not yet available, but is currently being studied," and no internal repairability-assessment system exists yet, "nor are there currently... official assessment systems available at the European level."

Reference: page 102 (Tables 4-5).

Waste generated in 2025: 13,019 tonnes (E5-5, 37a), mainly "plastic, metals, and electronic components resulting from the production process," plus paper/cardboard packaging waste, industrial dusts (resins, paints) and trace non-metallic minerals/rare metals from electronics.

Table 4 (waste diverted from disposal): 2025 recycling 9,733 t, other recovery 2,466 t, total 12,199 t (of which 62 t hazardous). Table 5 (waste directed to disposal): 2025 incineration 532 t, landfill 25 t, other disposal 264 t, total 820 t (of which 192 t hazardous). Circularity initiatives: Romanian plants (Cluj, Salonta) recycle 100% of annual moulding plastic waste (490 tonnes delivered in 2025, separated by ABS/ABS-PC); Eversys regenerated 242 electronic boards in 2025; Mignagola/Dongguan recover plastic moulding scraps internally; Italian operations participate in the Ecoped/Ridomus WEEE consortia.

Reference: pages 105-107 (Table 1, policies).

Core policies: the Human Rights Policy (developed 2025, formalised 2026; based on the UN Declaration of Human Rights, ILO Declaration, OECD Guidelines), the Code of Ethics, the Diversity, Equity and Inclusion (DEI) Policy (published 2024, covering gender, disability, age, sexual orientation, ethnicity, religion and other grounds under EU and national law), and a corporate-bodies Diversity Policy.

Despite the "current lack of a formal Groupwide policy for worker health and safety," all plants achieved ISO 45001:2018 certification from 2025, supported by rigorous prevention protocols and the "I am Safety" culture campaign. The whistleblowing channel is the Integrity Platform, managed by an independent third party to ISO 37001:2016, available to employees, suppliers and other parties; it handles reports of discrimination or harassment with anonymity and anti-retaliation guarantees.

Reference: pages 107-108.

Direct engagement channels: the annual Employee Engagement Survey ("Your Voice," run for the second time in 2025 with a new provider, 89% participation across more than 8,000 employees); the FORWARD performance-review platform (over 3,000 employees involved in 2025); periodic business-results meetings; the company intranet (redesigned in 2025 following an employee survey) and house magazine. Indirect engagement runs through employee representatives.

Operational responsibility sits with the Human Resources Division, with the Chief People Officer as point of reference, ensuring feedback is incorporated into decisions. The 2025 Your Voice results fed a global action plan built on two pillars: strengthening a "culture of recognition," and a talent-management transparency and feedback initiative. A targeted 2023 analysis of women's pay and workplace experience informed 2025 initiatives for vulnerable categories.

Reference: page 108.

The Integrity Platform whistleblowing system, compliant with ISO 37001:2016, lets employees, suppliers and other parties report illicit or Code-of-Ethics-non-compliant behaviour anonymously and confidentially, via an externally-hosted, encrypted platform. The Whistleblowing Committee -- comprising the Director of Human Resources, Director of Legal Affairs and Head of Internal Audit -- manages reports day-to-day and reports quarterly to the Risk and Control, Corporate Governance and Sustainability Committee and Supervisory Board; the Board of Directors monitors the procedure's overall effectiveness.

Victims of discrimination or harassment are encouraged to use the channel, with guaranteed anonymity and a commitment to prevent retaliation. Annual surveys, including the Employee Engagement Survey, and employee-representative involvement also help monitor wellbeing and identify problem areas.

Reference: pages 108-111.

Talent attraction: partnerships with Bocconi, Politecnico di Milano, Ca' Foscari, Padua and Trento universities; the Corporate Associate Program; an Ambassador-on-campus program (46 employee participants in 2025); a six-week IT Talent Academy (7 hires in 2025); and a 13-intern Internship Program. LinkedIn followers grew 20% in 2025 and 90% of completed hires came through the platform.

Health and safety: the "I am Safety" campaign and Safety Ambassadors; a forklift-pedestrian anti-collision system, fully installed in Romania's Satu Mare plant, 26 systems added at Salonta/Cluj in 2025 (27 more planned 2026). DEI: the People Development Compass project; Global DE&I Training reaching over 2,000 employees across 30 branches in 14 languages; the My Gift Time leave-donation program (1,137 hours collected since 2021); and partnerships including Valore D, InspirinGirls and Girls&Boys@work.

Reference: pages 111-112 (Table 2, targets).

Table 2 sets five own-workforce targets. Progress at 31 December 2025: 100% of Group plants ISO 45001 certified (target achieved, vs. a 2023 baseline with some plants certified out of 7); 28.6% of senior-management positions held by women (target 30% by 2028, vs. 26% baseline at September 2023); work-life-balance survey delivered in 2025 (target: improvement measured yearly); 95.9% of employees involved in training in 2025 (target 80% average 2024-2026 -- exceeded); and a STEM-for-women educational-orientation initiative launched in 2025 involving two Group employees (target: delivery in 2025, met).

Under EU Directive 2023/970 on Pay Transparency, the Group plans to strengthen remuneration transparency from 2026 and commits to its first Gender Pay Gap Report by 2027.

Reference: pages 112-114 (Tables 4-7).

Headcount at 31 December 2025: 10,304 (down from 10,641 in 2024; 9,837 in 2023). Gender split: men 51.8% (5,339), women 48.0% (4,942), other 1, not disclosed 22. Turnover: 2,227 leavers in 2025, a 21.6% turnover rate (down from 29.5%/3,136 in 2024), with the company attributing the rate to "the high turnover rate of blue-collar workers at the production plants." By region: Europe 68%, America & Asia 31%, MEIA 1%. By country (>10% of total): Italy 2,217, China 2,403, Romania 3,409 (2025).

Contract mix (2025): permanent 9,753, temporary 549, flexible-hours 2; full-time 10,062, part-time 242.

Reference: page 115 (Table 8).

Non-employee workers in De' Longhi's own workforce at 31 December 2025: 2,116 total -- 13 self-employed workers and 2,103 workers hired in outsourcing (up from 1,431 total / 1,415 outsourced in 2024). A footnote attributes the increase to "a methodological refinement in data collection" rather than a change in the underlying workforce. The category is defined to include "all the professional who work for De' Longhi without a direct employment contract," most commonly outsourced consultants, interns and self-employed specialists providing temporary services.

Reference: page 115 (Table 9).

At 31 December 2025, 62% of employees were covered by collective bargaining agreements, and 58% were covered by workers' representatives (up from 52% in 2024). Country-level coverage (Table 9) shows Italy and Romania in the 80-100% band for both collective-agreement coverage and social-dialogue coverage among EEA employees, while China sits in the 0-19% band for collective coverage among non-EEA employees.

Reference: page 116 (Tables 10-11).

Age breakdown 2025: under 30 = 1,463; 30-50 = 6,102; over 50 = 2,739 (total 10,304). Senior management by gender (Table 11): 2025 -- 7 men (70%), 3 women (30%), up from 2 women (22%) in 2023; total senior managers rose from 9 (2023) to 10 (2024-2025). De' Longhi cross-references its DEI approach described under S1-1 and S1-4 as the policy basis for these metrics.

Reference: page 116.

"When a minimum wage is established by law, this will be guaranteed as the base pay, along with all the benefits provided for under the law or contractual agreements. In countries where there is no legal minimum wage, fair compensation will be determined based on sector standards and the local cost of living." No quantified percentage of employees earning below an adequacy benchmark, and no country-by-country adequate-wage gap figure, is disclosed beyond this policy-level statement.

Reference: page 117 (Table 13).

Table 13 reports average training hours by gender and employee category, 2023-2025. 2025 figures include: men 27.4 hours average (up from 26.4 in 2023), women 25.5 (up from 22.1); by category, blue-collar worker average 25.6 hours, white-collar 27.9, and overall average 26.4 hours (up from 24.3 in 2023). A separate table reports the percentage of employees participating in performance/career-development reviews: 2025 average 31% (men 34%, women 27%), by category manager 67%, white-collar 76%, blue-collar 3%.

Training programs cover digital skills, managerial and organisational skills, communication, company culture, and a dedicated Google Workspace/Gemini AI program (over 1,400 and 2,200 employees trained respectively in 2025).

Reference: pages 117-118 (Tables 14-18).

2025: zero work-related deaths among employees and non-employees (Table 15, consistent with 2023-2024). Recordable workplace injuries (Table 16): 80 among employees (rate 3.98), up from 75 (3.5) in 2024; 10 among non-employees (rate 1.50). Recordable occupational diseases: 12 in 2025 (up from 5 in 2024, 2 in 2023). Days lost to injury/illness: 1,337 in 2025 (down from 1,401 in 2024). Health-and-safety management-system coverage: 88% of employees, 81% of non-employees in 2025 (down from 96%/93%, a change the company attributes to "a refinement in the calculation methodology"); 100% of production-site workers are covered via the Group's ISO 45001:2018 certification (achieved in 2025 across all plants).

Reference: pages 118-119.

The unadjusted gender pay gap was 40% in 2025 (35% in 2024); net of notional medium/long-term incentive-plan costs concentrated in senior Professional-division roles, it "would have stood at 34% in 2025 (33% in 2024)." The company attributes the gap to "a female workforce comprised of more blue and white-collar workers and fewer in managerial roles" and to unfavourable exchange-rate movements against the euro. The CEO-to-median pay ratio was 301 in 2025 (245 in 2024), also affected by medium/long-term incentive-plan costs.

Under EU Directive 2023/970, the Group plans to strengthen remuneration transparency from 2026 and commits to its first Gender Pay Gap Report by 2027. Blue-collar workers make up "more than 60%" of personnel, spread across geographies with very different labour costs, which the company says materially affects the ratio.

Reference: pages 119-120 (Table 19).

2025: 1 discrimination episode (verbal discrimination, Germany; "timely measures were adopted and the process is still ongoing"), down from 3 in 2024 (two in the US, one in New Zealand, which led to contract terminations) and 2 in 2023. 1 complaint lodged through company channels in 2025 (1 in 2024, 0 in 2023). Zero serious human-rights-violation incidents and zero related fines/penalties in all three years (2023-2025).

"De' Longhi does not support any kind of violence, harassment or discrimination at the workplace and is committed [to] providing a safe, inclusive and respectful environment through policy and specific actions," cross-referencing the S1-1 policy framework.

Reference: pages 122-123 (Table 1, policies).

Three policies govern value-chain workers: the Code of Ethics (extended to suppliers); the Supplier Code of Conduct (SCoC), covering forced/child labour prohibition and alignment with the UN Guiding Principles, ILO Declaration and SA8000, binding on first- and second-tier suppliers, subcontractors and business partners, with audit rights and termination rights for non-compliance; and the Human Rights Policy (developed 2025, formalised January 2026), covering workers from suppliers through to end consumers.

"As in the previous two years, in 2025 De' Longhi did not find any violations of the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines on value chain workers." The SCoC is published via a supplier vendor portal in Italian, English and Chinese, alongside the Responsible Sourcing Guidelines.

Reference: page 124.

"Despite De' Longhi's focus on value chain workers, to date no engagement processes have been implemented that allow suppliers to actively participate in strategic decisions." The Group does not participate in global framework agreements, enterprise agreements or global union federations on human rights, but joined the UN Global Compact (UNGC) on 30 September 2024. In 2025, two Group employees participated in the UNGC's "Business and Human Rights Accelerator" program, covering training with UN experts, peer exchange, and development of an internal action plan on human-rights issues across the value chain, spanning topics including resource use, pollution, human rights, workers' rights, human trafficking, product responsibility, climate impact, resilience, and data protection.

Reference: page 124.

The Integrity Platform whistleblowing system is extended to value-chain workers, who may anonymously report unlawful conduct via the Group's website; the Group "does not require [channels] to be set up locally at the workplace of value chain workers." Since the system was established, "no significant complaints have been filed" by value-chain workers specifically. "To date, De' Longhi has not developed structured processes to verify the effectiveness of actions to remedy its negative impacts on workers in the value chain," nor to assess whether value-chain workers are aware of, or consider reliable, these channels.

Reference: pages 124-125.

Finished-product suppliers are audited annually (new suppliers) or every two years (established suppliers), using an SA8000-based checklist covering six areas (Social Responsibility, Health & Safety, Environmental Compliance, Human Rights, Regulatory Compliance, Risk/Emergency Management), scored from "compliant" to "zero tolerance." In 2025, out of 221 audits carried out, no corrective action was required as all suppliers met the minimum requirements of the SCoC.

A separate 2025 supply-chain mapping exercise sent a compliance/sustainability questionnaire to "a sample of over 2,000 suppliers," including all suppliers of processed/semi-finished goods containing conflict minerals; by early 2026, remedial-action requests had been sent to "over 200 suppliers." "De' Longhi is currently unable to provide information on the resources and investments allocated to the management of material impacts."

Reference: page 125.

"To date, the De' Longhi Group has not established targets or engagement actions to manage its impacts, risks and opportunities relating to value chain workers." The stated reason: the Group "has decided to begin by mapping and collecting information along the supply chain (currently underway)... and then perform a risk analysis accordingly," setting targets once that analysis is complete. Because no targets exist, "it has not yet implemented tools to monitor the effectiveness of its actions involving workers in the value chain."

Reference: pages 128-129 (Table, policies).

Consumer-facing policies: the Code of Ethics; the Inclusive Product Guidelines (2025, adopted within De' Longhi, Kenwood and Braun, addressing age, disability/neurodiversity, ethnicity/culture, gender identity and socio-economic diversity); the Human Rights Policy (2025/2026, extended to consumers); the Cookie Policy and Privacy Policy (GDPR-aligned, data stored on Google Cloud Platform under ISO 27001/27017/27018); and the Food Policy and Product Integrity Policy (developed 2025, approved early 2026, covering food-contact material selection, migration testing, Food Safety Management, and "Safe-by-Design" criteria).

"In 2025, there were no recorded cases of human rights violations involving consumers." For remediation measures, the company cross-references S4-3.

Reference: pages 130-131.

Consumer feedback channels include email, social media, chat, satisfaction surveys and contact centres, analysed via SAP C4C CRM and Wonderflow (Voice-of-Consumer software covering "over 70 online sales channels"), with Gemini-AI-assisted analysis introduced in 2025. Market surveys in 2025 engaged "more than 39,000 people in 12 countries" on ergonomics, usability, performance and new-launch expectations. Loyalty is tracked via Net Promoter Score.

"Despite De' Longhi's commitment to actively engaging consumers in its positive impacts, at the moment the Group has not yet identified the categories of consumers most vulnerable to potential negative impacts." Service effectiveness is monitored via First Time Fix and Turnaround Time indicators.

Reference: pages 131-132.

Product-safety reports (from trade associations, social media, regulators, retailers, suppliers or consumers) are analysed and escalated to the Group Insurance & Product Risk Department ("Product Safety & Liability") and, where needed, the Legal Department; corrective actions can include product withdrawal or recall. An AI-based online self-service complaints channel provides initial answers, validated by specialists, now extended beyond Italy/English to Germany, Belgium, France and the Netherlands.

Retaliation risk for users of reporting tools is managed under the Code of Ethics' "Behavioral standards on the job." The company discloses whether it assesses consumer awareness and reliance on these channels, without providing a specific awareness metric (S4-3, 26).

Reference: pages 131-133.

Quality systems: ISO 9001 at every plant; ISO 22000 food-safety certification at Mignagola (Italy) and Cluj (Romania); HACCP/Codex Alimentarius-aligned food-safety management; an AI Visual Inspector for assembly QC; and external audits (Quality Evaluation, Technical Factory Audit, On Time Delivery, Order Fill Rate indicators).

2025 non-compliance incidents: an aluminium-release exceedance in imported Braun wafflemaker spare-part plates (disposed of per legal requirements), and a battery-overheating issue in a specific batch of Nutribullet NBG-100 units, triggering a voluntary corrective action in the UK, Japan and the Philippines in March 2025 with free replacement/refund offered. One labelling non-compliance (missing Romanian-language instructions on Kenwood food choppers) was promptly remediated. Over the prior three years, "no incidents regarding the circulation of personal data have been recorded."

Reference: pages 132-133 (Table 2, targets).

Two targets: (1) develop and implement Inclusive Product Guidelines (target 2025, baseline "no guidelines" at 2023) -- achieved via the 2025 Guidelines covering De' Longhi, Kenwood and Braun, piloted on the Kenwood "Multi Tasker"; (2) define a Group strategy for promoting a healthy and sustainable lifestyle, including food waste and responsible resource use (target 2026, baseline "no Group strategy" at 2023) -- advanced via Braun and Kenwood brand-website initiatives and the One Planet Food objective.

The company flags explicitly that "these objectives are not based on conclusive scientific data and... stakeholders were not directly involved in the process of defining them."

Reference: pages 134-136 (Table 1, policies).

The DMA identified as material "corporate culture, whistleblower protection, and active and passive corruption." Governing documents: the Code of Ethics; the Legislative Decree 231/2001 Organization, Management and Control Model (adopted by De' Longhi S.p.A., De' Longhi Appliances S.r.l. and La Marzocco S.r.l., covering financial-crime, corruption, health-and-safety and tax-crime risk); and the Supplier Code of Conduct.

The Integrity Platform whistleblowing system (ISO 37001:2016-aligned, EU Directive 2019/1937-compliant) is available in 8 languages as of December 2025, with an automatic transcriber added for accessibility, and a domain hosted outside company systems for independence. "The Group has yet to implement a policy for training in corporate conduct," though 231-Model training (including anti-corruption content) is mandatory for all Italian employees, with dedicated anti-corruption training for foreign-company staff.

Reference: page 137.

"Consistent with the trend seen in the last three years, in 2025 the Group did not record any episodes of corruption in its operations nor was it found guilty of corruption related crimes." Preventive controls: close monitoring of expenses, with direct investigation of the largest payments; a corporate-gifts policy requiring quarterly database registration for traceability; and investigative bodies (the Supervisory Board, the Whistleblowing Committee, internal and external audits) operating independently of the areas under review.

Anti-corruption training is delivered through the 231 Model's e-learning modules, mandatory for new hires at the Group's Italian companies; administrative, management and control-body members also receive anti-corruption/anti-bribery training. "Even if the Group had yet to conduct a specific analysis to determine the company divisions more exposed to risks of corruption," it is "considering implementing processes which will further strengthen its control and prevention system."

Reference: back-filled from G1-3 (Prevention and detection of corruption and bribery), pages 135, 137. No explicit business-conduct target is stated; MDR-T's effectiveness-tracking limb is satisfied instead.

No quantified anti-corruption target (e.g., a target audit-coverage rate or a target reduction in incidents) is disclosed. Effectiveness is tracked procedurally: "The Board of Directors is responsible for monitoring the effectiveness of the [whistleblowing] procedure," and the Whistleblowing Committee "reports every quarter to the Risk and Control, Corporate Governance and Sustainability Committee and the Supervisory Board." Expense monitoring, a quarterly corporate-gifts traceability database, and independent internal/external audits provide further periodic, structured review of the business-conduct control system described under G1-3, in place of a stated target.

Reference: page 137.

"Consistent with the trend seen in the last three years, in 2025 the Group did not record any episodes of corruption in its operations nor was it found guilty of corruption related crimes. In 2025, therefore, no public instances of corruption involving the Group emerged." No corruption-related fines, sanctions or convictions are reported for 2025, continuing the pattern described under G1-3.