Deceuninck

The role of the administrative, management and supervisory bodies

Composition

The Board currently consists of eight Directors:

• 1 Executive Director (CEO)
• 7 Non-Executive Directors
• 5 members (62.5%) are Independent Directors in accordance with the Code
• 2 Directors were appointed on the recommendation of important shareholders

Board composition as of 31 December 2024:

Gender diversity:

• On 31 December 2024, three women and five men sat on the Board (32.5% women and 67.5% men)
• The Executive Management consisted of two women and eight men (20% women and 80% men)

Age diversity:

• Board members: age ranges between 32 and 73 years of age
• Executive Management members: youngest member is 39 years old, oldest member is 68 years of age

Educational/professional background: The members of the Board and the Executive Management have various backgrounds, including economics, law, engineering, geology, marketing, finance, IT, HR, and business administration.

Geographical provenance:

• One Board member has Dutch nationality; other members are Belgian citizens
• One Board member lives in France
• Executive Management consists of seven Belgian citizens, two Turkish citizens and one US permanent resident

(International) experience: Most of the Board and Executive Management members have studied and/or worked abroad.

Specific committees with sustainability oversight

Audit Committee

The Audit Committee consists of three members, all Non-Executive Directors. Two members are considered independent:

• Wim Hendrix, representing Homeport Investment Management BV (Chairman)
• Marcel Klepfisch, representing Marcel Klepfisch SAS
• Francis Van Eeckhout, representing Beneconsult BV

The Audit Committee members as a whole have competence relevant to the sector in which Deceuninck is operating and at least one member has competence in accounting and auditing.

The CEO and the CFO are invited to the meetings of the Audit Committee.

Remuneration and Nomination Committee

The Remuneration and Nomination Committee consists of five members, all Non-Executive Directors. Three members are considered independent:

• Francis Van Eeckhout, representing Beneconsult BV (Chairman)
• Marcel Klepfisch, representing Marcel Klepfisch SAS
• Benedikte Boone, representing Venture Consult BV
• Anouk Lagae, representing Alchemy Partners BV
• Paul Van Oyen, representing PVO Advisory BV

Taking into account their education and professional experience, the members have the necessary expertise in the field of remuneration policy.

The CEO is invited to the meetings of the Remuneration and Nomination Committee.

Sustainability-related expertise and training

One Board member has followed external training to develop specific sustainability-related expertise. All Board members have access to sustainability expertise through their professional mandates.

Further on, the Board and the Executive Management were informed about sustainability legislation through information provided by the Group Sustainability Manager and the General Counsel.

Additionally, training programs will be implemented to ensure members stay updated on emerging trends, regulatory requirements and best practices in sustainability oversight.

Frequency of sustainability discussions at board level

Board of Directors: The Board convened eight times in 2024, addressing sustainability matters including:

• Approval of sustainability report
• Monitoring innovation projects and the technology strategy
• Long-term strategy (which includes sustainability as a core pillar under the purpose "Building a Sustainable Home")

During 2024, while preparing the first Annual Report under the CSRD regulation, the Board was engaged in the discussion of the preliminary results and confirmation of the final results of the Double Materiality Analysis (DMA), covering the due diligence process. The Board was informed by members of the Executive Management and the Group Sustainability Manager about material impacts, risks and opportunities included in the DMA.

As of 2025, progress on key targets will be reported to the Board minimum on a quarterly basis.

Executive Management: The Executive Management was involved in the discussion on material impacts, risks, and opportunities during the DMA and due diligence process. The performance on the targets set, together with a qualitative assessment of policies and actions in place on a regular basis. The CFO is responsible for providing this information. As of 2025, progress on key targets will be reported on a monthly basis.

Meeting attendance in 2024:

Material sustainability impacts, risks and opportunities addressed by the Board and Executive Management during 2024:

Environment:

• E1 Climate Change: climate change mitigation
• E2 Pollution: Use of substances of very high concern
• E5 Circular Economy: raw materials and recycling

Social:

• S1: Equal treatment and opportunities for all
• S1: Working conditions
• S4: Information-related impacts (data protection/privacy)

Governance:

• G1: Corporate culture
• G1: Protection of whistleblowers
• G1: Anti-corruption and Bribery

Specific roles assigned

Board of Directors: The Board of Directors is responsible for oversight of sustainability-related impacts, risks and opportunities.

Executive Management: Within the Executive Management, the Group CFO is responsible for management of sustainability-related impacts, risks and opportunities.

The Board of Directors' responsibilities for impacts, risks and opportunities are embedded in the Group's governance framework. The Corporate Governance Charter outlines the terms of reference of the Board and Executive Management. No specific dedicated controls and procedures are applied to the management of sustainability impacts, risks and opportunities other than the controls and procedures for other impacts, risks and opportunities.

The Executive Management determines the company and sustainability strategy, approves the targets and monitors the execution of the strategy.

Group Sustainability Manager: The Group Sustainability Manager reports to the CFO and coordinates the integration of sustainability into the company, identifying bottlenecks, drawing up action plans and providing input for the sustainability strategy.

Regional EHS Managers: Dedicated roles are attributed to the regional Environmental, Health, and Safety (EHS) managers who coordinate the execution of action plans locally.

Employees in different departments: Dedicated roles are given to employees in different departments to ensure the execution of the strategy: technical, procurement, R&D, product management, finance.

To ensure execution of the strategy and reporting in the plants, dedicated roles are given to employees in different departments: HR, EHS, technical, procurement, R&D, product management.

Independence and effectiveness arrangements

Board evaluation:

The Board is responsible for a regular evaluation of its own performance with a view to constantly improving the management of the Group. To this end, the Board, led by its Chairman, carries out an evaluation of its scope, composition, activities and interaction with the Executive Management, preferably every three years. The Board also assesses the functioning of the Committees and the individual Directors.

The evaluation process has four objectives:

• to assess the functioning and activities of the Board and of the relevant Committees;
• to check whether important issues are thoroughly prepared and discussed;
• to evaluate the actual contribution of the Board; and
• to assess the current composition of the Board or the Committees in light of the desired composition of the Board or the Committees.

The most recent performance evaluation was done in December 2024. The evaluations were conducted through a questionnaire and were facilitated by the Company Secretary. The results of the 2024 performance evaluation will be reported to the Board meeting in 2025.

Anonymous individual directors' performance evaluations: Anonymous individual directors' performance evaluations are regularly conducted, the results of which are included in Board's assessment of the Committees' functioning.

Exit interviews: Qualitative exit interviews are conducted with Directors leaving the Board.

Detailed provisions: Annex A to the Charter sets forth detailed provisions for the periodic assessment of the Board's functioning.

Recommendation process: On the basis of the results of the evaluation, the Chairman provides the Board with a recommendations report and, if necessary, proposes the appointment of a new Director or the non-renewal of a Director's mandate to the Remuneration and Nomination Committee.

Independence of Board members: 62.5% of Board members are Independent Directors in accordance with the Code.

Subscription rights: In deviation from the Code, the non-executive Board members may receive subscription rights upon approval by the General Meeting. The Company believes that the granting of subscription rights meets the objective of aligning the financial interests of non-executive directors with those of shareholders in a long-term perspective. The exercise of these subscription rights is subject to important limitations and time restrictions. The subscription rights plans are not deemed to affect in any aspect the independence of Board members.

Internal Audit: Internal Audit maintains the Risk Register and Risk Matrix for all risks which are relevant at Group and regional level. Actions are assigned to cross regional teams and overseen by an Executive Team member. These are reviewed twice a year by the Executive Management, and once a year with the Audit Committee of the Board.

Conflicts of interest: Each Director and each member of the Executive Management are encouraged to arrange their personal and business interests so that there is no direct or indirect conflict of interest with the Company. Deceuninck has no knowledge of any potential conflict of interest affecting the members of the Board and the Executive Management between any of their duties to the Company and their private and/or other duties.

Succession planning:

The Remuneration and Nomination Committee is responsible for balancing the required diversity requirements and competencies within the Board over the long term in accordance with the Company's strategy. This less rigid succession planning approach allows the Company to promptly adapt to changing circumstances and varying occupancy demands from time to time.

The Board believes in a dynamic, overall planning approach that is mainly centered around:

• continued expansion of management team capabilities;
• strengthening the necessary connections to align growth plans with executive team roles;
• a well-researched executive skills matrix and a live map of talent; and
• clear and orderly procedures for selecting and approving a successor.

Integration of sustainability-related performance in incentive schemes:

For members of the Executive Management, 10% of the variable, performance-based remuneration is tied to achieving the Group's targets on climate change, safety and recycling, equally divided between each of the targets. The targets are aligned with the targets agreed upon in the Sustainability Linked Loan (SLL) of the Group.

The terms of the incentive schemes are approved by the Remuneration and Nomination Committee.

Integration of sustainability-related performance in incentive schemes

Roles covered

For members of the Executive Management, variable, performance-based remuneration includes sustainability targets.

Members of the Management Team Group also have sustainability targets in their collective bonus.

Sustainability KPIs tied to remuneration

The variable remuneration is tied to achieving the Group's targets on:

• Climate change (carbon emissions)
• Safety
• Recycling

The targets are aligned with the targets agreed upon in the Sustainability Linked Loan (SLL) of the Group.

Weighting

Executive Management:

• 10% of the variable, performance-based remuneration is tied to achieving sustainability targets
• This 10% is equally divided between each of the three targets (climate change, safety, recycling)
• Specifically, 3.3% of their variable remuneration is tied to achieving the Group's Scope 1 and Scope 2 target

Management Team Group:

• 2.3% of the collective bonus depends on the achievement of the same carbon emission target

Link to STI or LTI

The disclosure refers to "variable, performance-based remuneration" without explicitly specifying whether this is short-term or long-term incentive.

Performance targets

Carbon emissions target (Scope 1 and 2):

• The target is aligned with the target agreed upon in the Sustainability Linked Loan (SLL)
• Annual reduction of on average (between 2022 and 2026) 6.5% of market-based carbon emissions
• The target for 2024 was to reach a maximum of 64,952 tCO2e emissions

For specific safety and recycling targets, the company refers to the specific chapters (E1, S1, E5).

Governance

The terms of the incentive schemes are approved by the Remuneration and Nomination Committee.

Strategy, business model and value chain

Description of products/services and key markets

Deceuninck serves over 4,000 customers in more than 90 countries across the world.

The largest number of customers are window manufacturers (business-to-business model), who assemble Deceuninck's profiles into a window in accordance with the installation instructions of Deceuninck. The large window manufacturers are equipped with highly automated machines for the manufacture of windows.

Other building products are mainly delivered to professional building material dealers, who sell Deceuninck products to the professional construction and renovation market. The assembly of the product is usually done by independent specialized installers.

Multi-material Window, Door and Building Solutions

Deceuninck primarily manufactures window profiles destined for the residential construction sector, including renovation, and related products.

Significant groups of products/services

The Group's activities fall under Division 22: 22.21 Manufacture of plastic plates, sheets, tubes and profiles of Annex I to Regulation (EC) No 1893/2006. The Group is not active in chemical production.

The primary material processed by the Group to create window solutions is PVC (Polyvinyl Chloride). PVC consists of 57% salt (chloride) and 43% ethylene (primarily derived from petroleum or natural gas). PVC products offer an excellent balance of cost and performance, providing superior thermal insulation (energy efficiency), low maintenance (no painting required) and long-lasting functionality (resistant to rot and rust). Additionally, PVC is a recyclable material, as demonstrated by the Group's recycling activities.

Significant markets / geographies

Deceuninck operates in the Americas, Europe and Türkiye with production plants and sales organizations.

Operational and Commercial Footprint (entities by region):

• Europe: Croatia, Czech Republic, France, Germany, Italy, Netherlands, Poland, Romania, Russia, Slovakia, Spain, United Kingdom
• Latin America: Colombia (Deceuninck de Mexico SA de CV listed as LATAM/Mexico)
• Türkiye and APAC: Türkiye (Ege Profil AS)
• North America: United States

The expectations towards incorporating sustainability in the company strategy are the highest in the European market, driven by stringent EU regulations (example: CSRD and the new Construction Product Regulation) and growing client expectations for environmentally responsible practices. Meanwhile, Türkiye is in the process of aligning with this trend, exemplified by the introduction of the Turkish Sustainability Reporting Standards (TSRS). Regulatory and client expectations in the U.S. market is evolving at a slower phase, and regulatory requirements vary significantly by state.

Number of employees by geography

Total headcount (FTE): 3,686 (2024)

For detailed breakdown by geographical areas, see S1-6 Characteristics of the employees.

Total revenue by significant ESRS sustainability matter

No breakdown of total revenue by significant ESRS sectors available: the activities of the Group fall under Division 22: 22.21 Manufacture of plastic plates, sheets, tubes and profiles of Annex I to Regulation (EC) No 1893/2006. The Group is not active in chemical production.

Breakdown of revenue by product group: see 2.6.2. Financial Statements and Notes, Segment Information.

Sustainability-related goals embedded in the business model

Purpose: Building a Sustainable Home

The Group's sustainability strategy positions sustainability as a core pillar through two core commitments:

1. We create innovative products that contribute to sustainable living:

• We design windows, doors and building profiles with the best insulation values
• …that last for a very long time
• …that are made from recycled base materials and are recyclable

2. We produce sustainably:

• We set the standard for our industry, following Science Based Targets
• We invest in recycling technology and facilitate waste stream collection
• We mitigate our environmental impact as much as possible

As an employer, we create a good 'home' to the people that work for us. We offer good working conditions in an inclusive and trusting environment for people to thrive. We actively promote safe working conditions. We protect their fundamental rights and encourage learning and development.

We uphold high ethical standards and ensure ethical business practices throughout the organisation.

Strategic commitments:

Validated SBTi targets:

Since September 2023, the Group has validated SBTi near-term targets for reduction of scope 1, 2 and 3 emissions by 2030 and long-term net-zero targets for 2050 (from a 2021 base year).

The target is to reduce Scope 1 and Scope 2 carbon emissions by 60% and Scope 3 carbon emissions by 52% per tonnes PVC by 2030, ultimately striving for net-zero emissions across all scopes by 2050.

Description of the upstream and downstream value chain

The Value Chain Model:

The value chain model illustrates how the Group generates value for both internal and external stakeholders. The business model, driven by the purpose of 'Building a Sustainability Home,' outlines the key inputs, outputs and outcomes that contribute to value creation.

Upstream Value Chain:

Raw material production:

• Ethylene, Chloride, Energy
• PVC is manufactured by polymerisation of vinyl chloride monomer (VCM), produced by the thermal cracking of ethylene dichloride (EDC)
• Most ethylene is produced by steam cracking of naphtha
• Chlorine is produced by electrolysis of sodium chloride (NaCl)
• The environmental impact of PVC production upstream mainly relates to the refinery of crude oil for the ethylene production as well as the energy needed for the production of EDC and the polymerisation of VCM into PVC
• Approximately 80% of the carbon footprint of Deceuninck is linked to GHG emissions from raw material production

Supplier management:

• The Group works to source materials with a lower carbon footprint
• Supplier Code of Conduct guides approach to supply chain due diligence
• Key raw materials suppliers are requested to provide information on their decarbonization strategy and roadmap
• Suppliers are requested to provide product related carbon data through Environmental Product Declarations
• It is mandatory for raw material suppliers to implement recognized quality and environmental management systems (ISO 9001, ISO 14001)
• Participation in voluntary industry initiatives (VinylPlus Product Label, ECVM Industry Charter) is encouraged

Transportation:

• Raw materials, semi-finished and finished products are transported in every step of the value chain
• Upstream transportation accounts for part of Scope 3 emissions

Deceuninck's Position in the Value Chain:

Compounding, Extrusion, Processing:

• The Group's compound factories deliver compound to most of the Group's extrusion factories
• Located in Belgium, Colombia, Poland, Russia, Türkiye and the United States
• Production: We create a safe and inclusive workplace
• We work to reduce the environmental impact of our manufacturing sites and operations through investments in renewable energy and energy efficiency
• Approximately 10% of the carbon footprint of Deceuninck is attributed to GHG emissions from energy consumption

Product design:

• We design high quality, long-lasting products
• We reduce the products' embodied carbon footprint by increasing the proportion of recycled materials used
• Research & Product Development focus on window and door solutions, building products, multi-material: PVC, aluminum, wood composites

Downstream Value Chain:

Fabrication:

• Our customers assemble our products into a window
• We organise awareness activities to inform them about the importance and possibilities of climate action and circular economy

Installation:

• Our installation instructions ensure installation is done in a qualitative way

Use-phase:

• Our products are defined by superior thermal and acoustic performance
• They require little maintenance and have a long service life
• PVC windows and doors offer excellent thermal insulation, reducing energy consumption for both heating and cooling, which in turn lowers greenhouse gas emissions of buildings
• Our products do not need energy while being used

Recycling:

• We collect end-of-life PVC material and via mechanical recycling methods, we transform them into raw material to produce new products
• We increase efforts into recycling and use of recycled material
• The Group pursues a strategy of in-house recycling of postconsumer PVC material
• The recycling plant in Diksmuide (Belgium) has a capacity of 40,000 tonnes annually
• PVC is recycled in a closed loop system, meaning the material can be used to create a new version of the same or similar product
• PVC can be recycled at least eight times without losing its mechanical characteristics
• Installed for at least 35 years, it has a potential lifecycle of 280 years or more

Key inputs and outputs

Resources (input):

• Human: Our people: 3,686 FTE; Our customers: +4,000; Our suppliers
• Materials: Raw materials: 22,200 tonnes of PVC recycled; Recycled materials: 16.5% recycled material used
• Know-How: 0.8% sales spent on R&D
• Financial: € 15.9 m net profit
• Legal and Compliance

Products and Services (output):

• Research & Product Development
• Window and door solutions
• Building products
• Multi-material: PVC, aluminum, wood composites
• Manufacturing
• Logistics & Supply
• Technical Support
• Marketing
• Investor Relations

Value Creation (outcome):

For Our People:

• Job creation
• Talent acquisition and retention
• Learning and development
• Safe working environment

For Our Planet:

• Use of recycled material in our products and products with optimal thermal insulation
• Recycling of post-consumer waste
• Energy and water management in production
• Use of renewable electricity

For Prosperity:

• Financial sustainability
• Top 3 global player
• Shareholder return

For Our Community:

• Health & Safety of our products in use-phase
• Business ethics and compliance
• Community engagement

Interaction with strategy and business model

Sustainability is woven into the strategic business planning and key decisions, with material impacts, risks and opportunities forming a core part of the Group's strategy to set an industry-leading example. These elements are central to Group's purpose "Building a Sustainable Home," reflecting the commitment to developing innovative products that promote sustainable living and are produced in a responsible manner.

The Group's decarbonization strategy is embedded in the business strategy, ensuring long-term value creation. The decarbonization strategy reinforces the company's commitment to environmental stewardship while driving cost efficiency and market leadership.

Renovation and new housing remain essential to tackle demographic issues globally. The Group is well positioned to respond to this opportunity because the products directly contribute to energy savings. Providing homes with windows and doors with optimal insulation values made from recycled material and recyclable themselves; this is our business value and the reason why our business and sustainability strategy are resilient on the long term.

Interests and views of stakeholders

Stakeholder engagement

Achieving our purpose of Building a Sustainable Home cannot be done without considering the interests and expectations of our stakeholders. We listen to their expectations and build on their feedback to progress. We are committed to working together to address our collective impact on people and the environment.

Overview of key stakeholder groups and engagement

Stakeholder coverage in materiality assessment

All stakeholder groups above were involved in the materiality assessment process, with the exception of governments. To include their expectations in our assessment, the Group relied on the content of current and foreseen policy initiatives. In the Supplier stakeholder group, we focused on the suppliers of our most important raw material (PVC resin). Stakeholders from all regions in which the Group is active, were involved in the process.

All stakeholders mentioned are affected stakeholders.

Integration of stakeholder views into strategy and business model

All stakeholder expectations mentioned above were considered in the materiality assessment process. These are processed in the descriptions of Impacts, Risks and Opportunities (see IRO-1).

No amendments to the strategy and/or business model to address the interests and views of its stakeholders were made based on the DMA. The assessment confirms that the Group has been focusing on the right topics, i.e. topics where the impact on society or the impact on the Group is high.

The Board and the Executive Management were informed about the views and interests of the stakeholders with regard to the sustainability impacts during the discussions of materiality levels in the context of the materiality analysis conducted.

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

The Double Materiality Analysis

In accordance with the ESRS a Double Materiality Assessment (DMA) has been conducted. Topics have been ranked following the two distinctive dimensions of impact materiality and financial materiality. See IRO-1 for information about the process followed.

Overview of all topics assessed during the DMA and their scoring

All topics assessed during the Double Materiality Analysis were scored on impact materiality (vertical axis, scale 5-8) and financial materiality (horizontal axis, scale 5-8). Topics included:

List of topics assessed:

• S1.1: Secure employment
• S4.2: Data protection/privacy of client information
• E1.2: Carbon emissions upstream
• S1.2: Adequate wages
• E2.3: Use of substances of (very) high concern
• E5.2: Raw materials
• S4.1: Health & safety impact of products
• S1.6: Training and skills development
• S1.7: Health and safety
• E5.1: Waste generation
• E3.1: Water consumption
• E1.1: Carbon emissions own operations
• E1.3: Carbon emissions downstream
• E5.3: Packaging material
• E2.2: Emissions to water and soil from pellet losses
• E2.1: Emissions of air pollutants
• G2.3: Payment practices to suppliers
• G2.4: Business Conduct
• G2.1: Anti-corruption and bribery
• S1.3: Social dialogue
• S1.5: Work-life balance
• S1.4: Diversity & inclusion
• E3.2: Water recycling and water treatment
• S1.8: Human rights
• S2.1: Working conditions
• S3.1: Effects for the immediate community
• E4.2: Pressure on the state of species
• S4.3: Social inclusion of clients
• E4.3: Pressure on the ecosystems
• E4.1: Land use and deforestation
• G2.2: Political influence & lobbying
• S2.2: Equal treatment and opportunities
• E1.4: Climate change vulnerability (physical risks)

Validated material topics

Based on the scoring and analysis conducted, materiality was defined on the 2 dimensions: impact materiality and financial materiality. This led to a more condensed list of sustainability topics.

All the topics listed below are considered material. However, the Group has identified certain topics as highly material (marked in green in the original). These are the critical components of the business model and strategy. Medium material topics are marked in yellow.

Material topics by category:

Summary of the most material impacts, risks and opportunities

For the material topics, detailed summaries are provided in the topic-specific disclosures. A summary of the most important IRO's to the Group, forming a pivotal aspect of the business model and strategy, includes:

Environmental

Resource inflows and circular economy

The extraction and processing of PVC feedstock has an environmental impact on the availability of natural resources. However, PVC is a recyclable material and recycling is incorporated in the Group's business model and strategy underscoring the significance of responsible supply chain management, both upstream as downstream. Circular economy requirements are increasingly promoted by public policy and the consumer interest is increasing. Closed-loop recycling minimizes a product's end-of-life impacts and reduces the need for extracting or producing virgin materials. Therefore, end-of-life product recovery and the use of recycled material in products reduces future regulatory risk and helps to meet a growing customer demand.

Climate Change

The feedstock and the energy required to process the raw materials the Group uses (PVC resin and additives) is largely fossil-based. The energy consumed by the Group is still partly fossil-based. Energy costs represent a significant share of production costs. The financial effects of the related GHG emissions may result in regulatory compliance costs, as companies are subject to increasingly stringent regulations such as carbon taxes. Through the ambitious decarbonization targets set (in line with SBTi) we aim to reduce GHG emissions, through energy efficiency, the use of renewable energy sources and cooperations in the supply chain.

Social

Own workforce

Building a broad base of valued employees is crucial for the long-term growth prospects of our company. Our employees, as our primary asset, drive revenue through their knowledge, talent and technical expertise. Ensuring fair treatment and equitable pay for all employees enhances productivity and performance across the organization. This focus is relevant not only because of labour shortages, but also because a high quality and diverse workforce fosters innovation and company resilience. The Group emphasizes talent management by organizing training programs.

Our operations hold inherent safety risks. Safety is a number one priority. We ascertain that tangible actions are taken to reduce risks to the maximum. We work hard to strengthen a safety culture, to make sure that our employees return home safe at the end of each workday.

Linkage between IROs and strategy/business model

Sustainability is woven into the strategic business planning and key decisions, with material impacts, risks and opportunities forming a core part of the Group's strategy to set an industry-leading example. These elements are central to Group's purpose "Building a Sustainable Home," reflecting the commitment to developing innovative products that promote sustainable living and are produced in a responsible manner.

The Group's sustainability strategy takes global trends into consideration. The Purpose "Building a Sustainable Home" positions sustainability as a core pillar. Environmental responsibility lies at the heart of the purpose and is composed of two core commitments:

• We create innovative products that contribute to sustainable living: We design high-end products with the best insulation values, that last for a very long time and that are made from recycled materials and are recyclable at their end-of-life.
• We produce sustainably: We strive to reduce the environmental footprint of our operations. We combat global warming in a supply chain approach. We are committed to long-term employment and provide our employees with a good and safe working environment.

As an employer, we create a good 'home' to the people that work for us. We offer good working conditions in an inclusive and trusting environment for people to thrive. We actively promote safe working conditions. We protect their fundamental rights and encourage learning and development.

We uphold high ethical standards and ensure ethical business practices throughout the organisation.

Strategic commitments:

How material IROs interact with the business

No amendments to the strategy and/or business model to address the interests and views of its stakeholders were made based on the DMA. The assessment confirms that the Group has been focusing on the right topics, i.e. topics where the impact on society or the impact on the Group is high.

These material impacts, risks and opportunities related to the topics below were addressed by the Board and the Executive Management during 2024:

Environment:

• E1 Climate Change: climate change mitigation
• E2 Pollution: Use of substances of very high concern
• E5 Circular Economy: raw materials and recycling

Social:

• S1: Equal treatment and opportunities for all
• S1: Working conditions
• S4: Information-related impacts (data protection/privacy)

Governance:

• G1: Corporate culture
• G1: Protection of whistleblowers
• G1: Anti-corruption and Bribery

Resilience to identified IROs

Climate-related resilience:

The resilience analysis evaluates the Group's capacity to withstand and adapt to climate-related risks and opportunities, focusing on GHG emissions across own operations, upstream and downstream activities. The analysis was conducted in a qualitative way for the Group's activities, focusing on climate transition risks with a short- and medium-term time horizon (until 2030). The analysis did not use a climate scenario analysis. Financial effects have not been quantified yet.

Results of the resilience analysis:

The Group has developed its business model around recycling PVC waste and reintroducing it in new PVC products. This not only reduces waste and supply chain related carbon emissions, it also reduces raw material dependency, which strengthens supply chain resilience. The Group's revenue growth will be increasingly driven by a higher share of sales which incorporate recycled materials and as such, have a lower carbon impact. This comes with investments in recycling capacity as well as co-extrusion technology to use recycled materials in new products.

The ambitious decarbonization targets as part of the SBTi goals set by 2030, guide the Group's transition to a lower operational carbon footprint. The shift to renewable electricity and energy efficiency measures are on the long term a protection to energy cost volatility. Energy efficiency often comes hand in hand with operational efficiency.

Lowering the product carbon footprint appeals to a growing share of environmentally conscious customers. By enhancing sustainability and competitive advantage, the Group will capitalize on the opportunities of the transition to a low-carbon economy.

Renovation and new housing remain essential to tackle demographic issues globally. The Group is well positioned to respond to this opportunity because the products directly contribute to energy savings. Providing homes with windows and doors with optimal insulation values made from recycled material and recyclable themselves; this is our business value and the reason why our business and sustainability strategy are resilient on the long term.

The decarbonization strategy comes with short-term investments. Access to finance is safeguarding through a SLL, agreed upon 2022 and in place until 2027. There are no indications refinancing would not be possible.

Existing productive assets are evaluated on a continuous basis to meet current and future (building and technological) standards.

Necessary reskilling of employees is part of the HR training plan. The current evaluation is that the skills needed to enable to meet the decarbonization targets are not that fundamentally different than the ones needed to be able to be an innovative employer.

Biodiversity considerations:

The outcome of the DMA does not consider biodiversity (ESRS E4) as a material topic for the following reasoning linked to both impact as financial materiality:

• The Groups' operations are confined to industrial zones with little interaction with natural habitats.
• The environmental regulations for PVC manufacturing focus on other aspects rather than direct biodiversity impact.
• The direct supply chain for raw materials is not closely linked to biodiversity-sensitive areas.
• As a result of the interactions during the DMA process, stakeholder priorities on the short and medium-term are linked to other environmental aspects.
• The Group prioritizes sustainability efforts on areas with more direct and significant impact.

Nevertheless, topics such as reducing greenhouse gas emissions and managing pollution are indirectly also linked to biodiversity concerns.

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

General process conducted

IRO identification

To define the basis to assess material topics, the Group started from a longlist of 33 subtopics of the ESRS. This list was supplemented with industry-specific risk documentation, including the Sustainability Accounting Standards Board (SASB) standards. Additionally, insights were drawn from sustainability reporting guidelines, roadmaps and verification schemes developed by sector federations. The outcome of the latest Enterprise Risk Assessment served as input as well. These were crosschecked with global trends and company-specific information. The list was reviewed internally by a selected group of colleagues of different departments.

There are no specific activities, business relationships, geographies or other factors that give rise to heightened risk of adverse impacts.

IRO evaluation

To determine priorities, internal and external stakeholders prioritized topics through an online questionnaire. This was completed by in-depth interviews with a selection of key suppliers and clients.

In the survey the stakeholders were not only given a topic but also a short description of the impact and financial materiality related to the topic, in order to give some context and allow to provide more granular feedback on the described materiality. This served as valuable input to analyze and finalize the IRO's.

Stakeholder groups consulted were employees (across all functions), clients, suppliers, investors and the Group's European industry association. Not all internal stakeholders scored every topic, as we targeted specific questions to selected stakeholders to leverage their specialized expertise on the matters. The external stakeholders have scored a more condensed list of topics as interrelated impacts were combined in order to make the list more digestible. A total of 84 unique stakeholders were involved in the assessment of both impact and financial materiality.

Based on this scoring, topics were categorized into high, medium and low materiality levels.

To define the final material topics and related impacts, risk and opportunities, the scoring by the stakeholders was consolidated. A discussion with the Executive Management members served to determine materiality in greater depth.

The result was a matrix identifying material topics on the 2 dimensions of the DMA: impact materiality and financial materiality. The materiality matrix defines the scope of disclosure in the sustainability statement of this report, as such that all material topics are included in the reporting.

The matrix was presented to the Board and the last adjustments were made to determine the material topics and IRO's for the Group.

Sources used as input parameters

↳ ESRS topics and subtopics ↳ SASB Standard for Chemical + Building products + Waste Management sector ↳ GRI: ESG standards ↳ Sector reference documents: Essenscia Sustainable Development report, PlasticsEurope 2050 Roadmap, Vinylplus Product Label ↳ Materiality assessment of the Group conducted in the past ↳ Enterprise Risk Assessment of the Group to include other types of risks

Scoring system

Impact materiality

Impact materiality was scored on the elements of likelihood and severity of occurrence. Likelihood assesses the probability of the predefined topic materializing into a significant impact. Severity integrates the aspects of scale, scope and (for negative impacts) irremediable character of the impact.

Scale refers to the potential magnitude of the potential impact. Scope addresses the breadth and extent of the impact. Remediability concerns whether and to what extent the negative impacts could be remediated.

Financial materiality

The financial materiality of predefined risks and opportunities is assessed based on a combination of the likelihood of occurrence and the potential magnitude of the financial effects.

Severity and likelihood criteria of impact and financial materiality were independently evaluated for each topic included in the DMA, each having a maximum score of 5 leading to a maximum score of 10 for impact and financial materiality.

In the calculation of the average results per topic, all stakeholders were given equal weight.

Thresholds for materiality

The same thresholds were applied for impact and financial materiality:

In conclusion, all topics with a score of 6.9 or above are defined as material topics.

Other elements of the DMA process

The DMA covers all activities and geographies of the Group.

The assessment incorporates a value chain perspective, through the involvement of suppliers and clients, through the desk research performed and through the scoring method as stakeholders were requested to not only consider what is relevant to the Group's own operations, but also the entire value chain (upstream and downstream).

The process to identify, assess and manage IRO's has been separately conducted from the overall risk management process, to allow for an in-depth analysis on sustainability. In an update of the Enterprise Risk Assessment, the outcome of this DMA will be integrated in the overall risk profile and risk management processes.

Frequency / when last reviewed

The materiality assessment will be screened for relevance annually and updated if needed.

Use of value chain mapping

The assessment incorporates a value chain perspective, through the involvement of suppliers and clients, through the desk research performed and through the scoring method as stakeholders were requested to not only consider what is relevant to the Group's own operations, but also the entire value chain (upstream and downstream).

Transparency on environmental topics not defined as material topics

The outcome of the DMA does not consider biodiversity (ESRS E4) as a material topic for the following reasoning linked to both impact as financial materiality.

The Groups' operations are confined to industrial zones with little interaction with natural habitats. The environmental regulations for PVC manufacturing focus on other aspects rather than direct biodiversity impact. The direct supply chain for raw materials is not closely linked to biodiversity-sensitive areas. As a result of the interactions during the DMA process, stakeholder priorities on the short and medium-term are linked to other environmental aspects. The Group prioritizes sustainability efforts on areas with more direct and significant impact. Nevertheless, topics such as reducing greenhouse gas emissions and managing pollution are indirectly also linked to biodiversity concerns.

Transition plan for climate change mitigation

Ambitious GHG emission reduction targets

Since September 2023, the Group has validated SBTi near-term targets for reduction of scope 1, 2 and 3 emissions by 2030 and long-term net-zero targets for 2050 (from a 2021 base year).

The target is to reduce Scope 1 and Scope 2 carbon emissions by 60% and Scope 3 carbon emissions by 52% per tonnes PVC by 2030, ultimately striving for net-zero emissions across all scopes by 2050. This is compatible with the Paris Agreement's goal of limiting global warming to 1.5°C above pre-industrial temperatures level.

Key decarbonization levers

1. Increasing consumption of renewable electricity in production (Scope 2)
2. Energy and operational efficiencies in production (Scope 1, 2)
3. Sourcing less carbon intensive raw materials (Scope 3)
4. Increased use of recycled materials (Scope 3)

The action plan to decarbonize the direct GHG emissions mainly builds upon the broader deployment of established technologies rather than new technologies.

The raw material suppliers of the Group face additional challenges related to new technologies, for example through the adoption of green hydrogen, advanced electrification processes and carbon capture and storage (CCS).

Investments supporting the transition plan

The investments for the implementation transition plan have not been quantified. They are demonstrated through the annual EU Taxonomy disclosures.

The economic activity 5.9: Material recovery from non-hazardous waste is aligned with the provisions of the Climate Change Mitigation objective of the EU Taxonomy.

For these other economic activities eligibility is reported under the Climate Change Mitigation objective of the EU Taxonomy. The activities are:

• Category 3.5: Manufacture of energy efficiency equipment for buildings
• Category 7.3: Installation, maintenance and repair of energy efficiency equipment
• Category 7.4: Installation, maintenance and repair of charging stations for electric vehicles in buildings
• Category 7.5: Installation, maintenance and repair of instruments and devices for measuring, regulation and controlling energy performance of buildings
• Category 7.6: Installation, maintenance and repair of renewable energy technologies

In addition, eligibility is reported for the activity 5.9: Material recovery from non-hazardous waste under the Climate Change objective of the EU Taxonomy.

The Group will further work toward aligning its economic activities under Category 3.5 and the abovementioned Category 7 with the EU Taxonomy DNSH-criteria on climate adaptation in the coming years, although no concrete action plan has been established yet. As long as the DNSH criterium stays as it is and does not reflect the provisions outlined in the Derogation under the REACH regulation related to the presence of lead (Pb), alignment with the Taxonomy objective of activity 3.5 is impossible.

The turnover of activity Category 5.9 is expected to increase as a result of increased recycling activities.

Alignment of sustainability and business strategy

The Group evaluates its strategy and business model compatible with limiting of global warming to 1.5°C in line with the Paris Agreement. The action plan linked to the SBTi should enable the decrease of GHG emissions in line with maximum 1.5°C global warming.

The Group's decarbonization strategy is embedded in the business strategy, ensuring long-term value creation. Overall, the decarbonization strategy reinforces the company's commitment to environmental stewardship while driving cost efficiency and market leadership.

How each key decarbonization lever aligns with the company's broader goals:

1. Increasing renewable electricity consumption (Scope 2)

By transitioning to renewable energy sources, we reduce the carbon footprint and mitigate exposure to volatile fossil fuel prices.

2. Energy and operational efficiencies (Scope 1 and 2)

Improving energy efficiency and optimizing operational processes reduce production costs and as such, enhance competitiveness.

3. Sourcing less carbon-Intensive raw materials (Scope 3)

By prioritizing suppliers who offer low-carbon materials, we strengthen supply chain resilience and align with customer preferences for sustainable PVC solutions.

4. Increased use of recycled materials (Scope 3)

Using recycled materials not only reduces waste and raw material dependency but also positions us as a leader in the circular economy.

The transition plan has been approved by the Executive Management and Board of Directors of the Group as part of the SBTi commitment and approval process.

Locked-in GHG emissions

Locked-in GHG emissions from the Group's assets are considered in the Group's decarbonization plan under the 'business as usual' scenario, where company growth would lead to increased carbon emissions. The emissions refer to those that are expected to occur through existing infrastructure. Locked-in GHG emissions of assets are included in the decarbonization targets of the Group. As the products manufactured by the Group do not emit carbon emissions during their lifetime and as such are not included in the carbon footprint or decarbonization strategy, no locked-in GHG emissions associated with the product use-phase are considered.

Cumulative locked-in GHG emissions associated with key assets and activities from 2021 until 2030 (cfr. 'Business as Usual scenario'):

• Scope 1, 2 GHG emissions: 119,954 tCO2e
• Scope 3 GHG emissions: 1,124,778 tCO2e

The Group is not excluded from the EU Paris-aligned Benchmarks.

Progress reporting on the transition plan

The Group is well advanced on reaching the 2030 targets on direct (Scope 1, 2) emissions, mainly due to Group-wide investments in renewable energy and the use of Guarantees of Origin in Europe. The progress on the target related to indirect emissions (Scope 3) is slower, as expected. Yearly reductions were never expected as the achievement of the target is dependent on large investments in the supply chain which might only take effect on the long-term.

Quantitative status reporting on the transition plan and reaching the SBTi targets set, see E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions

Resilience strategy to climate related risks

All climate-related risks identified, are considered climate-related transition risks. We refer to IRO-1 Physical risks for more details on the analysis conducted.

The scope of the resilience analysis

The analysis evaluates the Group's capacity to withstand and adapt to climate-related risks and opportunities, focusing on GHG emissions across own operations, upstream and downstream activities.

The resilience analysis was conducted in a qualitative way for the Group's activities, focusing on climate transition risks with a short- and medium-term time horizon (until 2030). The analysis did not use a climate scenario analysis. Financial effects have not been quantified yet.

The results of the resilience analysis

The Group has developed its business model around recycling PVC waste and reintroducing it in new PVC products. This not only reduces waste and supply chain related carbon emissions, it also reduces raw material dependency, which strengthens supply chain resilience. The Group's revenue growth will be increasingly driven by a higher share of sales which incorporate recycled materials and as such, have a lower carbon impact. This comes with investments in recycling capacity as well as co-extrusion technology to use recycled materials in new products.

The ambitious decarbonization targets as part of the SBTi goals set by 2030, guide the Group's transition to a lower operational carbon footprint. The shift to renewable electricity and energy efficiency measures are on the long term a protection to energy cost volatility. Energy efficiency often comes hand in hand with operational efficiency.

Lowering the product carbon footprint appeals to a growing share of environmentally conscious customers. By enhancing sustainability and competitive advantage, the Group will capitalize on the opportunities of the transition to a low-carbon economy.

Renovation and new housing remain essential to tackle demographic issues globally. The Group is well positioned to respond to this opportunity because the products directly contribute to energy savings. Providing homes with windows and doors with optimal insulation values made from recycled material and recyclable themselves; this is our business value and the reason why our business and sustainability strategy are resilient on the long term.

The decarbonization strategy comes with short-term investments. Access to finance is safeguarding through a SLL, agreed upon 2022 and in place until 2027. There are no indications refinancing would not be possible.

Existing productive assets are evaluated on a continuous basis to meet current and future (building and technological) standards.

Necessary reskilling of employees is part of the HR training plan. The current evaluation is that the skills needed to enable to meet the decarbonization targets are not that fundamentally different than the ones needed to be able to be an innovative employer.

Policies related to climate change mitigation and adaptation

The objectives and approaches to climate change mitigation are integrated in the Group Health, Safety and Environment policy.

Group Health, Safety and Environment Policy

Key content:

• Formalizes commitment to reduce GHG emissions in own operations (Scope 1, 2) through renewable energy and energy efficiency
• Includes upstream and downstream value chain commitments to recycling and use of recycled materials in product design (Scope 3)
• References SBTi targets for GHG emission reductions
• Emphasizes environmental compliance

Scope:

Downstream impacts are indirectly included through the Scope 3 target.

Governance:

• Management oversight: Group CTO and CFO
• Coordination at Group level: Group Sustainability Manager and Global Technology Director
• Roll-out of general objectives integrated in operational responsibilities at regional level within the Group

Implementation monitoring:

The roll-out is integrated into operational responsibilities at regional level. There is management oversight by the Group CTO and CFO, with coordination by the Group Sustainability Manager and Global Technology Director.

Policies for upstream value chain

For managing environmental sustainability impacts in the upstream value chain, the company has specific requirements and a Supplier Code of Conduct.

Key content:

• Mandatory implementation of recognized quality and environmental management systems (ISO 9001 and ISO 14001) for raw material suppliers
• Encourages participation in voluntary industry initiatives (VinylPlus Product Label and ECVM Industry Charter)
• Suppliers must establish an environmental management system
• Key suppliers are rated on their sustainability/carbon strategy and product carbon footprint data as part of procurement decisions
• Suppliers requested to provide information on decarbonization strategy, roadmap, and product carbon data through Environmental Product Declarations

Scope:

All suppliers. The Supplier Code of Conduct must be signed by all suppliers.

Implementation monitoring:

Monitored by regional purchase and EHS departments in the Group, overseen by the Group Sustainability Manager. Responsibility lies with Regional Managing Directors, part of Executive Management.

Policies for downstream operations

No policies for downstream IRO's are disclosed.

Actions and resources in relation to climate change policies

Transition Plan Overview

As part of the SBTi approval process, the Group developed a transition plan towards the target year 2030. The transition plan has been approved by the Executive Management and Board of Directors of the Group as part of the SBTi commitment and approval process.

The action plan to decarbonize the direct GHG emissions mainly builds upon the broader deployment of established technologies rather than new technologies.

Four Key Decarbonization Levers

1. Increasing consumption of renewable electricity in production (Scope 2)

Scope: Own operations

Time horizon: Short to medium term (target year 2030)

Actions taken in reporting year:

• Solar PV systems with a combined capacity of 3,400 kWp have been installed at three Group locations, including two sites in Türkiye and one in Europe
• Assessment of (financial and technical) possibilities to install solar photovoltaic (PV) systems on rooftops and to source electricity through mechanisms such as Guarantees of Origin (GoO) and virtual Power Purchase Agreements (vPPAs)

Responsibilities: Ongoing efforts led by the purchasing and technical teams

Link to EU Taxonomy: Category 7.6: Installation, maintenance and repair of renewable energy technologies

2. Energy and operational efficiencies in production (Scope 1, 2)

Scope: Own operations

Time horizon: Short to medium term (target year 2030)

Actions taken in reporting year:

• LED relighting projects
• Machinery replacements with energy-efficient solutions
• Installation of energy meters to enable precise monitoring and analysis of energy consumption, accompanied by efforts to integrate real-time monitoring of energy consumption of machinery in the IT-system used by operations
• Feasibility study of HVAC system at HQ (electrification of heating)
• Installation of e-chargers at one site

Responsibilities: Energy efficiency programs are implemented locally and aligned with prioritized initiatives at the Group level. The roll-out of the plan is integrated within business operations.

Link to EU Taxonomy:

• Category 7.3: Installation, maintenance and repair of energy efficiency equipment
• Category 7.4: Installation, maintenance and repair of charging stations for electric vehicles in buildings
• Category 7.5: Installation, maintenance and repair of instruments and devices for measuring, regulation and controlling energy performance of buildings

3. Sourcing less carbon-intensive raw materials (Scope 3)

Scope: Upstream value chain

Time horizon: Short to medium term (target year 2030)

Actions:

• Key suppliers are rated on their sustainability/carbon strategy and the product carbon footprint data, as part of the procurement decision process
• Key raw materials suppliers are requested to provide information on their decarbonization strategy and roadmap
• Suppliers are requested to provide product related carbon data through Environmental Product Declarations

Responsibilities: Task embedded in by the regional purchase teams in cooperation with the Group Sustainability Manager

Policy support: Supplier Code of Conduct outlines the Group's expectation for suppliers to establish an environmental management system. Mandatory for raw material suppliers to implement recognized quality and environmental management systems, such as ISO 9001 and ISO 14001. Participation of suppliers in voluntary industry initiatives (VinylPlus Product Label and the ECVM Industry Charter) is encouraged and tracked.

Expected outcome: By prioritizing suppliers who offer low-carbon materials, strengthen supply chain resilience and align with customer preferences for sustainable PVC solutions

4. Increased use of recycled materials (Scope 3)

Scope: Own operations and value chain

Time horizon: Short to medium term (target year 2030)

Actions:

• Increased recycling of PVC (pre-consumer and post-consumer material) with a greater usage of recycled material in new products
• EPD prepared during 2024 for the recycled material produced in the recycling plant in Diksmuide (Belgium)

Responsibilities: Integrated into the responsibilities of the recycling plant in Belgium, the regional product management teams focusing on product design and the extrusion plants tasked with implementing technological adjustments to co-extrusion lines

Expected outcome: Using recycled materials not only reduces waste and raw material dependency but also positions the company as a leader in the circular economy. Revenue growth will be increasingly driven by a higher share of sales which incorporate recycled materials and as such, have a lower carbon impact.

Link to EU Taxonomy: Category 5.9: Material recovery from non-hazardous waste (aligned with Climate Change Mitigation objective)

Environmental Product Declarations (EPDs)

Scope: Downstream value chain

Time horizon: Phased approach between 2025 and 2028

Actions taken in reporting year:

• New EPDs for window solutions launched in Colombia in 2024
• EPDs for full product range in the French market prepared during 2024
• EPD for recycled material produced in the recycling plant in Diksmuide (Belgium) prepared
• Internal approach for data collection, calculation and verification in development

Responsibilities: Dedicated roles within the European organization have been attributed to ensure compliance

Expected outcome: EPDs help customers to make more informed decisions on environmental performance of products from a life cycle perspective. Delivering strong environmental performance in EPDs could enhance the Group's market share.

Forecasted Impact of Key Decarbonization Levers

Cumulative locked-in GHG emissions associated with key assets and activities from 2021 until 2030 (cfr. 'Business as Usual scenario'):

• Scope 1, 2 GHG emissions: 119,954 tCO2e
• Scope 3 GHG emissions: 1,124,778 tCO2e

Resources and Investments

Financial resources: The investments for the implementation transition plan have not been quantified. They are demonstrated through the annual EU Taxonomy disclosures.

Alignment with EU Taxonomy: The Group will further work toward aligning its economic activities under Category 3.5 (Manufacture of energy efficiency equipment for buildings) and the Category 7 activities with the EU Taxonomy DNSH-criteria on climate adaptation in the coming years, although no concrete action plan has been established yet.

Access to finance: The decarbonization strategy comes with short-term investments. Access to finance is safeguarding through a SLL (Sustainability-Linked Loan), agreed upon 2022 and in place until 2027.

Non-financial resources:

• Necessary reskilling of employees is part of the HR training plan. The current evaluation is that the skills needed to enable to meet the decarbonization targets are not fundamentally different than the ones needed to be an innovative employer.

Governance and Oversight

Management oversight: Group CTO and CFO

Coordination: Group Sustainability Manager and the Global Technology Director

Regional responsibility: Regional Managing Directors (part of the Executive Management)

Monitoring: Regional purchase and EHS departments

Targets related to climate change mitigation and adaptation

SBTi-validated GHG emission reduction targets

Deceuninck has validated Science Based Targets initiative (SBTi) near-term targets for reduction of scope 1, 2 and 3 emissions by 2030 and long-term net-zero targets for 2050 (from a 2021 base year). These targets were validated by SBTi in September 2023.

Scope 1 and 2 combined target

Progress to date (2024):

• Scope 1 actual 2024: 10,392 tCO2e (vs. 11,672 tCO2e in 2023; -11% year-on-year)
• Scope 2 (market-based) actual 2024: 50,467 tCO2e (vs. 50,689 tCO2e in 2023; 0% year-on-year)
• Target 2030: 30,871 tCO2e combined Scope 1 & 2
• Annual reduction target: -6.7% per year (Scope 1 & 2 combined)

Scope 3 target

Progress to date (2024):

• Scope 3 actual 2024: 619,235 tCO2e (vs. 612,426 tCO2e in 2023; +1% year-on-year)
• Target 2030: 542,821 tCO2e (absolute) / 1.4 tCO2e/tPVC (intensity)
• Annual reduction target: -2.8% per year

Long-term net-zero target

Sustainability Linked Loan target (market-based Scope 2)

The Group has a separate target aligned with its Sustainability Linked Loan (SLL) agreed in 2022, valid until 2027:

• Target metric: Market-based carbon emissions (Scope 1 & 2)
• Target value: Annual reduction of on average 6.5% per year between 2022 and 2026
• Target for 2024: Maximum 64,952 tCO2e
• Baseline: 2022

Key decarbonization levers

The targets are supported by four key decarbonization levers with estimated reduction potential by 2030:

1. Increasing renewable electricity consumption (Scope 2)
2. Energy and operational efficiencies (Scope 1, 2) - 10% contribution to target
3. Sourcing less carbon-intensive raw materials (Scope 3) - 44% contribution to Scope 3 target
4. Increased use of recycled materials (Scope 3)

Notes on methodology:

• Scope 1, 2 target uses market-based calculation method for electricity
• Baseline year 2021 was restated in 2024 due to methodology updates (emission factor updates and inclusion of upstream transportation category)
• The targets are compatible with limiting global warming to 1.5°C above pre-industrial levels (Paris Agreement)

Energy consumption and mix

Energy mix 2024 vs 2023

Scope and methodology

Geographical scope: Group entities and production facilities in Belgium, Colombia, Croatia, France, Germany, Poland, Russia, Spain, Türkiye, United Kingdom, United States. Locations with purely warehouses and/or sales offices are excluded as not material.

Technical scope: All greenhouse gases are considered. Energy consumption data sourced from direct measurement at facilities.

Market-based method: The renewable energy percentage uses the market-based calculation method for electricity-related emissions, reflecting Guarantees of Origin (GoO) and renewable electricity contracts.

Restated 2023 figures: The 2023 energy consumption figures were restated due to methodology updates. Previously, electricity generated by a cogeneration system was classified under electricity consumption. In line with CSRD definitions, only natural gas consumption by the cogeneration unit is now included in the energy mix. The revised 2023 total energy consumption is 209,451 MWh (previously disclosed as 218,688 MWh). Revised electricity consumption is 160,200 MWh (previously 169,447 MWh).

Energy intensity

Energy intensity metrics are not disclosed in this report.

Additional context

23% of location-based Scope 2 GHG emissions are linked to purchased electricity bundled with Guarantees of Origin. Solar PV systems with a combined capacity of 3,400 kWp were installed at three Group locations in 2024, including two sites in Türkiye and one in Europe.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1, 2 and 3 GHG emissions

*The 2030 targets set are distinct from the metrics provided in the CSRD template and as such, cannot be disclosed according to the template. The target is to reduce Scope 1 and 2 combined by 60% and Scope 3 by 52% per tonne PVC by 2030 (SBTi targets).

GHG Intensity

Value chain split of GHG emissions

Other GHG Indicators

Methodology and scope notes

Greenhouse Gas Protocol applied.

Geographical scope: Group entities and production facilities in Belgium, Colombia, Croatia, France, Germany, Poland, Russia, Spain, Türkiye, United Kingdom, United States. Locations with purely warehouses and/or sales offices are excluded as not material.

Technical: All greenhouse gases are considered.

Emission factors: Internationally recognized emission factor databases (Ecoinvent 3.10, ADEME Base Carbone® v. 23.4, DEFRA), EPD from suppliers, sector and product specific LCA reports and national electricity emission factors from IEA reports.

Scope 1, 2:

• Electricity: IEA country emission factors, except for USA where regional EF's are used (EGrid).
• Company cars: for fossil fuel cars, an average annual distance of 25,000 km is multiplied with the number of cars per subcategory. For e-cars, an average annual distance of 25,000 km is used in combination with average real-world consumption per km (source: ev database.org).

Scope 3:

• Cat 1 Purchased goods and services: majority of the emission factors come from EcoInvent 3.10. A different regional emission factor for Europe and 'Rest of World' is used based on the country of production of the suppliers. For European production of PVC resin and foiling material the externally verified sector and product specific LCA reports are used. For aluminium a supplier EPD-based emission factor is used.
• Cat 4 Upstream transportation and distribution and Cat 9 Downstream transportation and distribution: emission factor per tonne.km are based on Base Carbone® ADEME v. 23.4.
• Cat 5 Waste generated in operations: an emission factor is applied in function of waste category and treatment method (recycling, incineration, landfill). The majority of the emission factors are based on Base Carbone® ADEME v. 23.4.
• Percentage of scope 3 emissions using primary data from suppliers: 0.3%.
• 23% of location-based scope 2 GHG emissions are linked to purchased electricity bundled with Guarantee of Origins.

Scope 3 exclusions:

• GHG emissions categories excluded from the inventory following a screening because they are not material: 2. Capital goods; 6. Business travel; 7. Employee commuting; 8. Upstream leased assets; 10. Processing of sold goods; 12. End-of-life treatment of sold products.
• Scope 3 GHG emissions categories not applicable to the Group: 11. Use of sold goods; 13. Downstream leased assets; 14. Franchises; 15. Investments.

Restatement of prior years: Due to a methodology update in 2024 resulting in a material change in GHG emissions, the reported values of 2023 (year -1) and 2021 (base year of the SBTi targets) were restated. The changes were:

• Updates of the carbon emission factors: shift from Bilan Carbone to Eco-Invent for raw materials (Scope 3 Category 1 Purchased Goods & Services), update to the newest version of Bilan Carbone for the other categories (Scope 3 Category 5 Waste, Category 4 & 9 Upstream & Downstream transportation).
• Inclusion of a new category (Upstream transportation) to allow for a more complete coverage of Scope 3 related impacts. This category was not previously calculated due to limited data availability.

2023 restated figures:

• Scope 3 tCO2e emissions: previously disclosed 481,240; revised to 612,426.
• Total tCO2e emissions (Scope 1, 2, 3): previously disclosed 531,549; revised to 662,722.

Energy consumption restatement: The electricity generated by a cogeneration system was previously considered under electricity consumption. In line with the CSRD definition, only natural gas consumption consumed by the cogeneration unit should be considered in the energy mix. Therefore, the related electricity consumptions have been restated in the previous year reporting and 2021 (base year of the SBTi targets).

2023 restated energy figures:

• Total energy consumption: previously disclosed 218,688 MWh; revised to 209,451 MWh.
• Total electricity consumption: previously disclosed 169,447 MWh; revised to 160,200 MWh.
• Share of renewable sources in total energy consumption: previously disclosed 45%; revised to 32%.

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

Assessment of materiality and phase-in

The following ESRS E1-9 datapoints that derive from other EU legislation are deemed not material to the Group:

• ESRS E1-9: Exposure of the benchmark portfolio to climate-related physical risks paragraph 66
• ESRS E1-9: Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a)
• ESRS E1-9: Location of significant assets at material physical risk paragraph 66 (c)
• ESRS E1-9: Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67
• ESRS E1-9: Degree of exposure of the portfolio to climate-related opportunities paragraph 69

Climate Change Adaptation - DNSH assessment

The Group does not meet the DNSH criteria Climate Change Adaptation under the Climate Change Mitigation objective. It has not implemented adaptation solutions and performed a robust climate risk and vulnerability assessment according to all criteria of the Taxonomy for all activities and all locations in scope of the eligibility reporting.

Policies related to pollution

Deceuninck explicitly states that there is no specific policy in place to ensure compliance with Regulation (EU) 923/2023 related to pollution.

Approach

Instead of a dedicated policy, procedures and actions are integrated into operational processes, procedures and practices.

Compliance verification:

• Compliance is independently verified by the Recyclass audit scheme
• The recycling and extrusion plants in Belgium are certified against ISO 14001
• The ISO 14001 management system covers the pollution topic amongst others

Future plans:

• There are no immediate plans to develop a specific policy

Key operational procedures

While not formalized as a named policy, the company follows procedures as stated in Regulation (EU) 923/2023 to ensure transparency and compliance regarding the presence of lead in recycled materials and products.

Actions and resources related to pollution

Compliance with EU Regulation 923/2023 on Lead in Recycled PVC

The Group follows the procedures as stated in Regulation (EU) 923/2023 to ensure complete transparency and compliance of the presence of lead in recycled materials and products.

Scope: Own operations (recycling and extrusion facilities)

Time horizon: Implemented end of 2024

Key actions:

• Co-extrusion manufacturing process: The visible surface of profiles and sheets employed in interior building applications is produced in material containing less than 0.1% lead. In profiles and sheets for terraces, recyclate is used in a middle layer entirely covered by a material layer containing less than 0.1% lead. Virgin PVC is combined with recyclate through co-extrusion.

• Product marking: PVC profiles containing recyclate are visibly marked with the statement "contains ≥ 0.1% lead".

• Controlled recycling loop verification: The origin and use of recyclate is independently verified to comply with EN 15343:2007. The extrusion sites in Europe are certified against the Traceability scheme of RecyClass Recycled Plastics Traceability guidelines. The recycling plant in Diksmuide (Belgium) is certified to meet the Recycling Process Audit Scheme.

• Continuous lead testing: Lead levels in recyclate and profiles are continuously checked at the recycling factory through testing in the lab. Test results are monitored by EPPA (European Trade Association of PVC Window System Suppliers). A sample of the test results were subjected to an additional review by an external laboratory in 2024.

Resources allocated:

• Financial: These procedures have been implemented end of 2024 without associated CapEx expenditure
• Non-financial: Independent verification by RecyClass audit scheme; monitoring by EPPA; external laboratory reviews

Expected outcomes: The actions ensure that lead (Pb) is present in recyclate in a controlled environment. As a result, handling the profiles and the recycled material is harmless and safe.

Linkage: Compliance is independently verified by the RecyClass audit scheme. The recycling and extrusion plants in Belgium are certified against ISO 14001, which covers the pollution topic.

Soil Contamination Monitoring

Action: Potential soil contamination at the recycling plant is measured every 10 years in accordance with applicable legislation.

Scope: Own operations (recycling plant)

Time horizon: Next measurement planned for 2028 (previous measurement: 2018)

Expected outcomes: During the previous measurement in 2018, no deviations from the limit values were found.

Health Monitoring

Action: Potential health effects are measured annually via blood samples.

Scope: Own operations (employees at recycling facility)

Expected outcomes: Results show that lead detection remains below the limit values.

Process Water Management

Action: To avoid soil contamination, process water in the recycling site is captured and cleaned prior to discharge, in accordance with applicable legislation.

Scope: Own operations (recycling site)

Linkage: Compliance with applicable legislation

Targets related to pollution

The Group does not apply targets related to the presence of SVHC (Lead), as the presence is an inevitable effect of processing post-consumer PVC.

Whereas the activities in the recycling factory (testing of lead presence and independent audit of waste inflows and outflows) were already executed prior to the new regulations which came into force in 2024, the controlled-loop requirements for the extrusion facilities were recently introduced because of the Derogation.

Pollution of air, water and soil

Context

Deceuninck assessed potential impacts, risks and opportunities related to pollution of air, water and soil. The company determined that the most material pollution topic relates to substances of very high concern (SVHC), specifically lead (Pb) in recycled PVC, rather than direct emissions to air, water or soil.

Material pollution topic: Lead in recycled PVC

The Group recycles post-consumer PVC material which historically contained lead as a stabilizer (used prior to 2004). This lead is deeply integrated within the PVC material itself in a fixed and insoluble form. The recycled materials are incorporated into the final product in a controlled closed-loop system.

Effective 29 November 2024, EU Regulation 2023/923 came into force, banning lead in PVC in concentrations ≥ 0.1%, with a derogation allowing recovered rigid PVC with a maximum of 1.5% presence until May 2033. This derogation allows the recycling of post-consumer PVC.

These IROs are only material for Group activities in Europe, as the Group only recycles post-consumer material in Europe.

Monitoring and controls

The lead levels in recyclate and profiles are continuously checked at the recycling factory through testing in the Group's laboratory. Test results are monitored by EPPA (European Trade Association of PVC Window System Suppliers). A sample of the test results were subjected to an additional review by an external laboratory in 2024.

Compliance is independently verified by the Recyclass audit scheme. The recycling and extrusion plants in Belgium are certified against ISO 14001.

Soil contamination monitoring: Potential soil contamination at the recycling plant is measured every 10 years in accordance with applicable legislation. The next measurement is planned for 2028. During the previous measurement in 2018, no deviations from the limit values were found.

Health monitoring: Potential health effects are measured annually via blood samples. Results show that lead detection remains below the limit values.

Water treatment: To avoid soil contamination, process water in the recycling site is captured and cleaned prior to discharge, in accordance with applicable legislation.

Other pollution topics assessed as not material

Additional potential IROs related to raw materials processed by the Group, as well as other forms of pollution—including air, water and soil pollution—were assessed but determined not to be material.

The manufacture of PVC resin and additives involves the use of potentially polluting chemicals. However, the risks are adequately controlled. All manufacturing processes of all suppliers are very tightly regulated. Regulations are complemented by voluntary industry commitments (example ECVM Charter). Over the past two decades, hazardous substances such as lead have been substituted with safer alternatives. Compliance with REACH regulation is monitored on a continuous basis through the use of Safety Data Sheets for all raw materials.

E-PRTR disclosure

The company notes in its EU Taxonomy disclosure that it does not report on:

Amount of each pollutant listed in Annex II of the EPRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil, paragraph 28

This datapoint is listed as voluntary/omitted in the company's phase-in plan.

Scope

As the Group only recycles post-consumer material in Europe, the pollution-related IROs elaborated are only material for activities of the Group in Europe.

Substances of concern and substances of very high concern

E2-5 Substances of concern and substances of very high concern

Total amounts of substances of very high concern used during production (ton): 158

Total amounts of substances of very high concern that leave the facilities (ton): 158

The volumes mentioned above are based on testings done in the recycling factory of the Group. On a sample basis, the test results are verified by the European industry association.

The average share of Lead detected in the material recycled is multiplied by the volume of internal and external sales of the recycling plant. The lead is present in recycled granulates. It is partly processed in products of the Group and partly used in products of other manufacturers outside of Deceuninck.

Context and Management Approach

Through the recycling and use of post-consumer PVC, small amounts of lead (Pb) are used in the production of new products. This is done in accordance with the European Derogation for PVC articles (Regulation (EU) 923/2023). Industry phased out lead stabilizer in virgin PVC since 2015.

Lead can have harmful effects on human health and can negatively impact both fauna and flora in the environment. However, the substance, categorized as a heavy metal, is deeply integrated within the PVC material itself. The recycled materials are incorporated in a fixed and insoluble form into the final product. As a result, handling the profiles and the recycled material is harmless and safe.

Effective since 29th November 2024, Regulation (EU) 923/2023 came into force. The European legislator has explicitly acknowledged the presence of lead as a legacy additive in PVC recyclate. This recyclate contains lead due to its previous application in stabilizing PVC profiles and other related products before 2004. The lead is deeply integrated within the PVC material. Considering extensive scientific evaluations, the European legislator has determined that recycling this Pb-containing material within a controlled loop system represents the safest and most sustainable approach to manage this Pb existing on the market, in view of the low risks and the lack of suitable alternatives.

REACH Compliance and Monitoring

Compliance with REACH regulation is monitored on a continuous basis through the use of Safety Data Sheets for all raw materials.

The Group follows the procedures as stated in the Regulation (EU) 923/2023 to ensure complete transparency and compliance of the presence of lead in recycled materials and in our products:

• The visible surface of profiles and sheets employed in interior building applications (facing the occupied areas of a building after installation) is produced in a material containing less than 0.1% lead. In profiles and sheets for terraces, recyclate is used in a middle layer entirely covered by a material layer containing less than 0.1% lead. Concretely, this is done through a co-extrusion manufacturing process, in which virgin PVC is combined with recyclate.
• PVC profiles containing recyclate are visibly marked with the statement "contains ≥ 0.1% lead".
• To ensure a controlled recycling loop, the origin and use of recyclate is independently verified to comply with EN 15343:2007. The extrusion sites in Europe are certified against the Traceability scheme of RecyClass Recycled Plastics Traceability guidelines. The recycling plant in Diksmuide (Belgium) is certified to meet the Recycling Process Audit Scheme.
• The lead levels in recyclate and profiles are continuously checked at the recycling factory of the Group through testing in the lab of the Group. Test results are monitored by EPPA (European Trade Association of PVC Window System Suppliers). A sample of the test results were subjected to an additional review by an external laboratory in 2024.

Potential soil contamination at the recycling plant is measured every 10 years in accordance with applicable legislation. The next measurement is planned for 2028. During the previous measurement in 2018, no deviations from the limit values were found. Potential health effects are measured annually via blood samples. Results show that lead detection remains below the limit values.

To avoid soil contamination, process water in the recycling site is captured and cleaned prior to discharge, in accordance with applicable legislation.

Compliance is independently verified by the Recyclass audit scheme. In addition, the recycling and extrusion plants in Belgium are certified against ISO 14001. This management system covers the pollution topic amongst others.

Policies related to water and marine resources

Deceuninck has disclosed that there is no specific policy in place for water management. The company states that procedures and practices are integrated into operational processes, procedures and practices in all plants of the Group. There are no immediate plans to develop a specific policy as the current integrated approach effectively ensures water management is handled efficiently.

Water management through ISO 14001

• Scope: Water usage and wastewater management are included in the ISO 14001 management system, which is adopted by 4 plants in the Group (3 extrusion and 1 recycling and compounding plant)
• Key content: Water management practices are covered in the management systems, including the use and source of water, water treatment, prevention of water pollution

Supplier Code of Conduct

• Scope: All suppliers
• Key content: The Supplier Code of Conduct outlines the Group's expectation for suppliers to establish an environmental management system
• Monitoring: The supplier assessment criteria are jointly monitored by the regional purchase and EHS departments in the Group and overseen by the Group Sustainability Manager
• Governance: Responsibility lies with the Regional Managing Directors, part of the Executive Management

Supplier requirements for environmental management

• Scope: Raw material suppliers (upstream value chain)
• Key content: It is mandatory for raw material suppliers to implement recognized quality and environmental management systems, such as ISO 9001 and ISO 14001. Additionally, participation of suppliers in voluntary industry initiatives, including the VinylPlus Product Label and the ECVM Industry Charter, is encouraged and tracked. These water management practices are covered in the management systems, including the use and source of water, water treatment, prevention of water pollution
• Links to standards: ISO 9001, ISO 14001, VinylPlus Product Label, ECVM Industry Charter

Sustainable oceans and seas

Not disclosed (referenced in the table of ESRS disclosures as ESRS E3-1 paragraph 14, but no content provided in the excerpts)

Actions and resources related to water

Closed-loop water systems in extrusion

Description: Water re-use and water treatment systems are integrated into the extrusion setups via closed-loop water systems. These systems collect, filter and reuse water from the extrusion process, minimizing water intake. Water is captured after extrusion and passed through a chiller unit to remove heat, after which it is partly reused in production again.

Scope: Own operations

Expected outcomes: Reduces water consumption, cuts costs of water procurement and wastewater discharge and maintains consistent water quality, critical for product quality.

Water pollution prevention through filtration

Description: Filtration technologies are used to avoid water pollution and ensure contaminants do not spread. Groundwater is filtered prior to using it in extrusion, as well as after extrusion prior to discharge. The filtration systems use mechanical filters to remove solid particles (notably PVC residues). Additionally, contaminants are neutralized via chemical cleaning.

Scope: Own operations

Wastewater treatment system at Diksmuide recycling plant

Description: The recycling plant in Diksmuide (Belgium) has a more extensive wastewater treatment system in place to remove larger solids and heavier particles before disposal, via mechanical and chemical treatment.

Scope: Own operations (Belgium)

Water storage basins in Türkiye

Description: In the plants in Türkiye located in areas of material water stress, a water basin is integrated under the buildings to store water and reduce freshwater intake.

Scope: Own operations (Türkiye - areas of material water stress)

Process efficiency measures implemented in 2024

Description: Installation of an industrial filter and a revamp of the dosing system for water treatment. The updated water cleaning system allows for a more efficient treatment for process water, which reducing water contamination. This minimizes water discharge and allows for greater reuse of process water.

Scope: Own operations (sites in areas at water risk in Belgium)

Time horizon: Implemented in 2024

Expected outcomes: Minimizes water discharge and allows for greater reuse of process water (no quantifiable results available)

Water measurement and monitoring improvement

Description: More accurate, monthly measurement and monitoring of water consumptions in all sites through online tool. Meters for water discharge will be installed in 2025 in key locations where this is still lacking.

Scope: Own operations (all sites)

Time horizon: 2025 (planned)

Cooling tower conversion and air-cooled chiller installation

Description: One cooling tower in an area at water risk was adapted to a closed loop type. At the same location an air-cooled chiller was introduced as a replacement for a water-cooled industrial chiller. Air-cooled industrial chillers rely on fans to dissipate heat outside the building.

Scope: Own operations (area at water risk)

Time horizon: Implemented in 2024

Expected outcomes: Improvement by avoiding evaporation from open, industrial cooling towers

Value chain actions

No actions are identified for the value chain.

Targets related to water

The Group has not set targets on water consumption due to lack of comparable year-over-year data. The aim is to set targets for water consumption in 2026, once 2024 and 2025 data allow for a good comparison on Group level.

This does not prevent us from implementing efficiency measures to reduce water consumption, with priority focus on locations at material water risk.

Water consumption

Water consumption metrics

Methodology

Water consumption is calculated as the amount of water withdrawal minus the amount of water discharge, measured in cubic meters per year. Water withdrawal is the volume of incoming water purchased from third parties (drinking water) and from rainwater and groundwater sources. Water consumption is defined as the amount of water which is not returned to the water body it was taken from.

The information is based on direct measurements. At the 2 locations where the discharge is not measured, the average water discharge share of the Group is applied as best estimate (< 5% of total water consumption). The metric is not validated by another body than the assurance provider.

The water consumption cannot be compared with previous years as the calculation methodology has changed in 2024. In line with the ESRS E2, water discharge is taken into consideration in 2024. This was not measured yet in 2023. Nevertheless, in general, water withdrawal volume follows production volume.

The volume of water stored is linked to two facilities where water storage systems are available. There are separate storage facilities for process water and for sprinkler water systems. There are no changes in water storage capacity in 2024 compared to previous years.

Scope

The scope of the metrics is limited to the Group entities and production facilities in the following countries (in alphabetic order): Belgium, Colombia, Croatia, France, Germany, Poland, Russia, Spain, Türkiye, United Kingdom, United States. As a result of the DMA, locations with purely warehouses and/or sales offices are not material and therefore excluded.

Water stress areas

6 key sites of the Group, of which 5 extrusion sites and 1 recycling site, are located in water intensity areas. 3 locations are in areas of extremely high water stress risk.

Policies related to resource use and circular economy

Group EHS Policy

The Group EHS policy underscores Deceuninck's commitment to circular economy, highlighting the core elements of recycling and usage of recycled content in the production.

Key content and principles:

• Recycling: The Group pursues a strategy of in-house recycling of postconsumer PVC material through a closed loop system at superior efficiency. The quality of the recycled material to ensure the quality of the end-product is paramount. The Group invests in automated recycling processes that eliminate contaminations from other waste streams in the PVC fraction. All recycled materials comply with the applicant quality certifications.

• Use of recycled materials: The use of recycled materials and recyclability are key design criteria applied by product design teams. They follow the Design for Recycling guidelines of EPPA. These were processed into a draft European Standard in 2024. The principles focus on functionality, product-specific design for recycling and identifying the recycled content. The same guidelines are followed in the Turkish facilities of the Group on a voluntary base.

• Waste materials: Waste materials of the internal production processes or byproducts are grinded and re-used on-site. This is already done since 2012. As such, extra transportation is avoided. When the PVC material is contaminated, it is not recycled on-site, but at local waste recyclers or in the Group's recycling facility in Diksmuide (Belgium).

External certifications and standards:

• The recycling plant in Diksmuide (Belgium) is independently certified by Recyclass, affirming the quality of the recycling processes and the origin of the waste
• The Group contributes to the European recycling objectives of Recovinyl and Vinylplus
• European extrusion sites are audited by Recyclass for the first time in 2024 to externally verify the traceability of the use of the recycled materials. The verification requirements are aligned with those of EN 15343:2007 standards
• Deceuninck North America is GreenCircle Certified for the recycled content in window profiles (certification renewed in 2024)
• For European sites the VinylPlus product label has been renewed in 2024, confirming that products comply with the sustainability standards established for the PVC industry, including raw material procurement and use of recycled PVC

Actions and resources related to circular economy

Collection and recycling of post-consumer PVC waste

Scope: Downstream value chain (collection from window and door fabricators and installers)

What it does: Collection and recycling of end-of-life PVC through a breaking, cleaning, sorting and granulation process at the recycling plant in Diksmuide (Belgium).

Time horizon & milestones:

• Ongoing since 2012 for internal production waste
• Extended to preconsumer waste outside Europe since 2022
• 5-year investment plan finalized in 2024

Resources allocated:

• 2024 capex: €4.7 million invested in the recycling plant
• Enhancements included: expanding breaking and cleaning capacity, adding three granulation lines, constructing an extra warehouse and implementing process improvement initiatives

Expected outcomes:

• Recycling capacity increased from 8,000 tonnes (2017) to 40,000 tonnes annually
• Avoidance of 45,000 tons of carbon equivalents
• Annual recycling volume target for 2024: 23,152 tons
• Target for 2025: 26,393 tons
• Annual increase target: 10% to 16% year-over-year

Quality certifications:

• Recyclass certification for the recycling plant
• European extrusion sites audited by Recyclass in 2024 for traceability verification
• Verification aligned with EN 15343:2007 standards

Link to targets: Targets set voluntarily with banking partner in context of Sustainability Linked Loan (2022)

Collection program for cut-off material from fabricators and installers (2024)

Scope: Downstream value chain

What it does: Increased efforts to collect and recycle cut-off material from window fabricators and installers

Time horizon:

• North America: Program initiated in 2023, evaluated in 2024, increased customer cooperation planned from 2025
• Belgium: New initiative launched in 2024 (www.gobag.be)

How it works (Belgium):

• Window installers order big bags to fill with mixed materials (aluminium, PVC, wood, metal and glass)
• Collection from installers or construction sites
• Transportation for recycling

Investment in co-extrusion production lines

Scope: Own operations

What it does: Enables processing of more recycled PVC in product manufacturing through separated material inflow (virgin and recycled PVC)

Resources allocated:

• 2024 capex: €1,212,300 invested in new co-extrusion lines in Europe and Türkiye

Approach: Investment plans prioritize co-extrusion for new extrusion lines and gradual shift of existing lines

Link to targets: Central element of the Group's Scope 3 decarbonization target by 2030

R&D projects for scaling recycled materials use

Scope: Own operations

What it does: Multiple R&D initiatives aimed at:

• Scaling up use of recycled materials in production
• Enhancing valorization of waste fractions lacking circular solutions

Specific projects:

• OpToSims project: Investigating improved tool designs for recycled PVC through simulation procedures
• Foiling process optimization: Enabling up to 80% recycled content in profiles
• Glass fiber recycling: Exploring ways to recycle glass fibers for use in injection-molded parts

Design for Recycling approach

Scope: Own operations (product design)

What it does: Application of recycled materials and recyclability as key design criteria

Guidelines followed:

• EPPA Design for Recycling guidelines
• Processed into draft European Standard in 2024 (FprEN 18066:2024)
• Principles focus on functionality, product-specific design for recycling and identifying recycled content
• Applied in Turkish facilities on voluntary basis

Certifications maintained:

• GreenCircle Certification (North America) - renewed in 2024
• VinylPlus product label (European sites) - renewed in 2024

On-site reuse of internal production waste

Scope: Own operations

What it does: Internal production waste and byproducts are grinded and re-used on-site

Time horizon: Ongoing since 2012

Benefits: Avoidance of extra transportation

Exception: When PVC material is contaminated, it is recycled at local waste recyclers or at the Group's recycling facility in Diksmuide

Targets related to circular economy

Recycling facility output volume target

Deceuninck has set annual targets to increase the recycling volumes of the Group's recycling facility. This relates to the output weight of PVC material processed in the recycling factory, ready for being used in new products.

Scope: The targets relate to the Group's recycling facility output volumes.

Target methodology: The targets envisage an annual increase as of 2022 of 10% to 16% with the forecasted volumes of the previous year.

Recycled material consumption in new products

There is no specific volume or percentage target set for the consumption of recycled material in new products. However, the Group intends to gradually increase the share year-over-year.

Progress to date (2024):

• 16.5% recycled PVC material, including byproducts, was used in production (2023: 15.1%)
• 6.3% recycled materials excluding post-industrial waste (2023: 5.9%)

Note: The use of recycled PVC is described as a central element of the Group's Scope 3 decarbonization target by 2030, though no specific circular economy target percentage or volume is set.

E5-4 Resource inflows

Overview

The raw materials used to produce PVC compound consist primarily of PVC resin as the base polymer. It is combined with additives to achieve specific properties. Key components include stabilizers for heat and UV resistance, fillers to enhance strength, lubricants for smooth processing and modifiers to improve impact resistance and processing. The total weight of raw material mentioned is a sum of these PVC components, plus the aluminum volume processed in the Turkish facility of the Group.

Materials used

Narrative context

In 2024, on average 16.5% recycled PVC material, incl. byproducts, was used in production. This is a combination of post-consumer waste sourced from the Group's recycling plant, post-industrial waste originating from own production and pre-consumer waste from window fabricators and installers. It is expressed as a percentage from the total input material used.

Excluding the share of post-industrial waste, which is not defined as recycled material in European product standards, the share of recycled materials amounts 6.3%.

Recycling activity volumes

Data quality

The data is sourced from direct weighting and measurement. The volume of recycled material is externally verified by Recyclass.

Resource outflows

Recyclability

PVC products:

• PVC can be recycled at least eight times without losing its mechanical characteristics
• Installed for at least 35 years, PVC has a potential lifecycle of 280 years or more
• PVC is recycled in a closed loop system, meaning the material can be used to create a new version of the same or similar product
• Recycled PVC has the same value as the original, virgin material
• The Group follows Design for Recycling guidelines of EPPA, processed into draft European Standard FprEN 18066:2024 (Design for recycling of PVC based profiles for construction products)

Product design:

• The use of recycled materials and recyclability are key design criteria applied by product design teams
• The Phoenix range makes optimal use of recovery and recycling to give rebirth to post-consumer materials
• The Elegant range is recyclable and the best performing steelless window and door solution available, awarded with German Innovation Award, German Design Award and Red Dot Award for its design and recyclability

Packaging:

• 60% of packaging is reusable or recyclable

Durability

• PVC products have a service life of at least 35 years
• Products are defined by superior thermal and acoustic performance combined with the lowest possible material consumption
• Products are long-lasting, low-maintenance with little maintenance required
• Products are resistant to rot and rust

Product performance

• Window and door solutions defined by superior thermal and acoustic performance
• Energy-efficient products with stylish design
• Products with optimal insulation values
• ThermoFibra and Innergy AP technology provide extra performance in terms of stability, strength and insulation

Waste

Assessment context

Additional potential impacts, risks and opportunities related to waste were assessed but did not meet the materiality thresholds:

• Waste generated — other than PVC production waste
• Resource outflows

Only 2% of the total waste volume is hazardous waste and more than half of the waste volume is recycled.

While waste topics were assessed as not material within the scope of this report, this does not imply a lack of action or commitment of the Group. The Group continues to implement initiatives to minimize the environmental impact of waste and packaging across operations.

Waste management approach

Internal production waste:

• Waste materials of internal production processes or byproducts are grinded and re-used on-site (practice in place since 2012)
• Extra transportation is avoided through on-site recycling
• When PVC material is contaminated, it is not recycled on-site but at local waste recyclers or in the Group's recycling facility in Diksmuide (Belgium)

Post-consumer and pre-consumer waste:

• Since 2022, the Group started to collect and recycle PVC material from window and door fabricators and installers (preconsumer waste) also outside of Europe
• The recycling plant in Diksmuide (Belgium) is independently certified by Recyclass
• In Belgium, a new initiative was launched (www.gobag.be) where window installers can order big bags to fill with a mix of materials (aluminium, PVC, wood, metal and glass) for collection and recycling
• In North America, a program initiated in 2023 was evaluated with increased customer cooperation planned as of 2025

Carbon impact:

• Through recycling activities, the Group directly contributes to preventing waste from ending up in landfills or being incinerated
• These efforts result in the avoidance of 45,000 tons of carbon equivalents

Recycling volumes

The data is sourced from direct weighting and measurement. The volume of recycled material is externally verified by Recyclass.

Policies related to own workforce

Deceuninck has implemented multiple policies covering its own workforce, inspired by externally recognized principles including the International Labour Organisation (ILO) Declarations on Fundamental Principles and Rights at Work, the United Nations (UN) Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises.

Code of Conduct

Scope: All employees of the Group

Governance: The Executive Management is responsible for monitoring whether and how effectively the policy is followed in practice and provides applicable reporting in this regard to the Board of Directors of the Company.

Key content:

• Human rights, the right for workers to organize, collective bargaining
• Equal opportunities and non-discrimination
• Banning of child labour and forced labour
• Anti-bribery and anti-corruption
• Prohibition of harassment and violence in the workplace
• Respect for cultural differences and diversity

Public availability: Available on Sharepoint for employees and via the website of the Group for external stakeholders

Link to international standards: Based on ILO Declarations on Fundamental Principles and Rights at Work, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises

Monitoring: The Executive Management monitors implementation and provides reporting to the Board of Directors. A training on the Code of Conduct is available to employees.

Human Rights Policy

Scope: All employees of the Group (including independent contractors, temporary workers and similar), extends to business partners

Governance: The Executive Management is responsible for monitoring effectiveness and reporting to the Board of Directors

Key content:

• Adequate wages: competitive compensation relative to industry and local labor market, following applicable wage, work hours, overtime and benefits laws
• Social dialogue: respect for employees' right to join, form or not join a labor union, seek representation, bargain collectively without fear of reprisal
• Prohibition of forced labor and human trafficking
• Prohibition of employment of underaged workers
• Diversity & inclusion: prohibition of discrimination on the basis of age, race, color, religion, gender, disability, national/social origin, sexual orientation, political opinion
• Recruitment, remuneration, employment conditions, training, promotion and career development based on professional qualifications only

Public availability: Encompassed within the Code of Conduct, available on Sharepoint and the Group website

Link to international standards: Based on ILO Declarations on Fundamental Principles and Rights at Work, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises

Monitoring: Executive Management monitors implementation. Potential risks are mitigated through active management engagement and empowering employees to report issues. Zero-tolerance culture enforced through investigation and disciplinary process.

Remuneration Policy

Scope: Applies to the remuneration of the Executive Team Group and Regions

Key content: The Group rewards the Executive Team based on contribution to long-term goals, sustainability and respect for the Group's values. Takes into account strategy, relevant market practices, and corporate governance requirements.

Public availability: Not specified

Global Merit Policy

Scope: All managers and expert functions within the company (in development in 2025)

Key content: Defines how Deceuninck incentivizes personnel through a unified global strategy. Adoption subject to local laws which may override specific provisions.

Status: Being developed in 2025

Group EHS Policy

Scope: All employees and non-employees (contractors, temporary workers) and visitors

Key content:

• Safety management system for identification, elimination, reduction and mitigation of risks
• 100% of workers covered by a management system based on legal requirements or recognized standard
• '10 Golden Rules' for behavior-based safety principles introduced in 2023
• Specific policies and procedures on:
  • Handling and storage of dangerous substances
  • Safety Data Sheets
  • Emergency preparedness & response
  • Monitoring and internal management reporting of incidents and near misses
  • Inspections of technical equipment
  • Internal and external communication
  • Training for department heads and operational staff
  • Purchase of new raw materials and machinery
  • Personal protective equipment
  • Working with third parties
  • Preventive alcohol and drug policy

Governance: Local EHS managers oversee implementation with direct reporting line to regional management. Safety performance reviewed monthly by safety managers and regional management.

Link to international standards:

• Deceuninck Türkiye applies ISO 45001 Occupational Health and Safety management system
• US plants apply Federal & State Occupational Safety & Health Administration Standards
• Deceuninck Europe based on Plan-Do-Check-Act principles of ISO 45001 Standard

Monitoring: Monthly communication on factory floor about department-level performance, quarterly via toolbox medium, external communication to authorities per legal obligations. Workers representation councils for safety and prevention in all production plants.

Training and Development

Scope: All employees

Key content: Training and upgrading capabilities, skills and competencies based on strategic objectives, employee performance and career development needs. Learning comes in many shapes including on-the-job, online courses and in-person training.

Note: No group policy in place, but many locations have local policies. Online learning platform Udemy introduced in 2023.

Work-Life Balance

Scope: All employees

Key content: Recognition of importance of maintaining connection between production environment and all employees, valuing social cohesion and in-person collaboration.

Note: No group policy in place, but many locations have local policies.

Social Dialogue

Scope: All employees

Key content: Workforce or their representatives have the right to be informed and consulted in timely manner on relevant matters, in line with national legislation and practices. Social partners regularly informed on design and implementation of economic, employment, and social policies. Encouraged to negotiate and conclude collective agreements.

Public availability: Part of Human Rights Policy

Monitoring: Workers representation councils for safety and prevention at work in all production plants.

Taking action on material impacts on own workforce

The effectiveness of actions is tracked performance-driven, through continuous assessment of metrics and through feedback/engagement mechanisms. Yearly Together Ahead Dialogues with employees aim to look back at the past year and look forward to the new year, providing information to connect to the workforce and keep track of retention.

Employment

Action: Global recruitment strategies and employer branding

• Description: Developed global recruitment strategies to attract and retain top talent in a competitive landscape. Uses different channels including internal promotions. Employer branding highlighted by sponsoring the Alpecin-Deceuninck cycling team.
• Scope: Own operations
• Time horizon: Implemented in 2024, ongoing
• Resources: Partnership with Alpecin-Deceuninck cycling team (non-financial)
• Outcomes: Cycling teams embody hard work, high performance, determination and passion, serving as inspirational content for internal communications

Adequate wages

Action: Worldwide Compensation & Benefits ('Comp & Ben') exercise

• Description: Review of salary structures to ensure market competitiveness through labor market surveys and benchmarking exercises. Training completed in 2024 for alignment, standardization of job descriptions and grading.
• Scope: Own operations (worldwide)
• Time horizon: Started in 2024, aiming for completion by mid-2026
• Resources: External party partnership (non-financial)
• Expected outcomes: Establish reliable and structured salary framework for all employees worldwide. Bonus structure to be reviewed and updated to ensure fair and performance-driven reward system. Higher performance directly linked to greater rewards.

Social dialogue

Action: Expansion of social dialogue to all countries

• Description: Expanded social dialogue with employees to all countries where Deceuninck is present, including locations without workforce representation through Unions. Assures dialogue and open communication.
• Scope: Own operations (all countries)
• Time horizon: Implemented in 2024, to be continued and strengthened in 2025
• Measurement: Annual satisfaction surveys with satisfaction scores and reflection of opinions and suggestions
• Expected outcomes: Build stronger relationships more effectively through open communication and collaboration

Work-life balance

Action: Wellbeing program

• Description: Efforts to encourage healthy lifestyle and balanced work-life dynamic. Monthly wellbeing themes in European sites ('on the move', caring, healthy food). Free soup introduced at Belgian facilities. Support through solidarity actions or assistance when employees or close family face exceptional health or economic difficulties.
• Scope: Own operations (European sites and Belgian facilities)
• Time horizon: Implemented in 2024, to be strengthened in 2025
• Expected outcomes: Enrich social environment and improve well-being of employees

Training and skills development

Action: Udemy online learning platform

• Description: Online learning and training platform offering wide range of courses (communication, sustainability, IT, finance, people management, language, personal development at different levels). Introduced in 2023 and further implemented in 2024.
• Scope: Own operations (Group-wide)
• Time horizon: 2023-2024 implementation, 2025 expansion planned
• Resources: Udemy platform partnership (non-financial)
• Expected outcomes: Access to be further expanded within the Group in 2025 to increase use and related training hours
• Link to impact: Supports qualitative training programmes that enhance employee capabilities and drive better business performance, fostering culture of continuous improvement and excellence

Diversity and inclusion

Action: Language lessons and integration support

• Description: Language lessons for foreign language speakers given in several plants to accelerate integration into company and society. Language lessons for managers to facilitate communication with new staff members.
• Scope: Own operations (several plants)
• Time horizon: Ongoing
• Expected outcomes: Accelerate employee integration and improve communication

Action: Diversity and inclusion commitment

• Description: Commitment to becoming diverse and inclusive organization. Prioritize diversity and inclusion across all entities. Put diversity on agenda and ensure diversity throughout recruitment and promotion process.
• Scope: Own operations (all entities)
• Time horizon: Ongoing

Health and safety

Action: Behavior Based Observation Tours program

• Description: New program launched to install Behavior Based Observation Tours in sites that did not have this formally in place. Tours encourage proactive approach to identify and correct unsafe behaviors before incidents occur, fostering culture of continuous safety improvement. Actively involves employees in safety practices.
• Scope: Own operations (sites without existing program)
• Time horizon: Launched in 2024, to be continued in 2025
• Expected outcomes: Encourage personal responsibility for safety, continuous safety improvement

Action: Safety training program

• Description: Training organized on safety priorities and good practices covering use of personal protection equipment, handling and storage of chemicals, safe working practices, emergency procedures, and regulatory updates.
• Scope: Own operations
• Time horizon: Ongoing

Action: Global annual Safety Day

• Description: Organized since 2023 to relay message that safety is everyone's responsibility. Priority topics in 2024 were emergency preparedness and response (first aid, fire safety, evacuation).
• Scope: Own operations (global)
• Time horizon: Annual since 2023, continued in 2024 and planned for 2025
• Expected outcomes: Embed safety culture, anchor safe behavior in mindset of all people, foster mentality where all people take responsibility for collective safety

Action: Site-specific safety targets

• Description: Each production site has set specific annual targets on frequency and severity rate, developed in close consultation with EHS responsibles and employee representatives.
• Scope: Own operations (all production sites)
• Time horizon: Annual targets
• Expected outcomes: Year-over-year improvement in frequency and severity rates
• Link to policy/target: Links to overall health and safety ambitions and metrics (S1-14)

Anti-discrimination / Human rights

Action: Mandatory Code of Conduct training

• Description: All white-collar new joiners follow mandatory training course on Code of Conduct outlining principles for prevention and remediation of adverse impacts. Employees expected to apply knowledge in daily tasks and responsibilities.
• Scope: Own operations (all white-collar new joiners)
• Time horizon: Ongoing
• Expected outcomes: Incidents reported are addressed adequately

Targets related to own workforce

Health and Safety

A Group target has been developed in the context of a Sustainability Linked Loan in 2022, based on the performance in 2021 a year-over-year performance improvement is envisaged.

Scope: Group-wide target

Other Topics

The Group does not have Group-wide targets in place related to the following topics:

• Employment
• Adequate wages
• Social dialogue
• Work-life balance
• Training and skills development
• Diversity & Inclusion
• Anti-discrimination / Human rights

The Group aims to continually evolve by implementing the above-described actions. The effectiveness of the policies and actions is tracked performance-driven, through assessment of the metrics and through the engagement mechanisms described above. There are no immediate plans to define quantitative targets.

Characteristics of the undertaking's employees

Total headcount and FTE

Key Figures 2024

** 2022 and 2023 restated to align with the CSRD definition

Note on restatement (from BP-2): Due to change in methodology in line with CSRD definitions, the number of employees (FTE) in the annual report 2023 has been restated. Some subcategories of what is considered non-employees under CSRD, were previously included in the calculation. This has been corrected and excluded.

Headcount by gender (S1-6)

Headcount by employment contract type and gender

Headcount by employment contract type and region

Headcount breakdown per country (countries > 50 employees)

Employee turnover

Methodology note: The number of employees (headcount) as per the breakdowns disclosed is the number of employees on 31 December in the reporting year. The employee contract type, gender classification and region specifications are based on registrations in the Group's HR systems. The number of employees who left the company is the number of employees who left the organisation voluntarily or due to dismissal, retirement or death while employed during the year, based on registrations in the Group's HR systems. The total employee turnover is calculated based on the average number of employees and the number of employees who left the company during the year.

Additional diversity metrics (S1-9)

Gender distribution at top management

The top management is defined as the senior leadership, two levels below the Board of Directors.

Age distribution of the workforce

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

Definition and Scope

Own workforce comprises people in an employment relationship with Deceuninck ('employees'). Non-employees are people with contracts with the undertaking to supply labour ('self-employed people') or people provided by undertakings primarily engaged in employment activities ('agency workers'). In addition, health and safety policies are also valid for contractors working on-site.

The safety policies and instructions that apply to employees also apply to non-employees (contractors, temporary workers) and visitors.

Metrics

No quantitative metrics for non-employee workers are disclosed in the excerpts provided. The company defines the categories of non-employees (self-employed people, agency workers, contractors) but does not provide headcount, FTE, or breakdown data for these worker types.

Collective bargaining coverage and social dialogue

Coverage of employees by collective bargaining agreements

The Group is active in 4 countries where collective bargaining agreements are in place. In these cases, all of the employees are covered. Outside of the EEA, none of the employees are covered by collective bargaining agreements. In total, 26% of the Group's employees are covered by collective bargaining agreements.

Coverage of employees by workers' representation

The Group is active in 4 countries where workers' representation by a work council is in place. In these cases, all of the employees are covered. Outside of the EEA, none of the employees are covered by workers' representation. In total, 33% of the Group's employees are covered by workers' representation.

European Works Council

No representation by a European Works Council (EWC), a Societas Europaea (SE) Works Council, or a Societas Cooperativa Europaea (SCE) Works Council.

Policy framework

The following objective is part of the Human Rights Policy and covers all employees of the Group:

• Deceuninck respects its employees' right to join, form or not to join a labor union, seek representation, bargain or not bargain collectively in accordance with local laws and without fear of reprisal, intimidation or harassment. Where employees are represented by legally recognized unions, we aim to have constructive dialogues with their chosen representatives and bargain in good faith with such representatives.

Deceuninck believes that the workforce or their representatives have the right to be informed and consulted in a timely manner on relevant matters, in line with national legislation and practices. Social partners are on a regular basis informed on the design and implementation of economic, employment, and social policies according to national practices. They are encouraged to negotiate and conclude collective agreements.

Actions and engagement

In 2024, we expanded social dialogue with employees to all countries where Deceuninck is present, also the locations without workforce representation through Unions. The Group assures dialogue and open communication. This is measured through annual satisfaction surveys, with satisfaction scores and reflection of opinions and suggestions. These dialogues allow the workforce to propose new ideas and suggestions for improvements.

The purpose is to continue and strengthen these dialogues in 2025. By encouraging open communication and collaboration through the outcome of the surveys and performance reviews, the Group aims to build stronger relationships more effectively.

Diversity metrics

Gender distribution at top management

Definition: The top management is defined as the senior leadership, two levels below the Board of Directors.

Age distribution of the workforce

Note: The number of employees (headcount) as per the breakdowns disclosed is the number of employees on 31 December in the reporting year. The gender classification is based on registrations in the Group's HR systems.

Adequate wages

S1-10 Disclosure

Benchmark Used:

Deceuninck states: "All of the employees of the Group are paid an adequate wage, in line with applicable benchmarks provided by international or national legislation."

The Human Rights policy outlines:

• Deceuninck Group compensates employees competitively relative to its industry and the local labor market.
• Deceuninck Group follows applicable wage, work hours, overtime and benefits laws in the countries where it operates, or, in the absence of such laws, with international labor standards.

Coverage:

All employees of the Group (100%) are stated to be paid an adequate wage.

Methodology:

The Group is implementing a 'Comp & Ben' (Compensation & Benefits) initiative, aiming to establish a reliable and structured salary framework for all employees worldwide by mid-2026. The company uses labor market surveys and benchmarking exercises to determine the competitiveness of salary structures with market offerings. Training for the first step (alignment, standardization of job descriptions and grading) was completed in 2024.

Targets:

By mid-2026: Establish a reliable and structured salary framework for all employees worldwide through the 'Comp & Ben' initiative. The bonus structure will be reviewed and updated to ensure a fair and performance-driven reward system.

Gender Pay Gap Metric:

The gender pay gap is -4.0% (2024), meaning the average remuneration of female employees is 4% higher than that of male employees.

Annual Total Remuneration Ratio:

38.3 (2024) - the ratio between the highest paid employee and the median total remuneration of all other employees.

Note on Benchmark:

The disclosure refers to "applicable benchmarks provided by international or national legislation" and "international labor standards" but does not explicitly reference a living wage methodology or external living wage benchmark (such as Fair Wage Network, Anker Methodology, etc.). The focus appears to be on legal compliance, market competitiveness, and internal compensation structures rather than a specific living wage assessment tool.

Training and skills development metrics

Total investment in training

€592,000 was spent on OpEx for training in 2024.

Training hours

The company introduced the online learning and training platform Udemy in 2023, which was further implemented and enrolled across the Group in 2024. The platform offers a wide range of online training courses, ranging from communication, sustainability, IT, finance, people management, language to personal development at different levels.

In 2025 the access to the Udemy platform will be further expanded within the Group to increase its use and the related training hours.

Specific training activities included:

• Safety training and awareness programs
• Training on safety priorities and good practices, covering use of personal protection equipment, handling and storage of chemicals, safe working practices and emergency procedures
• Language lessons for foreign language speakers in several plants
• Language lessons for managers to facilitate communication
• Mandatory training course on the Code of Conduct for all white-collar new joiners
• Planned Refresher Compliance Course for all white-collar employees in 2025

Note: Average training hours per employee (overall, by gender, or by employee category) are not disclosed. Breakdown of training hours by gender or employee category is not provided.

Performance and career development reviews

The company conducts annual performance reviews ("Together Ahead Dialogues") with employees to look back at the past year and look forward to the new year.

Note: The percentage of employees who received a performance and career development review (overall or by gender) is not disclosed in quantitative terms.

Health and safety metrics

Coverage by health and safety management system

100% of the workforce is covered by the undertaking's health and safety management system based on legal requirements and/or recognized standards or guidelines.

Health & Safety metrics

*Calculated based on 1,000,000 hours worked

Scope and methodology

The safety metrics are limited to the Group entities and production facilities in the following countries (in alphabetic order): Belgium, Colombia, Chile, Croatia, France, Germany, Poland, Russia, Spain, Türkiye, United Kingdom, United States. As a result of the DMA, locations with purely warehouses and/or sales offices are not material and therefore excluded.

The data is collected monthly by the local EHS responsibles. It is also shared with the regional and Group management teams, in addition to an in-depth analysis by the community of EHS managers.

In 2024, a deterioration in performance of the rate of recordable accidents on Group level is noticeable. Due to the start of a new activity in one plant of the Group, more accidents occurred in that site.

Phase-in datapoint

Number of days lost to injuries, accidents, fatalities or illness (ESRS S1-14 paragraph 88 (e)) is listed as a phase-in datapoint and not disclosed for the current reporting period.

Work-life balance metrics

Entitlement to family-related leave

All of the Group's employees (100%) are entitled to take family-related leave, in accordance with international or national legal frameworks in place.

Employees who took family-related leave

No data disclosed for the percentage of entitled employees who took family-related leave, with breakdown by gender.

Return-to-work rate after parental leave

No data disclosed for return-to-work rates after parental leave, with breakdown by gender.

Policy context

There is no group policy on work-life balance in place, but many locations have a local policy. Deceuninck recognizes the importance of maintaining a strong connection between the production environment and all employees. As a production company, the Group values the social cohesion between the various employees and collaboration that arise from working together in person.

Material impacts identified

Performing a job naturally has an impact on people's well-being and on the available free time they have, the latter being essential for decompressing from a sometimes demanding work environment. As an employer, support is given to employees to accommodate a good work-life balance, such as family-friendly practices or flexible working arrangements. This is identified as a positive, actual, short-term impact.

Risks identified

• Failing to provide flexible working solutions can result in imbalanced work-life balances of people. This is especially relevant for white-collar employees because their jobs typically involve tasks that can be performed remotely. This may result in less satisfied employees, lower workplace performance and less retention of employees. Work-life balance holds particular significance for the younger generation in the workforce.
• Work-life imbalance and stress are related to mental and physical health risks for all employees. It increases sickness and absenteeism.

Compensation metrics

Pay gap

The gender pay gap for 2024 is -4.0%.

The gender pay gap is calculated as the difference of average annual total remuneration of male versus female employees, expressed as a percentage of the average annual total remuneration of male employees. As a result, the average remuneration of female employees is 4% higher than that of male employees.

Remuneration ratio

The annual total remuneration ratio for 2024 is 38.3.

The annual total remuneration ratio is calculated by comparing the annual total remuneration of the highest paid employee in the Group with the annual median total remuneration of the rest of the own employees.

Methodology

The calculations are based on headcount and the annual total remuneration at 31 December in the reporting year.

This appears to be the first year of disclosure for both metrics, as 2023 values are reported as "N/A".

Incidents, complaints and severe human rights impacts

Registered incidents and complaints

Context

The complaints and incidents are filed by the own workforce and are related to behavior not in line with the principles outlined in the Code of Conduct of the Group. They do not qualify as severe human rights impacts.

The complaints have been filed through the channels available for employees to raise concerns. Incidents are defined as complaints that have resulted in specific actions following an investigation.

Value chain workers

No (severe) human rights issues and incidents connected to the upstream and downstream value chain have been reported.

Business conduct policies and corporate culture

Corporate culture framework

Deceuninck's corporate culture is built on three core values: Trust, Top Performance and Empowerment. These values are enshrined in the Code of Conduct, which serves as a guiding document for all employees.

The Group evaluates its corporate culture on a continuous basis through employee feedback channels including surveys, focus groups, exit interviews, and evaluation cycles. The CHRO consolidates findings, which are reviewed by the Executive Management.

Governance:

• The Executive Management is responsible for monitoring how effectively policies are followed and provides reporting to the Board of Directors

Training and communication:

• New white-collar hires complete mandatory Code of Conduct E-learning
• Policies communicated via HR departments and available on Sharepoint and the Group website
• Refresher Compliance Course planned for 2025

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Code of Conduct

The Code of Conduct covers ethical behavior principles including human rights, anti-bribery, anti-corruption, anti-discrimination, and business conduct standards.

Scope: All employees of the Group and extends to business partners

Key content:

• Trust, Top Performance and Empowerment as guiding principles
• Prohibition of discrimination, harassment and violence in the workplace
• Respect for cultural differences and commitment to diversity
• Fair dealing with customers, suppliers and competitors
• Anti-corruption and anti-bribery provisions

Governance:

• Executive Management responsible for monitoring effectiveness
• Compliance Officer (currently the General Counsel, member of Executive Management) oversees implementation
• Reports to Board of Directors

Public availability: Available on the Group intranet and website

Links to international standards: Inspired by:

• United Nations Convention against Corruption
• UN Guiding Principles on Business and Human Rights
• ILO Declarations on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Monitoring:

• Internal audits conducted regularly
• Audit Committee oversees audit process
• Whistleblower platform allows anonymous reporting
• Investigation and disciplinary process for violations

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Human Rights Policy

The Human Rights Policy is encompassed within the Code of Conduct and applies to the whole of Deceuninck Group.

Scope: All employees (including independent contractors, temporary workers) and extends to business partners

Key content:

• Promotion of human rights
• Prohibition of forced labor and human trafficking
• Prohibition of employment of underaged workers
• Competitive compensation relative to industry and local labor market
• Compliance with applicable wage, work hours, overtime and benefits laws
• Right to join, form or not join a labor union
• Right to collective bargaining without fear of reprisal
• Prohibition of discrimination based on age, race, color, religion, gender, disability, national/social origin, sexual orientation, political opinion
• Zero tolerance for harassment and violence
• Respect for cultural differences and commitment to diversity

Governance:

• Executive Management responsible for monitoring effectiveness
• Reports to Board of Directors

Public availability: Available via HR departments, Sharepoint and Group website

Links to international standards:

• ILO Declarations on Fundamental Principles and Rights at Work
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises

Monitoring:

• Active management engagement
• Employees empowered to report issues
• Zero-tolerance culture enforced through investigation and disciplinary process
• Human rights due diligence and mitigation processes

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Group EHS Policy

The Group Environment, Health and Safety (EHS) policy underscores the Group's commitment to safety.

Scope: All employees; safety policies that apply to employees also apply to non-employees (contractors, temporary workers) and visitors

Key content:

• '10 Golden Rules' - behavior-based safety principles introduced in 2023
• Handling and storage of dangerous substances
• Safety Data Sheets requirements
• Emergency preparedness and response
• Monitoring and reporting of incidents and near misses
• Regular inspections of technical equipment
• Training requirements
• Personal protective equipment
• Preventive alcohol and drug policy

Management system coverage:

• 100% of workers covered by management system based on legal requirements or recognized standard
• Deceuninck Türkiye applies ISO 45001 Occupational Health and Safety management system
• US plants apply Federal & State Occupational Safety & Health Administration Standards
• Deceuninck Europe applies Plan-Do-Check-Act principles based on ISO 45001

Governance:

• Local EHS managers oversee implementation and updates
• EHS managers report to regional management
• Safety performance reviewed monthly by safety managers and regional management

Monitoring:

• Monthly review of safety performance
• Internal and external communication of incidents
• Risk assessments after incidents, near-misses and changes
• Workers representation councils for safety and prevention in all production plants
• Group target: 13.8 rate of recordable work-related accidents for 2025 (part of Sustainability Linked Loan)

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Supplier Code of Conduct

The Supplier Code of Conduct outlines minimum expectations for supplier standards.

Scope: All suppliers and subcontractors; covers all value chain workers

Key content:

• Health and safety standards
• Labour practices and human rights
• Prohibition of child labor
• Prohibition of trafficking in human beings, forced labor or compulsory labor
• Environmental protection
• Ethics and fair business practices
• Freedom of association and collective bargaining
• Expectation to establish environmental management system

Governance:

• Regional purchase and EHS departments monitor compliance jointly
• Overseen by Group Sustainability Manager
• Responsibility with Regional Managing Directors (part of Executive Management)

Public availability: Available on Group intranet and website; last updated 2023

Links to international standards:

• UN Guiding Principles on Business and Human Rights
• ILO Declarations on Fundamental Principles and Rights at Work

Monitoring:

• All direct materials and indirect suppliers obliged to sign
• No new supplier can be created without signed Code of Conduct
• Compliance monitored with focus on large suppliers
• Enhanced monitoring, suspension or termination possible for non-compliance
• 86% of spend covered by signed Supplier Code of Conduct in 2024

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Whistleblower Policy

The Whistleblower Policy establishes internal reporting channels for concerns about breaches of the Code of Conduct, internal policies, laws and regulations.

Scope: All global operations; available to employees and external parties

Key content:

• Confidential reporting outside direct management lines
• Anonymous reporting option via online platform and email
• Protection from retaliation for good faith reports
• Investigation procedures

Governance:

• Compliance Officer (General Counsel) responsible for investigations
• Internal Audit department conducts independent investigations
• Reports to Audit Committee
• Group General Counsel holds responsibility in cooperation with Group CHRO

Public availability: Information provided to employees; online reporting platform available

Links to international standards:

• Complies with Directive (EU) 2019/1937 on whistleblower protection

Monitoring:

• Compliance Officer and Internal Audit investigate reports
• Outcomes reported to Audit Committee
• Tracking of reported incidents (1 confirmed incident of corruption/bribery in 2024)

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Privacy and Data Protection Policy

The Privacy and Data Protection Policy outlines commitment to protecting personal data.

Scope: End-users and consumers

Key content:

• Commitment to protecting personal data
• Compliance with data protection regulations including GDPR
• Process for data subjects to lodge complaints
• Contact information for Data Protection Officer

Governance:

• Monitored by Legal department
• Data Protection Officer designated
• General Counsel (Executive Management member) holds joint responsibility for implementation
• Global IT Infrastructure Manager holds operational responsibility
• CIO (part of Extended Executive Team) oversees IT Infrastructure Manager
• CFO (Executive Management) oversees CIO
• Internal Auditor audits and reports to Audit Committee

Public availability: Available on Group intranet and public websites

Monitoring:

• Zero data breaches and zero legal proceedings on data breaches in 2024
• Periodic disaster recovery testing
• Third-party and internal cybersecurity assessments
• Annual penetration tests
• NIS2 registration completed in 2024

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Data Breach Incident Response Plan

Internal procedure detailing steps in event of a data breach.

Scope: All categories of data subjects

Governance:

• Monitored by Legal department
• General Counsel (Executive Management) holds joint responsibility

Public availability: Internal procedure

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Local policies

The Group notes that many locations have local policies on:

• Work-life balance (no group-wide policy)
• Training and development (no group-wide policy)

These are not detailed in the disclosure.

Prevention and detection of corruption and bribery

Code of Conduct

The Group's policy on anti-corruption and anti-bribery are set out in the Code of Conduct.

Scope:

• All employees
• Available on the intranet and the website of the Group

Governance:

• The Compliance Officer (currently the General Counsel, who is member of the Executive Management) holds responsibility for the implementation of the Code of Conduct
• The Internal Auditor reports directly to the Audit Committee
• Investigations are carried out by the Compliance Officer and the Internal Audit department
• Outcomes of investigations are reported to the Audit Committee

Key content and principles:

• Inspired by the United Nations Convention against Corruption
• Covers all forms of bribery and corruption, including:
  • The offering, giving, receiving, or soliciting of any advantage—whether financial or otherwise—designed to influence the actions of an individual or entity inappropriately
  • Facilitation payments made to expedite routine transactions
  • Gifts, hospitality, or entertainment intended to improperly influence decisions or gain unfair business advantages
• Built on foundation of Trust, Top Performance and Empowerment
• Provides ethical framework based on four elements: Core Values, Guiding Principles, People, and Long-lasting Relationships

Link to international standards:

• Inspired by the United Nations Convention against Corruption

Implementation and monitoring:

• New white-collar hires are invited to complete the Code of Conduct E-learning (estimated duration 35 minutes)
• All white-collar new joiners are required to complete the training
• Refresher Compliance Course to be offered as of 2025
• In the past 5 years, 45% of employees in purchase departments have followed the Code of Conduct E-learning
• Regular internal audits are conducted to ensure compliance
• Dedicated whistleblower platform allows employees to report concerns anonymously
• Internal reporting channels include e-mail and an online reporting platform
• Procedures in place to investigate business conduct incidents promptly, independently and objectively
• Investigators are separate from the chain of management involved in prevention and detection
• The Group evaluates its corporate culture on a continuous basis through employee feedback channels: surveys, focus groups, exit interviews, evaluation
• Tracks effectiveness of policies and programs on a continuous basis

Whistleblower Policy

Key content and principles:

• Establishes internal reporting channels (e-mail and online reporting platform)
• Protects whistleblowers from retaliation
• Includes measures to safeguard employees who report concerns in good faith

Link to international standards:

• Complies with Directive (EU) 2019/1937

Incidents of corruption or bribery

Confirmed incidents

In 2024, Deceuninck reported 1 confirmed incident of corruption or bribery. This represents an increase from zero confirmed incidents in 2023.

Convictions and fines

Disciplinary actions

1 employee was dismissed or disciplined for corruption or bribery-related incidents in 2024 (2023: 0).

Contracts terminated

No contracts with business partners were terminated or not renewed due to violations related to corruption or bribery in 2024 (2023: 0).

Investigation and speak-up mechanisms

The company has established several mechanisms to identify, report and investigate concerns about unlawful behavior:

• Whistleblower platform: A dedicated anonymous reporting platform available to employees
• Internal audit: Regular audits conducted to ensure compliance with policies
• Compliance officer: The General Counsel (member of Executive Management) oversees implementation of compliance programs and investigates reported concerns
• Audit Committee: Oversees the audit process and ensures concerns are addressed promptly

Investigations are carried out by the Compliance Officer and Internal Audit department to ensure confidentiality, thoroughness and impartiality. Investigators are separate from the chain of management involved in prevention and detection. Outcomes are reported to the Audit Committee.

The company notes that the rise in incidents reported in 2024 "reflects the success of our awareness initiatives and underscores the critical role of internal reporting procedures. By encouraging and facilitating whistleblower reports, we ensure that issues are promptly addressed, fostering a culture of integrity and trust within our organization."

No specific actions to address breaches in procedures and standards of anti-corruption and anti-bribery were taken in 2024, apart from ongoing training and awareness programs.

Payment practices

Standard contractual payment terms

The Group typically grants payment terms between 15-120 days but offers under certain conditions discounts for prompt payment. The payment terms differ substantially between the regions in which the Group operates.

Average payment time

Trade debts do not bear interest and are usually paid on the basis of payment terms that can vary depending on the market. On average, these payment terms fluctuate between 45 and 65 days from the end of the month in which the debt is incurred. In Türkiye this can be up to one year after the invoice date.

Cash discounts

The Group recognizes the cash discounts given to customers as a deduction on revenue. Similarly, the cash discounts received from the suppliers are deducted from the costs.