Deceuninck

Governance roles

Reference: page 100.

The Board of Directors and the Executive Management "ensure that appropriate skills and expertise are available or will be developed to oversee sustainability matters." Composition and diversity of the Board (executive/non-executive split, gender balance) are cross-referenced to the Board and Committees section of the Annual Report; the report notes there is "no representation of employees and other workers at Board level," with employee input instead channelled through social dialogue and employee-representation policies.

One Board member "has followed external training to develop specific sustainability-related expertise," and all members can draw on sustainability expertise through their professional mandates. The Board and Executive Management were also briefed on sustainability legislation by the Group Sustainability Manager and General Counsel, and the report states that "training programs will be implemented to ensure members stay updated on emerging trends, regulatory requirements and best practices in sustainability oversight."

Information to governance bodies

Reference: pages 100-101.

The Board oversees sustainability-related impacts, risks and opportunities; within Executive Management "the Group CFO is responsible for management of sustainability-related impacts, risks and opportunities." The Group Sustainability Manager reports to the CFO and coordinates integration of sustainability across the business, supported by regional EHS managers and functional leads in procurement, R&D, product management and finance.

The Board and Executive Management were involved in the 2024 Double Materiality Analysis; the DMA "was not updated in 2025, hence there was no specific involvement in 2025," except for a separate DMA run for the newly acquired Aluminium business, with Executive Management involvement. Progress on targets is reported quarterly or annually depending on topic, and sustainability-related risks sit within the Audit Committee's broader risk-management oversight.

Remuneration link

Reference: pages 102, 118-119.

For 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," aligned with the targets agreed in the Group's Sustainability Linked Loan (SLL). The Remuneration and Nomination Committee approves the terms of the incentive schemes.

In the E1 chapter this is quantified further: 3.3% of Executive Management's variable remuneration is tied to achieving the Group's Scope 1 and 2 target specifically, and "Members of the Management Team Group receive 2.3% of the collective bonus depending on the achievement of the same carbon emission target." The scheme therefore links pay to climate, safety and recycling performance at both Executive Management and broader management-team level.

Due diligence mapping

Reference: pages 101-103.

The report maps the core elements of due diligence to specific sections: (a) embedding in governance, strategy and business model is placed under "ESRS 2 Governance, SBM Governance G1.1 (Policies)"; (b) engaging with affected stakeholders under "ESRS 2 SBM-2 Interests and views of stakeholders"; (c) identifying and assessing adverse impacts under "ESRS 2 SBM-3 ... disclosed under the Topic-Specific Disclosure Requirements," noting "all stakeholders mentioned are affected stakeholders."

Data governance underpinning the process is also described: regional Finance departments run internal controls over data collection, a Group-developed digital tool consolidates monthly site-level data, and quarterly reporting cycles allow regular status checks. Main inherent risks identified are data accuracy, completeness, inconsistency, availability and confidentiality (page 103).

Risk management and internal controls

Reference: page 103.

"The Audit Committee, the Board of Directors and the Executive Management regularly assess material risks and internal controls associated with the company's integrated reporting process." The report identifies the main inherent risks to sustainability reporting as data accuracy (manual entry, limited internal controls), data completeness (missing or unavailable data), data inconsistency (differing frameworks and definitions across the Group), data availability (obtaining reliable ESG data from suppliers) and data confidentiality (misuse of sensitive data).

Controls are built around a Group-developed digital data-management tool, monthly site-level submissions, and regional Finance-department oversight of collection, described under GOV-4 (page 102). No separate description of a formal internal-audit sign-off specific to sustainability metrics is given beyond this.

Strategy and value chain

Reference: pages 104-107.

Sustainability strategy is anchored in the Group purpose "Building a Sustainable Home," structured around two commitments: innovative, recyclable, high-insulation products, and sustainable, safe production. Four macro trends shape strategy: demography/urbanisation (renovation demand), climate change (stricter carbon regulation, EPD expectations), talent attraction/retention, and a challenging economic environment ("a significant slowdown in the construction sector," easing but still-pressuring inflation).

The value chain is mapped from raw-material sourcing (ethylene, chloride, energy) through compounding, extrusion, product design, transportation, fabrication by customers, installation and use-phase, to recycling of end-of-life PVC back into new products - "in green: position of Deceuninck Group in the value chain" spans production, product design, transportation and recycling. PVC is described as "57% salt (chloride) and 43% ethylene," and the Group notes its activities fall under NACE Division 22.21 with no chemical production.

Stakeholder engagement

Reference: page 108.

"All stakeholder expectations mentioned above were considered in the materiality assessment process," integrated into the impact, risk and opportunity descriptions under IRO-1. The report states that "no amendments to the strategy and/or business model to address the interests and views of its stakeholders were made based on the DMA," concluding the Group was "already focusing on the right topics."

Key stakeholder groups identified elsewhere in the DMA process (IRO-1, page 112) include employees, clients, suppliers, investors and the Group's European industry association; a total of 84 unique stakeholders took part in scoring impact and financial materiality. The Board and Executive Management were briefed on stakeholder views during discussions of materiality levels as part of the DMA.

Material IROs and stakeholder table

Reference: pages 109-113.

A stakeholder-engagement table sets out engagement channels, actions and expectations for employees (fair wages, safety, career development), customers (quality, service, data security, circular solutions) and other groups. The Double Materiality Analysis scored topics on impact and financial materiality with thresholds of "7.5-10 High material, 7.4-6.9 Medium material, <6.9 Low material," using a longlist of 33 ESRS subtopics supplemented by SASB standards and sector references.

Material topics span climate change (upstream, own-operations and downstream carbon emissions), circular economy (raw materials and recycling, packaging), water consumption, use of substances of very high concern, several own-workforce subtopics, working conditions in the value chain, and business conduct (corporate culture, anti-corruption). A separate DMA was run in 2025 for the newly acquired Decalu (aluminium) business, cross-checked against the Group-wide DMA and found not to change the conclusions.

IRO identification process

Reference: pages 112-114.

The Group built a longlist of 33 ESRS subtopics, supplemented with SASB Chemicals/Building Products/Waste Management standards, GRI, sector references (Essenscia, PlasticsEurope 2050 Roadmap, VinylPlus Product Label) and its Enterprise Risk Assessment. Internal and external stakeholders scored topics via an online questionnaire, supplemented by in-depth interviews with key suppliers and clients; "a total of 84 unique stakeholders were involved in the assessment of both impact and financial materiality," each topic scored on a 0-10 scale for impact and financial materiality independently, with a 6.9 threshold for materiality.

A specific 2025 DMA covered the newly acquired Decalu aluminium business for environmental topics; social and governance were not re-scored "because the outcome does not depend on the type of raw material." The Group states "there are no specific activities, business relationships, geographies or other factors that give rise to heightened risk of adverse impacts."

ESRS content index

Reference: page 114; full index pages 180-187.

The statement provides an ESRS content index cross-referencing each Disclosure Requirement to its report page and, where applicable, to datapoints required by other EU legislation (SFDR, Benchmark Regulation, Pillar 3, Climate Law). The index covers ESRS 2 (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1/IRO-2) and the topical standards E1, E2, E3, E5, S1, S2 and G1.

A separate list on pages 186-187 identifies specific datapoints, mostly deriving from other EU legislation, that the Group has assessed as "deemed not material" (e.g. E1-7 GHG removals and carbon credits, several E1-9 physical-risk-exposure datapoints, E2-4 pollutant amounts, E3-1/E3-4 sub-items, E4-2 land/ocean/deforestation items, E5-5 non-recycled and hazardous waste), plus a distinct set of "Phase-in datapoint" items under S1-13 to S1-17.

Transition plan

Reference: pages 118-121.

Since September 2023 the Group has validated SBTi near-term targets covering Scope 1, 2 and 3 emissions to 2030 and a long-term net-zero target for 2050, both from a 2021 base year: "Deceuninck commits to reduce absolute Scope 1 & 2 emissions 60% by 2030" and "Scope 3 emissions 52% per ton PVC produced by 2030." Four decarbonisation levers are named: renewable electricity, energy/operational efficiency, sourcing less carbon-intensive raw materials, and increased use of recycled PVC.

The plan "has been approved by the Executive Management and Board of Directors ... as part of the SBTi commitment and approval process." Investments are "demonstrated through the annual EU Taxonomy disclosures" rather than quantified as a dedicated transition-plan budget. Locked-in Scope 1/2 emissions of 120,000 tCO2e and Scope 3 emissions of 1,125,000 tCO2e (2021-2030, business-as-usual) are disclosed. The Group states it is "not excluded from the EU Paris-aligned Benchmarks," and is on track for its Scope 1/2 target while Scope 3 progress is "slower, as expected."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate-DMA section, where this content is disclosed in the FY2025 report (pages 122-123). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Transition risks and opportunities were screened through the DMA across categories of policy/legal (current and emerging regulation, non-compliance/litigation), technology, market (customer demand for lower-carbon products, raw-material and transition costs) and reputation. The report states "the Group has not identified assets and business activities that are incompatible with or need significant efforts to be compatible with a transition to a climate-neutral economy."

For physical risk, the analysis is explicitly qualitative and preliminary: "No scenario analysis has been applied yet. The long-term risks of climate change using (high emissions) scenario analysis (with time horizons of 10-years and more) have not been assessed yet." Floods, heat stress and drought were considered at a high level, and physical risk "did not reach the threshold to be defined as material" on either impact or financial materiality.

Coverage note: the report names no specific climate scenario (e.g. SSP or IEA pathway); scenario analysis as required by ESRS is not yet performed.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 / the E1 resilience-strategy section, where this content is disclosed in the FY2025 report (pages 120-123). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

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." All identified climate-related risks in this analysis are treated as transition risks, assessed against the four decarbonisation levers (renewable electricity, energy/operational efficiency, lower-carbon raw materials, recycled-material use).

Supporting resilience factors cited include the recycling-based business model reducing raw-material dependency, SBTi-aligned decarbonisation targets, and financing access through a Sustainability Linked Loan running to 2027, with "no indications refinancing would not be possible." The Group states it will "expand the current risk analysis and potentially update conclusions of the DMA and resilience analysis" once more specific tools become available.

Climate policies

Reference: pages 124-125.

Climate mitigation objectives sit within the Group Health, Safety and Environment (HSE) policy, which "mentions the SBTi targets and formalized the commitment to reduce GHG emissions in own operations (Scope 1,2) through renewable energy and energy efficiency," and includes an upstream/downstream commitment to recycling and use of recycled materials (Scope 3), plus a general emphasis on environmental compliance. The CFO holds management oversight of the roll-out, coordinated by the Group Sustainability Manager.

Supplier-facing elements are embedded in procurement policy: key suppliers "are rated on their sustainability/carbon strategy and the product carbon footprint data," and the mandatory Supplier Code of Conduct requires environmental management systems (ISO 9001/14001) and participation in initiatives such as the VinylPlus Product Label and ECVM Industry Charter. The report notes there are "no policies for downstream IRO's."

Actions and resources

Reference: pages 124-127.

Per decarbonisation lever, 2025 actions include: preparation for solar PV installation at one European site (renewable electricity); LED relighting projects and machinery replacements with energy-efficient solutions, plus energy-meter installation for real-time monitoring (energy efficiency); dialogue with suppliers on carbon data and decarbonisation plans (raw materials); and investment in co-extrusion lines to process more post-consumer PVC (recycled content). "In 2025, an amount rounding to €2,788,300 has been invested in the abovementioned CapEx projects."

Forecasted Scope 1/2 and Scope 3 reduction-lever charts quantify contributions from energy efficiency, renewable electricity and other levers against a "-60% scenario" and a 2030 Scope 3 reduction path. No dedicated decarbonisation budget is set aside; instead, financing draws on the Group's €120 million Sustainability Linked Loan and broader strategic and operational planning.

Climate targets

Reference: pages 128-129.

Scope 1 and 2: "Deceuninck commits to reduce absolute Scope 1 & 2 emissions 60% by 2030 from a 2021 base year," from 78,227 to a target of 31,291 tCO2e. Scope 3: a 52% reduction "per ton PVC produced by 2030" on a 2021 base year (735,345 to 551,510 tCO2e on the restated baseline), broken down by lever as raw materials -44%, logistics -5%, upstream energy -2%. A net-zero target across the value chain is set for 2050.

"Due to the full acquisition of Deceuninck Aluminum in 2025, the baseline year has been restated." The Scope 1/2 target uses the market-based method and covers "24% of Scope 1 GHG emissions and 76% of Scope 2 emissions" (baseline-year status); the targets "do not use a sectoral decarbonisation pathway as this is not available for our sector," and sales-volume growth is built into the "business as usual" scenario.

Energy consumption and mix

Reference: pages 130-131.

Total energy consumption was 224,411 MWh in 2025 (207,467 MWh in 2024), of which 176,090 MWh came from fossil sources and 48,321 MWh from renewable sources (market-based), giving a "share of renewable sources in total energy consumption" of 22% (down from 32% in 2024 as the denominator grew with the Aluminium acquisition). Electricity consumption was 147,172 MWh, of which 40,327 MWh was purchased renewable electricity and 7,994 MWh self-generated renewable electricity.

Fuel consumption from natural gas rose to 72,782 MWh (43,010 MWh in 2024), and consumption from other fossil sources was 5,164 MWh. No energy consumption from nuclear sources is reported (0 MWh in both years). The data sits alongside the Scope 1/2 GHG figures reported under E1-6 on the same pages.

GHG emissions

Reference: pages 130-133.

Gross Scope 1 emissions were 18,215 tCO2e in 2025 (comparative 2024 restated to 18,999 tCO2e). Gross location-based Scope 2 was 49,034 tCO2e and market-based Scope 2 was 40,151 tCO2e. Total gross Scope 3 was 655,983 tCO2e, up 6% year-on-year, dominated by Category 1 Purchased goods and services (550,470 tCO2e) and Category 4 Upstream transportation and distribution (26,287 tCO2e). Total GHG emissions (market-based) were 714,349 tCO2e, up 7% on 2024.

The value-chain split shows 85% of emissions upstream, 8% in own operations and 7% in transport. GHG intensity per net revenue (market-based) was 924 tCO2e/EUR million, up from 811. Scope 3 categories 6, 7, 8, 10 and 12 are screened out as immaterial; categories 11, 13, 14 and 15 are excluded as not applicable to the Group's business model. Only 6% of Scope 3 emissions use primary supplier data; the rest relies on Ecoinvent, ADEME and EPD-based emission factors.

Pollution policy

Reference: pages 134-136.

"While there is no specific policy in place to ensure compliance with Regulation (EU) 923/2023, the procedures and actions are integrated into operational processes, procedures and practices." Manufacturing risk is managed through tight regulation of suppliers, voluntary industry commitments (e.g. the ECVM Charter), and substitution of hazardous substances such as lead with safer alternatives over the past two decades. Compliance with REACH is monitored continuously via Safety Data Sheets for all raw materials.

Compliance is independently verified through the RecyClass audit scheme, and the Belgian recycling and extrusion plants are ISO 14001-certified, a management system that "covers the pollution topic amongst others." The report states "there are no immediate plans to develop a specific policy" beyond this integrated, certification-based approach.

Actions related to pollution

Reference: page 135.

Actions centre on responsible handling of legacy lead in recycled PVC. "The Group has been actively engaged in the recycling of PVC for over a decade and remains committed to continuing these practices"; because lead is "deeply integrated within the PVC material," recyclate is processed under closed-loop conditions with specific controls to "minimize potential health and environmental risks." The industry phased out lead stabiliser in virgin PVC since 2015, and the EU Regulation 2023/923 derogation (in force since November 2024, valid to May 2033) permits recycling of postconsumer PVC containing legacy lead under controlled conditions.

The recycling and extrusion plants in Belgium are ISO 14001-certified and audited under the RecyClass scheme, which the Group treats as its operational control for pollution-related actions rather than a standalone action plan.

Targets related to pollution

Reference: page 136.

"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." Rather than a reduction target, management relies on controlling and disclosing the substance: lead content in recyclate is capped through the co-extrusion process (visible surfaces kept below 0.1% lead) and profiles containing recyclate above that threshold are visibly marked "contains ≥0.1% lead."

Effectiveness is instead tracked operationally, through continuous lab testing of lead levels in recyclate and profiles, an annual independent laboratory review, and RecyClass/EN 15343:2007-aligned traceability certification of the extrusion sites and the Diksmuide recycling plant.

Substances of concern

Reference: pages 136-137.

Total amounts of substances of very high concern (lead) used during production and leaving the facilities were both 189 tonnes in 2025. Lead enters the product through recycling of post-consumer PVC produced before 2015, when the industry phased out lead stabiliser; under EU Regulation 2023/923 recyclate may contain up to 1.5% lead, while visible surfaces are kept below 0.1% and marked "contains ≥0.1% lead" where the threshold is exceeded.

Volumes are based on internal testing, verified on a sample basis by the European industry association and an external laboratory. Potential soil contamination at the recycling plant is measured every ten years (next due 2028; the 2018 measurement found "no deviations from the limit values"), and worker lead exposure is checked annually via blood samples, with results "below the limit values." The procedures were implemented at end-2024 "without associated CapEx expenditure."

Water policy

Reference: pages 138-139.

"While there is no specific policy in place for water management, procedures and practices are integrated into operational processes, procedures and practices in all plants of the Group." Water usage and wastewater management sit within the ISO 14001 management system adopted by four plants (three extrusion, one recycling/compounding). Upstream, raw-material suppliers must implement ISO 9001/14001 and are tracked for participation in VinylPlus and the ECVM Industry Charter.

Marine resources are explicitly out of scope: "Marine resources are not considered a material topic as the Group does not use sea water," and water recycling is described as immaterial to the Group's own process. The report notes "there are no immediate plans to develop a specific policy" given the current integrated approach.

Water actions

Reference: pages 140-141.

Closed-loop water systems are integrated into extrusion setups: water is captured post-extrusion, passed through a chiller to remove heat, filtered and partly reused. Groundwater is filtered before and after extrusion using mechanical filters and chemical neutralisation, and the Diksmuide recycling plant has an extended wastewater treatment system for larger solids. In water-stressed Turkish sites, a water basin under the buildings stores water to cut freshwater intake.

In 2025, water purification filters were installed at several sites, an air-cooled chiller replaced a water-cooled industrial unit, and a discharge meter was installed at one key site for more accurate measurement. "A total amount of 154,000 euro was invested in water management in 2025." The report adds that "no actions are identified for the value chain."

Water targets

Reference: page 141.

"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 2027, once historical data allow for a good comparison on Group level." In the meantime, the Group states this "does not prevent us from implementing efficiency measures to reduce water consumption, with priority focus on locations at material water risk," referencing the closed-loop reuse systems and filtration investment described under E3-2.

Water consumption

Reference: page 140.

Total water consumption was 178,857 m³ in 2025 (182,448 m³ in 2024), of which 149,898 m³ occurred in areas at material water risk (up from 142,900 m³). Water consumption intensity was 1,950 m³ per million EUR net revenue in both years. Total water stored was 231 m³ (221 m³ in 2024), held across two facilities with separate storage for process water and sprinkler systems.

Consumption is calculated as withdrawal minus discharge. The scope covers Group entities and production facilities in Belgium, Colombia, Chile, Croatia, France, Germany, Poland, Russia, Spain, Türkiye, the UK and the US; "locations with purely warehouses and/or sales offices are not material and therefore excluded." The metric is "based on direct measurements" and "not validated by another body than the assurance provider."

Circular economy policy

Reference: pages 142-143.

"The Group EHS policy underscores our commitment to circular economy, highlighting the core elements of recycling and usage of recycled content in the production." The policy is built around in-house recycling of postconsumer PVC material and investment in recycling-plant capacity, with a stated goal of ensuring recycled-material quality through automated processes "that eliminate contaminations from other waste streams in the PVC fraction."

No specific IROs were identified for circular economy in the upstream value chain, "as PVC recycling is done in-house by the Group." Downstream, the strategy of using recycled content is described as positively impacting the value chain by lowering products' carbon impact and recovering end-of-life material; the disclosures jointly cover own operations and value chain since "the approach of the Group is the same."

Circular economy actions

Reference: pages 144-145.

Post-consumer PVC recycling follows collection, breaking, cleaning, sorting and granulation. "In 2025, 1,050,000 euro was invested in the recycling facility, mainly for equipment replacements and upgrades," and a further "2,046,000 euro in new co-extrusion lines in Europe and in Türkiye" to process more recycled PVC. The Group states these recycling activities "result in the avoidance of 48,000 tons of carbon equivalents."

Design-for-recycling guidelines from EPPA (processed into a draft European standard in 2024) shape product design; Deceuninck North America is "GreenCircle Certified for the recycled content in window profiles," and European sites hold the VinylPlus product label. R&D projects include the OpToSims tool-design project, foiling processes enabling "up to 80% recycled content in profiles," glass-fibre recycling for injection-moulded parts, and the Cisuflo project on hard-to-recycle waste fractions.

Circular economy targets

Reference: pages 144-147.

The Group has an annual target for the output weight of PVC processed at its recycling facility: "2025 target: 26,393 ton; 2026: 30,616 ton." Set voluntarily in 2022 under the Sustainability Linked Loan, the targets "envisage a year-over-year increase as of 2022 of 10% to 16% (not science based)." The Group states plainly, "We did not reach the target in 2025, nor in 2024," citing a challenging renovation/construction market, limited input recycled-material availability, cheaper virgin PVC, and stringent quality requirements for recycled PVC.

There is "no specific volume or percentage target set for the consumption of recycled material in new products," though the Group "intends to gradually increase the share year-over-year," and recycled-PVC use is described as "a central element of the Group's Scope 3 decarbonization target by 2030."

Resource inflows

Reference: pages 146-147.

Total weight of resource inflows reached 497,609 tonnes in 2025 (476,707 tonnes in 2024), consisting mainly of PVC resin with additives (stabilisers, fillers, lubricants, modifiers) plus processed aluminium volumes. No biological materials are used (0% in both years). Recycled PVC made up 17.2% of material used to manufacture products (16.5% in 2024); recycled aluminium made up 66% (not available in 2024, the acquisition year).

At the recycling plant, input was 30,891 tonnes and output 21,482 tonnes of recycled material in 2025 (30,717 and 22,158 tonnes in 2024), externally verified by RecyClass. The 17% average recycled-PVC share combines post-consumer waste from the Group's own recycling plant, post-industrial waste from own production, and pre-consumer waste collected from window fabricators and installers.

Own workforce policies

Reference: pages 154-157.

Core policies are the Code of Conduct, Human Rights Policy, Remuneration Policy and EHS Policy, "inspired by externally recognized principles" including ILO Declarations, the UN Guiding Principles on Business and Human Rights, and OECD Guidelines. A Remuneration Policy governs Executive Team pay; a Global Merit Policy for managers and expert functions was under development in 2025, "still ongoing," with local law able to override specific provisions.

The Human Rights Policy sets out fair-pay, non-discrimination and freedom-of-association commitments, and "does not target specific people from groups at particular risk of vulnerability." No global policy yet exists for work-life balance or training and development, though "many locations have implemented a local policy." Health and safety is governed by a Group EHS policy plus region-specific frameworks (ISO 45001 in Türkiye, US federal/state OSHA standards, PDCA-based practices in Europe), and "100% of our workers is covered by a management system based on legal requirements or a recognized standard."

Workforce engagement

Reference: pages 158-159.

Engagement channels include workforce surveys, "designated trust persons," performance and development reviews, and a whistleblower mechanism covering "all Group operations worldwide." Other channels include information screens in production facilities, idea boxes, intranet updates, and biannual online briefings from the CEO/CFO with a Q&A segment for senior management, recorded for all employees.

Workers' representation councils for safety and prevention operate "in all production plants," advising on preventive measures and investigating incidents. In countries with employee representation, "the Group organizes formal engagement sessions with employee representatives." Overall responsibility for engagement sits with the Group CHRO, with outcomes shared with Executive Management, and effectiveness is tracked through annual employee-engagement surveys with regional satisfaction scores and follow-up actions.

Remediation channels

Reference: pages 159-161.

Reporting mechanisms described under S1-2 (whistleblower platform, trust persons) are "outlined on the intranet and communicated to all employees through training sessions, informative materials and posters." The Group states it "takes all incidents seriously and handles cases confidentially and with care, considering all parties' privacy and needs," providing employees facing bullying, discrimination or harassment "access to remedies that ensure fairness, justice and protection," with disciplinary measures or individual support applied case by case.

Monitoring is carried out by local HR departments under the Group CHRO, with overall responsibility resting with the Group General Counsel. Separately, unsafe situations are reported to local EHS managers, who oversee corrective procedures; safety performance is reviewed monthly by regional management and quarterly by Executive Management and the Board.

Taking action

Reference: pages 160-161.

Actions are tracked through "a performance-driven approach," continuous metric assessment and annual "Together Ahead Dialogues" performance and development reviews. On employment, the Group runs "global recruitment strategies" and employer-branding activity, including sponsorship of the Alpecin-Deceuninck cycling team through end-2025, with a new campaign planned for 2026. On work-life balance, the Group supports employees "when employees or their close family members face exceptional, serious health or economic difficulties ... through solidarity actions."

Training is delivered via the Udemy online platform (expanded further in 2025) and a Learning Management System under implementation, expected complete by end-2026. "The Group does not identify significant impacts on the workforce from the decarbonization transition plan"; no restructuring or employment-loss impacts are reported, and reskilling is folded into ordinary HR training.

Targets

Reference: page 162.

"The Group does not have Group-wide targets in place related to abovementioned topics [employment, adequate wages, social dialogue, work-life balance, training and skills development, diversity and inclusion/human rights] but aims to continually evolve by implementing the above-described actions." Effectiveness "is tracked performance-driven, through assessment of the metrics and through the engagement mechanisms described above," and there are "no immediate plans to define quantitative targets" for these subtopics.

Health and safety is the exception: a target set under the 2022 Sustainability Linked Loan targets year-over-year improvement in the rate of recordable work-related accidents; "the target for 2025 was to reach a 13.8 rate ... this has been reached. The target for 2026 is to reach 13.1."

Employee characteristics

Reference: pages 162-163.

Total headcount was 3,669 at 31 December 2025 (3,719 in 2024): 3,076 male and 593 female. By contract type, 3,135 employees were permanent (534 temporary), split as 504 permanent female / 2,631 permanent male and 89 temporary female / 445 temporary male. By region, employees split 1,827 Europe, 1,321 Türkiye & Emerging Markets, and 521 North America (totalling 3,669), broadly stable year-on-year.

"Significant financial resources allocated to the management of material impacts" include €1,463,000 invested as CapEx in structural safety improvements. Data is drawn from HR-system registrations as at 31 December of the reporting year.

Non-employee workers

Reference: page 152; index page 184.

The report defines its non-employee population for ESRS purposes: "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')." Health and safety policies and instructions applying to employees "also apply to non-employees (contractors, temporary workers) and visitors," and the same non-discrimination and equal-treatment principles extend to relationships with non-employees across the value chain.

The ESRS content index lists S1-7 as covered (page 184), though the extracted text does not carry a separate headcount breakdown of non-employees by category; the disclosure is limited to this definitional and policy-coverage statement rather than a quantified table.

Collective bargaining and social dialogue

Reference: pages 164-165.

"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." Belgium, France and Spain each report 100% coverage.

Separately, "the Group is active in 4 countries where workers' representation by a work council is in place," with "36% of the Group's employees ... covered by workers' representation," and no coverage by a European Works Council, SE Works Council or SCE Works Council. Belgium, France, Poland and Spain each report 100% work-council coverage in those jurisdictions.

Diversity metrics

Reference: pages 164-165.

Top management gender split: 7 female / 40 male in 2025 (9 female / 43 male in 2024), or 15% female / 85% male (down from 17%/83%). Top management is defined as "senior leadership, two levels below the Board of Directors." Age distribution of the workforce (permanent and temporary FTE) shows 691 employees aged ≤29, 2,229 aged 30-49, and 749 aged ≥50 in 2025.

Employee turnover was 886 leavers in 2025 (768 in 2024), a turnover rate of 29% (up from 24%). Data is based on HR-system registrations at 31 December of the reporting year, calculated using average headcount and leavers during the year.

Adequate wages

Reference: pages 150, 166.

"All of the employees of the Group are paid an adequate wage, in line with applicable benchmarks provided by international or national legislation." The Group "regularly reviews its salary structures to support external competitiveness and internal consistency," using labour-market surveys and benchmarking. In 2024 it launched a global Compensation & Benefits ("Comp & Ben") exercise for a "more consistent, transparent, and data-driven approach to compensation," with a pilot in two departments in 2025 ahead of a planned 2026-2027 wider rollout.

The gender pay gap, calculated as the difference in average annual total remuneration between male and female employees, was -0.3% in 2025 (-4.0% in 2024), which the Group describes as indicating "near parity" between genders.

Health and safety metrics

Reference: page 166.

"Percentage of workforce covered by the undertaking's health and safety management system based on legal requirements and/or recognized standards or guidelines" was 100% in both 2025 and 2024. Recordable work-related accidents fell to 57 in 2025 (79 in 2024), a rate of 8.6 per million hours worked (11.5 in 2024) - meeting the Group's 2025 target of 13.8. There were 0 fatalities as a result of work-related injuries or ill health in either year.

The Group attributes the improvement to "targeted measures implemented in 2025 to prevent incidents," noting one location where "the launch of a new activity had caused a significant rise in incidents in 2024" was "effectively addressed in 2025." The number of days lost to injuries, accidents, fatalities or illness is listed as a phase-in datapoint not disclosed this year (page 186).

Work-life balance

Reference: page 166.

"All of the employees of the Group are entitled to take family-related leave, in accordance with international or national legal frameworks in place." The Group describes broader work-life balance efforts under S1-4 (page 161): in 2025 it "continued its efforts to promote a healthy lifestyle, psychological well-being, and balanced work-life dynamic," and supports employees facing "exceptional, serious health or economic difficulties" through solidarity actions.

The quantified metric required by S1-15 - the average number of paid family-related leave days taken by gender - is listed as a phase-in datapoint not disclosed this year: "ESRS S1-15: Family-related leave" (page 186).

Compensation metrics

Reference: page 166.

The gender pay gap, "calculated as the difference of average annual total renumeration of male versus female employees, expressed as a percentage of the average annual total remuneration of male employees," was -0.3% in 2025 (-4.0% in 2024), described as indicating "near parity in average remuneration levels between male and female employees." The total annual remuneration ratio - comparing the highest-paid employee's gross salary to the median gross salary of the rest of the workforce - was 24.0 in 2025 (20.7 in 2024).

A footnote notes: "Due to data availability limitations, the total remuneration ratio KPI is calculated based on the annual gross salary, instead of the annual total remuneration as defined by the ESRS." Average, median and highest annual remuneration figures are listed as a phase-in datapoint not disclosed this year (page 186).

Incidents and complaints

Reference: page 166.

"Total number of incidents of discrimination" was 7 in 2025 (15 in 2024); "total number of complaints filed" was 12 (43 in 2024); "total amount of fines, penalties and compensation for damages" was 0 in both years. Incidents and complaints "are filed by the own workforce and are related to behavior not in line with the principles outlined in the Code of Conduct" and "do not qualify as severe human rights impacts."

Complaints are filed through the channels described under S1-2/S1-3; incidents are defined as "complaints that have resulted in specific actions following an investigation." Non-employee data for this metric is listed as a phase-in datapoint not disclosed this year: "ESRS S1-17: Non-employees" (page 186).

Value chain worker policies

Reference: pages 168-169.

Suppliers and subcontractors are expected "to comply with the same ethical standards" as the Group, set out in a Supplier Code of Conduct covering "health and safety, labour practices and human rights, child labor, environmental protection, fair business practices and freedom of association and collective bargaining," and indirectly prohibiting trafficking and forced/compulsory labour. All direct and indirect suppliers "are obliged to sign" the Code; "no new supplier can be created without a signed Code of Conduct."

A 2023 country-risk analysis (using ISS ESG, the Global Labor Rights Index and Amfori country governance data) classified Tier-1 suppliers into four labour-rights risk levels: "83% of the suppliers are located in countries with (very) good labor rights ... 16% ... in countries with (very) low labor rights," concentrated in South-East Asia, Eastern Europe and Türkiye. The Group evaluates its human-rights risk exposure as "low," so "no additional due diligence mechanisms have been implemented yet."

Engaging value chain workers

Reference: page 170.

"There are no dedicated resources allocated to managing human rights impacts, apart from the efforts of the procurement teams to ensure suppliers adhere to the Supplier Code of Conduct." The Group states plainly: "The Group has not adopted a process to engage with workers in the value chain and does not have concrete plans to do [so]."

This limited approach follows from the low-risk classification under S2-1 (83% of suppliers in countries with good labour rights) and the absence of adopted due-diligence mechanisms beyond the Supplier Code of Conduct requirement.

Remediation channels for value chain workers

Reference: page 170.

"The Group has not adopted a channel for raising concerns in the workplace of value chain workers and does not have concrete plans to do so." No dedicated grievance mechanism specific to upstream or downstream value-chain workers is described; the Group's whistleblower platform (described under G1 and S1) is open to "employees and persons in a professional relationship (such as trainees, contractors)," but a value-chain-worker-specific remediation channel is explicitly stated as not yet adopted.

Taking action on value chain workers

Reference: pages 169-171.

Action is concentrated on Supplier Code of Conduct adherence rather than direct engagement or remediation. Effectiveness is tracked through "'Percentage of spend covered by suppliers adhering to the Code of Conduct' in our 3 key markets (Europe, Türkiye, DNA). In 2025, 91% of spend is covered ... an increase compared to 2024 (86%)." Measures in place include grievance mechanisms open to employees, non-employees and subcontractors, ongoing supplier dialogue during procurement, and cooperation with authorities and affected stakeholders on any negative impact.

Where a supplier is not in line with the policy, the Group can request a corrective-action plan, apply enhanced monitoring (more frequent audits, progress reporting), or escalate to suspension of new orders, contractual penalties or termination. "No other actions were taken or are planned," and "no (severe) human rights issues and incidents connected to the upstream and downstream value chain have been reported."

Value chain worker targets

Reference: pages 170-171.

No quantified target is set; instead the Group tracks Supplier Code of Conduct adherence (91% of spend covered in 2025, up from 86% in 2024, described under S2-4). "As the Group is no longer subject to CSDDD at present, we are refining our approach to risk-based impact assessment, targeted supplier screening and performance tracking in line with regulatory requirements and stakeholder expectations." "No additional CapEx or OpEx is currently foreseen."

Responsibility for these efforts sits jointly with procurement teams, the Group General Counsel and the Group Sustainability Manager. Actions in 2025 focused regional procurement teams on increasing supplier acceptance and adherence to the Code, monitored with particular focus on large suppliers; "until now no supplier has obstructed signing the document."

Business conduct policies

Reference: pages 174-175.

Corporate culture is "built on a foundation of Trust, Top Performance, and Empowerment," embedded in the Code of Conduct; new values were defined via broad workforce consultation for implementation in H1 2026. Decision guidance for employees is framed around four questions: consistency with core values, guiding principles, impact on people, and protection of Deceuninck's reputation ("Long-lasting Relationships").

The anti-corruption and anti-bribery policy, set out in the Code of Conduct, is "inspired by the United Nations Convention against Corruption" and covers "offering, giving, receiving, or soliciting of any advantage," facilitation payments, and improperly influential gifts/hospitality. Oversight mechanisms include internal audit, the Audit Committee, a Compliance Officer (the General Counsel, an Executive Management member) and a whistleblower platform open to employees and contractors/trainees, allowing anonymous reporting.

Corruption and bribery procedures

Reference: pages 176-177.

Procedures to prevent, detect and address corruption and bribery allegations include internal audits (the Internal Auditor reporting directly to the Audit Committee), the Code of Conduct e-learning, oversight by the Compliance Officer (currently the General Counsel), and the whistleblower platform. "Investigators are independent from the management chain responsible for the prevention and detection of corruption and bribery," ensuring objective, impartial investigation.

New white-collar joiners must complete the Code of Conduct e-learning (about 35 minutes, covering identifying/reporting concerns, the legal framework, and ethical-behaviour best practices); a Compliance Refresher Course was also offered in 2025. Purchasing-department employees are treated as higher risk given supplier interaction and are specifically targeted for training completion. "The management is covered by the training program," though "Board members have access to the training material as part of the onboarding program, but have not been invited to the online Code of Conduct E-learning."

Targets related to business conduct

(part of MDR-T/GDR-T disclosures)

Reference: page 177. Prepared under the 2023 ESRS, which had no standalone G1-3 targets requirement (business conduct targets instead fell under MDR-T).

"There are no specific targets on anti-corruption and anti-bribery. The Group nevertheless tracks the effectiveness of its policies and programs on a continuous basis." Effectiveness tracking uses concrete measures rather than a numeric target: Code of Conduct e-learning completion for new white-collar joiners and purchasing staff, the G1-4 incident metrics (convictions, fines, confirmed incidents - all zero for 2025), and the whistleblower platform's reporting and investigation process, with the Internal Audit department reporting directly to the Audit Committee.

This satisfies the "other limb" of MDR-T: in the absence of a stated target, the report describes how effectiveness of business-conduct policy is monitored.

Corruption and bribery incidents

Reference: page 176.

"Number of convictions for violation of anti-corruption and anti-bribery laws" was 0 in both 2025 and 2024; "amount of fines for violation of anti-corruption and anti-bribery laws" was 0 in both years. "Total number of confirmed incidents of corruption or bribery" was 0 in 2025, down from 1 in 2024, when that incident also resulted in the "number of confirmed incidents in which own workers were dismissed or disciplined" being 1. "Number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations" was 0 in both years, as were "public legal cases regarding corruption or bribery."

"In 2025, the Group reported no incidents." The metrics table "discloses information on corruption and bribery as defined in the Code of Conduct"; other fraud types can also be reported via the whistleblower platform.