Deme Group

The role of the administrative, management and supervisory bodies

Board of Directors composition and diversity

The Board of Directors now has four Independent Directors out of 11 members, bringing the percentage to 36% of independent board members. The total number of female directors is now four out of 11 members resulting in a female representation of 36%, elevating the gender diversity of DEME's Board of Directors. The international perspective within the Board of Directors is ensured by the presence of four nationalities: Belgian, Italian, French, and Dutch. The age of our board members spans from 47 to 73 years old among board members elected by the AGM.

Our board members come from diverse educational backgrounds in finance, economics, and engineering, with professional experience from diverse industries, private equity, private investments, and academia. In the domain of ESG, the board members, with their varied backgrounds and expertise, collectively provide substantial knowledge to discussions on DEME's key material topics, including GHG emissions, the energy transition, and occupational health and safety.

Board Composition as at 19 March 2025:

Changes to Board composition

Mrs. Kerstin Konradsson, who served as an independent director on DEME's Board since 2022, has resigned from her position. Mrs. Gaëlle Hotellier and Mrs. Marieke Schöningh have been appointed to serve as independent directors of DEME's Board each for a four-year term.

Board expertise and skills

Each member of the Board possesses specific ESG qualifications, which are complemented with access to sustainability experts and targeted ESG trainings. Material topics like energy transition, greenhouse gas emissions, and Occupational Health and Safety are discussed at least twice a year, and sometimes at every Board meeting, fostering ongoing development of the Board's knowledge and skills in these areas.

As of 2024, the Board of Directors annually reviews the overview of the required competences within the corporate structure to also cover Environmental, Social and Governance (ESG) expertise domains:

• Environmental: Topics such as climate change, pollution, water and marine resources, biodiversity and ecosystems, resource use the circular economy
• Social: Own workforce, workers in the value chain, and affected communities
• Governance: Business conduct

Board activity and meeting frequency

In 2024, the Board of Directors was convened 8 times with a 94% attendance rate to deliberate on key strategic matters, ensuring the sustainable development and compliance of the organization.

Key areas discussed included:

• Continuous updates per segment on projects and outlook presented by DEME management at every meeting
• Deep dive sessions with management of segments DEME Offshore and DEME Environmental regarding their respective activities, outlook, current risks, and organizational structures
• Discussion and regular updates on the budget for the current financial year
• Approval of a general share buyback programme on 23 February 2024 to acquire 45,000 shares to cover the company's obligations under the approved stock option plan
• Presentation and discussion of the compliance activity report for 2024 and action plan for 2025, emphasizing the importance of maintaining a culture of compliance throughout the organization
• Updates on implementation of new compliance risk software
• ESG obligations with focus on CSRD reporting, double materiality assessment, and obligations under DEME's sustainability linked loans
• Regular HR matters updates, including churn, open vacancies, roadmap for employee training, and employer branding campaigns

Members of the Executive Committee, as well as the Strategic Operations Director and the Chief Legal Officer attend the meetings of the Board of Directors.

Board attendance 2024:

Executive Committee

The Executive Committee operates as an advisory committee (separate from the Board of Directors). It is responsible for discussing the general management of the Company and assists the CEO in the exercise of his powers.

Executive Committee composition as at 19 March 2025:

The Executive Committee typically meets twice a month. The Strategic Operations Director and Chief Human Resources Officer attend most of the Executive Committee meetings. In 2024, the Executive Committee held 20 meetings with a 98% attendance rate.

Changes to the Executive Committee

As planned, Ms. Els Verbraecken voluntarily resigned as CFO of DEME as from 15 May 2024 and was succeeded by Mr. Stijn Gaytant, who also became a member of the Executive Committee as of 1 July 2024.

Management Team

In its duty to steer the strategy and the day-to-day management of the company, DEME's Executive Committee is supported by the Management Team of DEME. The Management Team is set to meet 7 times per year. In 2024, the Management Team held 7 meetings with a 90% attendance rate.

The Management Team comprises 18 members including the CEO, Managing Directors of segments, Area Directors, General Managers, Chief Human Resources Officer, Chief Financial Officer, Chief Technology Officer, Strategic Operations Director, Sustainability Director, and Chief Legal Officer.

Board committees

Audit Committee

The Audit Committee reports to the Board of Directors with a focus on preparation of the Annual Report and consolidated financial and sustainability statements. It oversees financial reporting, internal control and risk management, and internal and external audits.

Audit Committee composition (5 members):

• Tom Bamelis (Chairman, Non-executive Director)
• Leen Geirnaerdt (Independent Director)
• Koen Janssen (Non-executive Director)
• Christian Labeyrie (Non-executive Director)
• Marieke Schöningh (Independent Director)

Key characteristics:

• 2/5 members (40%) are independent directors
• 2/5 members (40%) are women
• 5 meetings held in 2024
• 95% attendance rate

Tom Bamelis, Christian Labeyrie, Leen Geirnaerdt and Marieke Schöningh have the necessary accounting and audit expertise as shown in their biographies.

Audit Committee activities in 2024:

• 14 February and 19 March 2024: Reviewed annual financial and non-financial results, press release on results with external auditor feedback, updates on compliance status, tax control framework, treasury, 2023 ESG metrics, and draft 2023 Annual Report
• 7 May and 20 August 2024: Reviewed key figures and highlights for Q1 and Q2, orderbook, income statement, balance sheet, cash flow items, internal audit and control topics, tax control framework and strategy updates; external auditor presented 2024 Audit Plan at 20 August meeting
• 7 November 2024: Reviewed Q3 key figures and highlights, balance sheet items, investments, internal audit and control, company insurance overview, Tax Control Framework update, Internal Auditor status update on 2024 internal audit activities and 2025 Internal Audit Plan

The CFO, group Finance Directors, and Internal Audit Director attended all regular meetings. The external auditor is invited to every meeting.

Audit Committee attendance 2024:

Remuneration Committee

The Remuneration Committee advises the Board of Directors concerning the remuneration of the members of the Board of Directors and of the Executive Committee.

Remuneration Committee composition (3 members):

• Luc Bertrand (Chairman, Non-executive Director)
• Karena Cancilleri (Independent Director)
• Gaëlle Hotellier (Independent Director)

Key characteristics:

• 2/3 members (67%) are independent directors
• 2/3 members (67%) are women
• 2 meetings held in 2024
• 83% attendance rate

Remuneration Committee activities in 2024:

• 21 February 2024: Reviewed and approved remuneration of DEME Group NV's Directors and Committee members; approved bonus budget for DEME's senior management for 2023; discussed and approved a Stock Option plan (subsequently approved by Board on 23 February 2024); discussed and agreed individual remuneration components including short- and long-term incentive elements for Executive Committee and Management Team members; discussed share buyback program to cover obligations under Stock Option plan
• 9 October 2024: Approved implementation of self-employed transition scenario for Management Team members effective 1 January 2025; discussed and approved approach, process and budget for January 2025 pay review and 2024 bonuses for DEME's global staff

DEME Group NV's Chief Executive Officer, Chief Financial Officer and Chief Human Resources Officer attended all Remuneration Committee meetings, also attended by Mr. John-Eric Bertrand, Non-Executive Director.

Remuneration Committee attendance 2024:

Nomination Committee

As mentioned in DEME's Corporate Governance Charter, the role of the Nomination Committee was assumed by the Board of Directors. The Nomination Committee strives towards the organization of an objective and professional course of the nomination process.

In March 2024, the Board of Directors, in the role of Nomination Committee, decided to propose Gaëlle Hotellier and Marieke Schöningh as Independent Directors of the Company and to submit this proposal to the Annual General Meeting of 15 May 2024.

Sustainability governance

Our sustainability governance model focuses on two core elements: exploring sustainable business solutions by continuously challenging ourselves to develop more sustainable solutions, and excelling in our operations through sustainable performance in our daily operations.

Sustainability Board

DEME's Sustainability Board was established by the Executive Committee to ensure sufficient expertise in ESG and DEME's material topics. The Sustainability Board is charged with defining, managing, and monitoring these key ESG areas.

Sustainability Board composition:

• Chair: Luc Vandenbulcke (CEO and Executive Director)
• Sustainability Director: Jiska Verhulst
• Other members: Hugo Bouvy (Managing Director Offshore Energy), Hans Casier (Chief Human Resources Officer), Jan Gabriel (Head of Fleet Construction & Conversion Department), Stijn Gaytant (Chief Financial Officer), Christopher Iwens (Managing Director Dredging), Dirk Poppe (Area Director Dredging Asia Pacific / Managing Director Environmental), Olivier Maes (Strategic Planning & Growth Director), Eric Tancré (Managing Director Dredging / Managing Director Infra), Koen Vanderbeke (Strategic Operations Director)

Meetings and frequency: In 2024, the Sustainability Board met 7 times to evaluate the sustainability performance of our project portfolio and the progress made towards our objectives from both a strategic and operational perspective.

The Sustainability Board ensures regular and consistent updates to the Executive Committee, CEO (both represented in the Sustainability Board) and Board of Directors. It provides guidance on both strategic and operational sustainability matters to ensure that decisions align with our values, sustainability strategy, and objectives.

Sustainability Team

The Sustainability Team was established by the Executive Committee to ensure sufficient expertise in ESG and DEME's material topics, a dedicated and consistent follow-up of ESG, and to drive new initiatives within this domain. The team is composed of individuals with the necessary skillset and background, and they are provided with ample opportunities for training and education to continue contributing to DEME's relevant ESG topics.

Tasks:

• Follow-up regulatory evolutions concerning ESG
• Coordinate and follow-up of the execution of ESG-topics
• Monitoring and reporting on targets and KPIs related to sustainability

Objectives: The Sustainability Team is responsible for integrating sustainability into DEME's operations. Led by DEME's Sustainability Director, the team sets the agenda and ensures the preparation of the Sustainability Board.

Sustainability matters addressed by the Board and Audit Committee

Board of Directors:

Audit Committee:

Representation of employees and other workers

DEME employs a range of tools to ensure transparency, inclusiveness, and the well-being of employees, making sure their voices are heard across the organization, including at Board level:

1. Structured Dialogue Approach: DEME has a structured process for engaging in and maintaining a dialogue with employees. This is facilitated through a Workers' Council, which meets at least twice a year—shortly after the full-year and half-year results. Through debriefing sessions, HR ensures that employees' perspectives are communicated to the CEO (who holds a Board seat) and the Executive Committee, both of which regularly attend Board meetings.

2. Dedicated HR Discussions at the Board Level: Once a year, the Board of Directors includes human resources as a dedicated agenda topic to address workforce-related matters comprehensively, ensuring that employee concerns are given focused attention.

3. Employee Participation: Selected employees from various departments are regularly invited to participate in Board meetings, ensuring that decisions are informed by direct input from across the organization, reflecting its internal dynamics and diverse perspectives.

4. Annual Site Visits: An annual "extra muros" Board meeting is held at a DEME site or project location. These visits allow Board members to experience team dynamics, company culture, and operational priorities firsthand.

Diversity Policy

DEME is convinced of the positive influence of diversity-based human resources, employment policies and practices and strives to ensure diversity in terms of characteristics and skills, by including different nationalities, genders, ages, perspectives and backgrounds.

The composition of our Board of Directors and Executive Committee reflects our Diversity Policy in terms of professional background, skills and gender. The same principles applied to the Board of Directors are also applied to the Audit and Remuneration Committees, ensuring diversity in age, gender, nationality, educational background and professional experience and with Independent Directors present in both committees.

With regard to the composition of the Executive Committee, the Board of Directors must also ensure that the members have diverse professional backgrounds with complementary skills. It is the aim of the Board of Directors that the long-term vision of DEME is supported by executives who actively promote the values of the company and, in this sense, contribute to value creation. All members of the Executive Committee have been appointed from within the group based on their personal merits.

Independence and effectiveness

The Board of Directors has four Independent Directors out of 11 members (36%), meeting independence criteria for independent directors of article 3.5 of the Code.

The Board members, with their varied backgrounds and expertise, collectively provide substantial knowledge to discussions on DEME's key material topics. They are provided with continuous focus on ESG risks and opportunities through various governance roles, participation in training programs, and membership in ESG-related committees and councils.

Compliance with Belgian Corporate Governance Code

The Board of Directors published its policy regarding transactions between DEME Group NV or a company affiliated to it on the one hand, and members of the Board of Directors or Executive Committee (or their close relatives) on the other hand, which may give rise to a conflict of interest. In 2024, no decision had to be made to which this policy applied.

The Charter of DEME Group NV complies with the provisions of the Code (as it applied in 2024) in all but two points:

• Provision 4.19: requiring the Board of Directors to set up a Nomination Committee with the majority of its members comprising Independent Non-executive Board members. The Board of Directors as a whole performs the function of the Nomination Committee at DEME Group NV.
• Provision 5.2: requiring that the Nomination Committee should lead the nomination process and recommend suitable candidates to the Board of Directors.

Given the importance of (re)appointment processes for the company, the Board of Directors currently deems it appropriate to fulfil the role of the Nomination Committee itself and in this way, as a collegiate body, to lead such processes and to be fully involved in the preparation of any recommendations or proposals in this regard.

Integration of sustainability-related performance in incentive schemes

Roles covered

Integration of sustainability-related performance in incentive schemes applies to DEME's Executive Committee members.

Short-term incentive (STI) structure

Description: A short-term incentive (variable bonus) reflecting performance and contribution for which the annual budget is determined by DEME's annual company performance on a set of safety and financial Key Performance Indicators.

Sustainability KPIs:

• Worldwide Lost Time Injury Frequency Rate (WW LTIFR) - safety metric
• EBITDA - financial metric
• Net Profit - financial metric
• Debt Rate - financial metric

The KPIs are approved by DEME's Board of Directors.

Long-term incentive (LTI) structure

Description: A long-term incentive (stock option plan) reflecting performance and contribution for which the annual budget is determined by the evolution of DEME's annual company performance based on a set of safety and financial Key Performance Indicators.

Sustainability KPIs:

• Worldwide Lost Time Frequency Injury Rate (WW LTIFR) - safety metric
• EBITDA - financial metric
• Net Profit - financial metric
• Debt Rate - financial metric

The KPIs are approved by DEME's Board of Directors.

Stock option characteristics (2024 grant):

• Offer date: early March 2024
• Exercise price: the lowest of (i) the average closing share price during the last 30 days preceding the offer date or (ii) the closing share price on the day preceding the offer date
• Vesting: vesting at 1/3 of the number of options per calendar year during the 3 calendar years following the year of grant
• Exercise period: the stock options cannot be exercised before the end of the third calendar year following the year of grant and can then be exercised until the end of the eighth year following the date of grant

Allocation process: Stock options are allocated to DEME's Executive Committee (and Management Team) members, upon recommendation of the Remuneration Committee and approved by the Board of Directors, within the context of DEME's stock option plan.

Weighting and performance metrics

The company discloses that both STI and LTI annual budgets are determined by DEME's annual company performance on a set of safety and financial KPIs. The specific weighting (% allocation) of sustainability metrics versus financial metrics is not disclosed.

Performance outcomes for reporting period (FY2024)

Safety performance (WW LTIFR):

• FY2024 result: 0.10
• FY2023 result: 0.19
• FY2022 result: 0.23
• Performance: -47% improvement year-over-year, well below the 0.20 target

GHG reduction performance:

• FY2024 result: 30% reduction in GHG intensity (vs 2008 baseline)
• FY2023 result: not assessed nor audited
• FY2022 result: 27% reduction
• 2030 target: 40% reduction
• Performance: significant progress toward 2030 target

Low carbon fuels:

• FY2024 result: 5.8% of total fuel usage
• FY2023 result: 10.3%
• FY2022 result: 6.0%
• Performance: -4.4 percentage points decline, described as a setback due to non-generalized adoption in industry and limited availability

The company notes that DEME failed to meet its target for Sustainability-Linked Loans (SLLs) related to low carbon fuels usage in 2024.

Governance and approval process

Remuneration components of DEME's Executive Committee members are:

• Reviewed and agreed by DEME's Remuneration Committee
• Approved by the Board of Directors

Strategy, business model and value chain

Overview of products, services, and markets

DEME operates as a global leader in specialized marine activities, providing innovative solutions across four primary segments: Offshore Energy, Dredging & Infra, Environmental, and Concessions. The group has evolved into a provider of sustainable marine solutions, addressing environmental and societal challenges. Each segment caters to distinct markets and client groups, contributing to DEME's diverse and global portfolio.

Offshore Energy segment

This segment provides engineering and contracting services globally in the offshore renewables and non-renewables industry. These activities are carried out with a fleet of specialized offshore vessels. The services support the entire project life cycle and include among others the engineering, procurement, construction and installation of foundations, turbines, inter-array cables, export cables and substations. The segment also offers operations and maintenance, logistics, repair and decommissioning as well as salvage services to the market next to landfalls and civil works, rock placement, heavy lift and umbilicals. In addition to these main activities, the group also provides specialized offshore services, including geoscience services and the installation of suction pile anchors and foundations. Key clients include energy suppliers, private equity firms, and government bodies, either directly or through consortia.

Dredging & Infra segment

In this segment the group performs a wide variety of dredging activities worldwide, including capital and maintenance dredging, land reclamation, soil improvement, port construction, coastal protection and beach nourishment works. These activities are executed with specialized dredging vessels and various types of auxiliary vessels and earth-moving equipment. The group also provides contracting services for marine infrastructure projects. This includes the engineering, design and construction of complex marine structures such as jetties, port terminals, locks and weirs, infrastructural works such as bored and immersed tunnels, foundation and marine works for bridges or other constructions in a marine or fluvial environment, and civil works for harbor construction, dams and sea defenses, canal construction, revetment, quay wall construction and shore protection. In addition, the group is active in the marine aggregate business, which includes dredging, processing, storage and transport of aggregates. Finally, the group provides maritime services for port terminals. The segment's main clients are government bodies and port authorities.

Environmental segment

The Environmental segment focuses on innovative environmental solutions for soil remediation and brownfield redevelopment, environmental dredging and sediment treatment and water treatment. It is mainly active in the Benelux, France, as well as in other European countries on a project-by-project basis. An external partner participates in the Environmental segment. The segment can be considered as a material partly owned aggregated level of subsidiaries with non-controlling interests of 25.1%. The main clients are government bodies and public institutions.

Concessions segment

The Concessions segment, unlike the contracting segments, invests in and develops projects in wind, port infrastructure, green hydrogen and other special projects. It operates through participations in special purpose companies – greenfield and brownfield. Besides creating economic value on its projects and generating equity returns on its investments, it also aims to secure regular activities for the group contracting activities in the EPC phases of its projects. Within its concessions activities, the group also holds concessions of seabed areas which contain polymetallic nodules and develops a technology to collect and process these polymetallic nodules containing nickel, cobalt, manganese and copper from the deep ocean floor. The main clients are energy suppliers, private equity firms, and government bodies.

Significant groups of products/services and revenue share

As DEME expands its global operations and extends its activities to new regions, the company adapts its approach to align with local contexts and prevailing circumstances.

The main fully consolidated entities, contributing 92% in total group turnover as on 31 December 2024, relate to the ESRS sector group 'Construction and Engineering' based on their NACE codes. This revenue is mainly derived from the Offshore Energy and Dredging & Infra segments.

Involvement in specific activities (Datapoints in thousands of euro):

Significant markets and geographies

Headcount by geographical area is outlined in Section 3 'Social' under 3.1.5.2. Metrics.

Strategic alignment and sustainability-related goals

Strategically, DEME has built up almost 150 years of expertise in dredging, marine infrastructure, offshore energy, and environmental services. The company maintains a pioneering approach, fostering innovation and adopting new technologies to drive sustainable progress. Its operations span the globe, with a significant revenue base in Europe and a growing presence internationally, reflecting its ambition to support the global energy transition.

DEME's sustainability strategy is built on two interdependent pillars:

• We EXPLORE sustainable business solutions by continuously challenging ourselves to enlarge our sustainable business portfolio and to align our business decisions with the Sustainable Development Goals where DEME can create the most impact.
• We EXCEL in our operations by maintaining and strengthening a sustainable performance in our daily operations.

DEME has established sustainability-related objectives and targets aligned with its material topics. The group aims to expand its portfolio in offshore renewable energy solutions and to explore innovative marine-based technologies for energy production, connection, and storage. Progress in the energy transition is monitored through alignment with relevant EU Taxonomy activities that support the energy transition. For 2024, this alignment is restricted to activity 4.3 'Electricity generation from wind power'. Each year, DEME reviews and updates its list of EU Taxonomy activities, which means that in the future, alignment with the energy transition will not be limited to activity 4.3 but may also include other relevant Taxonomy activities that support the energy transition. Currently, DEME has not set a specific target for this alignment.

Additionally, DEME aims to achieve climate-neutral operations by 2050 and improve the energy efficiency of its activities. Key targets include reducing its GHG intensity by 40% by 2030 relative to 2008 levels and ensuring that 17% of its total fuel consumption comes from low-carbon fuels by 2026.

Enhancing occupational health and safety is another critical objective for DEME, with a steadfast goal to eliminate Lost Time Injuries across all vessels, projects, sites, and offices worldwide. The key target for this objective is maintaining DEME's annual Worldwide Lost Time Injury Frequency Rate (Worldwide LTIFR) at a target value of ≤ 0.2, upheld until 2026.

Goals and targets related to the energy transition are associated with the Offshore Energy segment, while those concerning GHG emissions reduction and occupational health and safety enhancements are integrated across all segments. This holistic approach enables the company to effectively address significant sustainability-related impacts and risks.

Business model and value chain

DEME operates as a global leader in contracting services across dredging, marine infrastructure, offshore energy solutions, and environmental works. Its core business encompasses engineering, procurement, construction, and maintenance activities, complemented by concessions in offshore wind, infrastructure, dredging, and green hydrogen. By integrating these operations, DEME delivers value over diverse range of sectors, supporting its stakeholders with sustainable and innovative solutions.

Upstream value chain

To achieve its objectives, DEME depends on a robust upstream value chain. Critical inputs include EPC(I) project materials (such as steelwork, constructions, and subsea cable systems), fuel for its fleet and equipment, auxiliary and earthmoving machinery, charter vessels, shipyard construction and maintenance services, contingent workforce, and insurance services. These resources are secured and managed by specialized departments to ensure operational excellence. For instance, the procurement and contracting teams source project materials, the Bunkering Department oversees fuel procurement, and the Crewing Department ensures workforce availability. Similarly, the chartering team manages auxiliary vessels, while shipyard communication is handled by the Newbuild Department, and insurance matters are overseen by the insurance team.

Downstream value chain

DEME delivers comprehensive solutions specifically tailored to meet the needs of its clients. The Dredging & Infra segment's activities encompass capital and maintenance dredging, land reclamation, beach nourishment, and marine engineering infrastructure. The latter includes the engineering, design, and construction of marine infrastructures such as jetties and port terminals, as well as inland waterway infrastructure like locks and weirs, and civil works including bored and immersed tunnels. These services are primarily offered to port authorities and government entities.

The Offshore Energy segment provides engineering and contracting services for both the offshore renewables and non-renewables industry, primarily supporting utilities, turbine manufacturers and private equity firms. The services include among others the engineering, procurement, construction and installation of foundations, turbines, inter-array cables, export cables and substations. The segment also offers operations and maintenance, logistics, repair and decommissioning as well as salvage services to the market next to landfalls and civil works, rock placement, heavy lift and umbilicals.

DEME Environmental addresses environmental challenges through innovative soil remediation, brownfield development, sediment treatment, and water treatment services, supporting government bodies in achieving a circular economy by recycling polluted soils and water.

Additionally, DEME Concessions invests in, develops, and operates projects in wind, port infrastructure, and green hydrogen through specialized participations, serving energy suppliers, private equity firms, and public entities.

The downstream value chain reflects DEME's global impact, catering to private companies and public authorities at local, national, and international levels. This integrated approach positions DEME as a critical player in delivering infrastructure, environmental, and energy solutions, creating long-term benefits for clients, investors, and broader stakeholders.

Key inputs and outputs

Key inputs:

• EPC(I) project materials (steelwork, constructions, subsea cable systems)
• Fuel for fleet and equipment
• Auxiliary and earthmoving machinery
• Charter vessels
• Shipyard construction and maintenance services
• Contingent workforce
• Insurance services

Key outputs:

• Capital and maintenance dredging
• Land reclamation and beach nourishment
• Marine engineering infrastructure (jetties, port terminals, locks, weirs, tunnels)
• Offshore renewable and non-renewable energy installation and construction services
• Operations and maintenance, logistics, repair and decommissioning services
• Soil remediation and brownfield development
• Environmental dredging and sediment treatment
• Water treatment
• Concessions in offshore wind, port infrastructure, and green hydrogen

Interests and views of stakeholders

Stakeholder engagement approach

As a global company, maintaining good relationships with stakeholders is crucial. DEME believes in collaboration to enhance sustainability. We actively engage with stakeholders through continuous dialogue to understand their expectations, address concerns, and foster partnerships that drive sustainability.

Investors and shareholders focus on value creation, transparency, and strategic sustainability. Clients expect sustainable and innovative solutions. Employees prioritize safety and career development. Suppliers value transparency and long-term relationships, while other stakeholders emphasize collaboration, community strengthening, and compliance.

This stakeholder interaction informs and drives our sustainability efforts, ensuring alignment with their interests while guiding double materiality assessments.

The communication of perspectives and interests of (affected) stakeholders, especially concerning sustainability impacts, is managed through regular meetings of the Sustainability Board, relevant management teams, and the Board of Directors. Additionally, there is ongoing engagement and transparent communication with the investment community regarding our ESG performance.

Key stakeholder groups and engagement channels

Integration of stakeholder views into strategy and materiality assessment

General insights from DEME's stakeholder collaboration and results from an online, anonymous survey conducted in 2021, which aimed to set our sustainability priorities at that time, were used as a proxy for external stakeholder views to inform our input parameters for the Double Materiality Assessment (DMA).

The final scores per Impact, Risk & Opportunity (IRO) were obtained through a process of intensive stakeholder engagement including a review by the DEME sustainability team for consistent application of the scoring methodology across the different topics; a review by the Chief Human Resources Officer and Talent Manager regarding the social topics and a review by the strategic and legal team regarding all ESRS topics.

A stepwise validation of both the methodology and outcome of the DMA has been performed: this included a validation of the methodology as well as the provisional outcome by the Sustainability Board and the final approval of methodology and the outcome of the DMA by the Board of Directors.

Distinction between affected stakeholders and users of sustainability information

DEME responds to stakeholders transparently by measuring our sustainability performance and publishing the results annually.

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

List of Material Impacts, Risks and Opportunities (IROs)

The following table presents the sustainability-related impacts, risks, and opportunities identified and assessed as material through the DMA process. The table specifies whether the impacts are positive or negative.

All impacts listed are considered 'actual' impacts.

Characteristics of Material IROs

For each material IRO, the following characteristics are provided:

Energy Transition (Entity-specific)

• Type: Positive impact and Opportunity
• Time horizon: Medium to long-term
• Value chain location: Own operations (Offshore Energy segment)
• ESRS topic: Entity-specific

Greenhouse Gas Emissions (ESRS E1)

• Type: Negative impact and Risk
• Time horizon: Short, medium and long-term
• Value chain location: Own operations and value chain (Scope 1, 2 and 3)
• ESRS topic: E1 Climate change

Occupational Health and Safety (ESRS S1)

• Type: Negative impact
• Time horizon: Short-term (ongoing)
• Value chain location: Own operations (vessels and project sites)
• ESRS topic: S1 Own workforce

Linkage to Strategy and Business Model

All identified material impacts (both negative and positive), risks, and opportunities are directly linked to DEME's strategy and business model. The nature of DEME's projects requires significant energy consumption, primarily through the combustion of fuels in DEME's vessels and auxiliary floating equipment, which accounts for approximately 90% of the total Scope 1 and 2 GHG emissions. Conversely, the activities performed by the Offshore Energy segment facilitate and support the global energy transition. The negative impact on the health and safety of workers within DEME's workforce is primarily associated with the nature of DEME's operations and the types of tasks conducted by the crew and workmen on vessels and project sites.

Interaction with Business Model

The material topics interact with DEME's business model in the following ways:

Energy Transition: DEME operates as a global leader in contracting services across offshore energy solutions. The Offshore Energy segment provides engineering and contracting services for the offshore renewables industry, primarily supporting utilities, turbine manufacturers and private equity firms. Progress in the energy transition is monitored through alignment with relevant EU Taxonomy activities that support the energy transition. For 2024, this alignment is restricted to activity '4.3 Electricity generation from wind power'.

GHG Emissions: Vessels account for 90% of the current Scope 1 and 2 emissions, making them the largest contributor to DEME's emissions profile and thus a critical focus. DEME tackles this by integrating leading climate-proof technologies, focusing on energy performance and transitioning to less GHG-intensive fuel types. The company has set targets aligned with the International Maritime Organization's GHG Strategy. The objective is to cut the GHG intensity of operations by at least 40% per unit of work by 2030 compared to 2008, and to achieve climate-neutral operations by 2050 (Scope 1 & 2).

Occupational Health and Safety: The highest health and safety risks are associated with crew members and workmen on vessels and project sites, who constitute approximately 45% of the workforce. DEME is dedicated to achieving zero accidents and continuously improving its safety performance by promoting a culture of safety through the Safety DNA framework. The key target is maintaining DEME's annual Worldwide Lost Time Injury Frequency Rate (Worldwide LTIFR) at a target value of ≤ 0.2, upheld until 2026.

Resilience to Material IROs

Climate Resilience: DEME conducted a climate resilience analysis in 2024 using scenarios from the Intergovernmental Panel on Climate Change (IPCC). The climate scenario-based analysis conducted to assess the physical climate risk resilience of offshore structures designed and built by DEME indicated that structures, including cables and foundations, are resilient to the assessed climate risks under the IPCC's RCP 8.5 worst-case scenario. A 25-year operational lifespan was considered to ensure these structures can adapt to future climate conditions. The assessment confirmed moderate impacts on the structures, maintaining performance under changing conditions. Physical risks associated with structures engineered and built by DEME are considered negligible.

DEME already integrates climate data projections into its operational processes, enabling the company to optimize fleet operations, enhance crew safety, and minimize disruptions from extreme weather events.

Transition Risk Resilience: The analysis identifies transition risks for DEME's entire business under the RCP 2.6 scenario, such as increased regulatory costs and potential changes in market demand. However, DEME is strategically positioned to capitalize on additional opportunities within the renewable energy sector, thus contributing to the shift towards a low carbon economy. The aligned turnover related to EU Taxonomy activity 4.3 experienced an increase of nearly 20% between 2023 and 2024, demonstrating DEME's ability to expand its portfolio with new projects in the renewable energy sector.

Time Horizons

DEME has applied the definition of time horizons defined by ESRS 1:

• Short-term: reporting period of Financial Statements (1 year)
• Medium-term: from the end of the short-term reporting period up to 5 years
• Long-term: more than 5 years

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

Overview

DEME conducted a double materiality assessment (DMA) to identify and assess material impacts, risks and opportunities (IROs). This materiality assessment, covering both impact materiality and financial materiality, is detailed in section 1.4 of the Sustainability Statements.

Step-by-step methodology

The DMA process used a structured, bottom-up approach with the following steps:

Step 1: Scope and boundaries alignment

• Aligned scope and boundaries of the DMA with the CSRD and financial reporting scope based on the group's legal structure
• Conducted value chain mapping, considering DEME's business model, segments and activities, project-based operations, and geographic areas where DEME is active

Step 2: Topic identification

• Reviewed all potentially relevant Environmental, Social and Governance (ESG) topics informed by ESRS standards and complemented with topics pertinent to DEME's industry and stakeholders
• Sources included: ESRS list of topics (ESRS 1 AR 16), EFRAG IG1 'Materiality Assessment' implementation guidance, ESG questionnaires from rating agencies, and benchmarking with industry peers
• Further selected the most relevant sustainability topics through comprehensive consultations with internal experts
• A topic is deemed relevant if it has the potential to become material to DEME's activities and/or value chain from either an impact perspective, financial perspective, or both

Step 3: IRO identification

• Identified associated impacts, risks and opportunities (IROs) for each relevant topic
• Based on the 2022 materiality assessment conducted by an external expert and input from internal subject matter experts
• Examined DEME's operations and resulting impacts, considering own operations and, where feasible, both upstream and downstream elements of the value chain

Step 4: Scoring

• Applied a consistent scoring methodology, including materiality thresholds to determine which IROs and associated sustainability topics are material for DEME
• IROs were rated and recorded based on a specific scale measuring their actual or potential effects and likelihood
• Both qualitative and quantitative measures were used to score the IROs, resulting in impact and financial materiality scores depending on the nature of the IRO

Step 5: Threshold application

• Applied thresholds to determine the materiality of the IROs, based on their impact and financial materiality scores

Validation process

• Stepwise validation of both methodology and outcome by the Sustainability Board
• Validation of methodology and provisional outcome by the Sustainability Board
• Final approval of methodology and outcome by the Board of Directors

Inputs to the assessment

Internal sources:

• Internal subject matter experts consulted throughout different stages
• 2022 materiality assessment conducted by an external expert
• Environmental Risk Matrix at project level (part of QHSE-S Management Process)
• Input from various departments including Opportunity and Risk Management, Internal Audit, Digital Office, QHSE, Compliance, and Legal

External sources:

• ESRS standards (ESRS 1 AR 16)
• EFRAG implementation guidance IG1 'Materiality Assessment'
• ESG questionnaires from rating agencies
• Industry peer benchmarking
• Results from online, anonymous stakeholder survey conducted in 2021 (used as proxy for external stakeholder views)
• General insights from DEME's stakeholder collaboration

Sector-specific considerations:

• Topics pertinent to DEME's industry and stakeholders
• Specific insights from Environmental Risk Matrix for pollution, water and marine resources, biodiversity and ecosystems, and resource use within circular economy

Scoring criteria for impact materiality

For actual negative impacts:

• Materiality based on severity of the impact
• Severity assessed using three parameters: 'scale', 'scope', and 'irremediable character'

For potential negative impacts:

• Materiality based on both severity and likelihood
• Higher severity (including higher scale, scope, and irremediability) and higher likelihood result in higher score

For actual positive impacts:

• Materiality determined by scale and scope of the impact

For potential positive impacts:

• Materiality depends on scale, scope, and likelihood

Impact materiality threshold:

• Defined through balanced management judgment
• Takes into account specific context and circumstances of the company and its stakeholders

Scoring criteria for financial materiality

Financial materiality assessed based on magnitude of effects multiplied by likelihood. Both magnitude and likelihood evaluated using a scoring matrix.

Magnitude of effect:

• Measured in terms of either financial or reputational effects, depending on nature of risk or opportunity
• For financial effects:
  • Recurring risks/opportunities (potential impact for 5 consecutive years): impact determined in terms of net profit
  • One-off events: impact determined in terms of equity
• For reputational effects: adverse or positive effect assessed on scale of 1 to 5
• Scope considered the project-based nature of DEME to determine extensiveness of perimeter and context

Likelihood:

• Assessed for both risks and opportunities
• Evaluated using scoring matrix

Threshold for materiality

Impact materiality threshold:

• Defined through balanced management judgment
• Considers specific context and circumstances of company and stakeholders

Financial materiality threshold:

• Established in absolute figures for both recurring risks/opportunities and one-off events
• For recurring risks/opportunities: based on average net profit from 2019 to 2023 (excluding 2020 due to non-recurring COVID-19 effects)
• For one-off events: based on equity levels as of 31 December 2022 and 31 December 2023

Frequency and last review

• DMA conducted in 2024 (first year of CSRD reporting)
• DEME has been performing materiality assessments since 2020, but methodology evolved under current CSRD legislation
• Previous assessments used 'business impact' and 'importance to stakeholders' dimensions
• 2024 assessment reassessed and modified evaluation based on double materiality requirements of ESRS 1 and EFRAG IG1

Use of value chain mapping

Value chain mapping was conducted as part of Step 1, considering:

• DEME's business model
• Business segments and activities (Offshore Energy, Dredging & Infrastructure, Environmental, Concessions)
• Project-based nature of DEME's operations
• Geographic areas where DEME is active

The scope of the analysis considered DEME's own operations and, where feasible, extended to both upstream and downstream elements of the value chain.

Value chain approach:

• Own operations: activities performed by fully consolidated entities and joint operations
• Upstream value chain: joint ventures, associates, suppliers, contractors
• Downstream value chain: clients, end-users of projects

Application to material topics:

• Occupational Health and Safety (OHS): confined to own operations by definition
• Greenhouse gas emissions: includes significant amount of value chain data (Scope 3 emissions)
• Energy transition: restricted to own operations of Offshore Energy segment

IRO categorization

Each IRO categorized based on:

• Type: positive impact, negative impact, risk, or opportunity
• Likelihood: actual or potential
• Business activity: Offshore Energy, Dredging & Infrastructure, Environmental, Concessions
• Location in value chain: own operations, upstream, or downstream
• Time horizon: short-term (reporting period), mid-term (up to 5 years), or long-term (more than 5 years)

Material topics identified

Based on the DMA analysis, three topics with potential material impact at group level were identified:

1. Energy transition (entity-specific)

   • Material positive impact
   • Material opportunity

2. Greenhouse gas emissions

   • Material negative impact
   • Material risk (transition risk)

3. Occupational Health and Safety (own workforce)

   • Material negative impact
   • Not financially material

Climate-specific process

For climate-related impacts, risks and opportunities, DEME conducted a climate resilience analysis in 2024 using IPCC scenarios:

Physical risks (RCP 8.5 worst-case scenario):

• 4-step approach at project level:
  1. Identification of services and structures at risk with expected operational lifetime
  2. Preliminary screening based on project location, identifying climate hazards
  3. Climate risk vulnerability assessment based on likelihood and magnitude
  4. Elaboration of adaptation solutions plan where risks appear significant
• Used geospatial data at regional level for operational locations
• Considered 25-year operational lifespan for structures
• Applied risk matrix to classify physical risk levels as insignificant, low, moderate, high, or extreme

Transition risks (RCP 2.6 best-case scenario):

• Applied with broad analytical scope, encompassing entire business
• Identified key transition risks including regulatory and compliance pressures, reputational risks, market and technological risks

Process for specific environmental topics

For pollution, water and marine resources, biodiversity and ecosystems, and resource use within circular economy:

• Followed same procedural steps and methodologies
• Informed by specific insights from Environmental Risk Matrix at project level (part of QHSE-S Management Process)

Governance and documentation

Proper governance established and each step documented to ensure qualitative and consistent DMA. Scoring of IROs based on supportable evidence and relies as much as possible on objective information.

Transition plan for climate change mitigation

Target year for net zero / carbon neutral

DEME is committed to achieving carbon neutral operations by 2050 (Scope 1 & Scope 2).

Scope of the plan

The transition plan focuses on DEME's vessel fleet, which accounts for approximately 90% of DEME's total global GHG emissions for Scope 1 and 2. The plan applies to the group's fleet of more than 100 vessels, operating across DEME's four segments: Offshore Energy, Dredging & Infra, Environmental, and Concessions.

GHG reduction milestones

Intermediate GHG intensity target: Reduce 40% of the fleet's GHG emissions per dredged m³ or installed MW by 2030 compared to the base year 2008.

Low-carbon fuels target: Achieve 17% of low carbon fuels consumed (energy based) in comparison to total consumed fuels (energy based) by 2026, with baseline value of 2% in 2021.

Interim targets for low-carbon fuels:

• 2022: 5%
• 2023: 8%
• 2024: 11%
• 2025: 14%
• 2026: 17%

Alignment with Paris Agreement / SBTi validation

DEME has not disclosed specific alignment with 1.5°C pathways or SBTi validation status. The company states: "DEME has not yet compiled its GHG emissions strategies into a Transition Plan as specified in ESRS E1. However, we intend to align DEME's Transition Plan with the forthcoming Corporate Sustainability Due Diligence Directive (CSDDD) and any future clarifications or guidelines issued in the meantime."

Decarbonization levers

DEME's decarbonization roadmap is based on three levers:

1. Operational Efficiency

Enhancing productivity while minimizing fuel consumption through:

• Increasing payload capacity
• Sailing at ecological speeds when feasible
• Ensuring just-in-time arrivals
• Eco-maneuvering, hull cleaning, turning off non-essential consumers on board

2. Technical Efficiency

Delivering more energy on board with reduced fuel usage through:

• Waste heat recovery systems converting exhaust heat into electrical energy
• Utilization of flywheels and battery packs
• Measures to boost propulsion efficiency
• Propulsion optimization through combinator curves and propeller blade design
• Variable frequency drives
• Hybrid power plants (e.g., 'Yellowstone' equipped with 1 MWh Li-ion battery pack)

Investment commitment: In 2023, the group launched a five-year investment plan of approximately 30 million euros to integrate fuel-saving technologies throughout the fleet.

3. Fuel Shift

Transitioning to less GHG-intensive fuel types:

Short and Medium-Term (Low Carbon Fuels):

• (bio)LNG and blended biofuels
• Dual-fuel technology allowing vessels to operate on both LNG and conventional fossil fuels
• 'Yellowstone' is the first vessel in the fleet prepared for (green) methanol and the first dual fuel fallpipe vessel in the industry

Medium and Long-Term (Future Net-Zero Fuels, (Net) Zero Carbon Fuels):

• Initial pilot projects being conducted to gain experience with future fuels
• Significant uncertainty remains regarding which specific fuels will dominate future markets

CapEx / investment commitments

• 30 million euro five-year investment plan (initiated 2023) for fuel-saving technologies
• Investment costs related to specific fuel-saving technologies in newly constructed vessels included in DEME's investment plan, mainly affecting from 2025 onwards with limited expenditure in 2024
• All 2024 investments are recurring; additional OpEx and CapEx expenditures specifically related to the decarbonization roadmap are not recorded separately
• DEME includes sustainability and ESG impact in all business cases and budget proposals
• "There remains a significant level of uncertainty regarding the specific fuels that will dominate the future market, their availability, and the capacity for bunkering. Consequently, estimating the precise investment required to fully prepare DEME's fleet for the transition to these future fuels is challenging."

Locked-in emissions and stranded asset analysis

DEME states: "It is crucial to further integrate and align our decarbonization plan with DEME's overall business strategy and financial planning. This will allow us to better understand how potential locked-in GHG emissions from key assets might affect current and future GHG emissions reduction targets."

No detailed locked-in emissions or stranded asset analysis is provided in the excerpts.

Use of carbon credits / removals

DEME's two GHG reduction targets "are considered gross targets; hence, GHG removals, carbon credits, or avoided emissions, will not be taken into account."

Section 2.4.10 states: "DEME has not invested in GHG removal projects or purchased carbon credits in 2024."

Buildings decarbonization

DEME is transforming its headquarters campus:

• In February 2025, started demolishing three large office buildings accounting for 50% of total fuel consumption of the entire DEME campus
• New building will feature fully glazed main facade with aluminum 'climate curtain'
• Six office buildings interlinked with heating/cooling network, equipped with heat pumps and heat/cold storage using geothermal energy
• Multi-year plan to shift away from fossil fuel heating to green energy
• DEME Labs (opened 2023) fitted with solar panels
• Approximately 340 electric vehicle charging points in designated car parks

Progress on HQ emissions: GHG emissions reduction at headquarters from 59 kgCO2e/GJ (baseline) to 26 kgCO2e/GJ

Policy framework

DEME has established a comprehensive Energy & Greenhouse Gas Emissions Policy that:

• Outlines objectives concerning energy efficiency and GHG emissions reduction
• CEO holds highest level of accountability for policy implementation
• Commits to ISO 14001, ISO 14064-1, and ISO 50001 standards
• Identifies five Significant Energy Users (SEUs): vessels, buildings, machinery and equipment, transport of people, and purchasing goods and services

Scope 3 approach

DEME's indirect GHG emissions (Scope 3) are mainly attributed to:

• Procurement of goods and services
• Capital goods
• Fuel- and energy-related activities not in Scope 1 or 2
• Business travel
• Upstream leased assets

"Regarding value chain emissions, our focus in the coming years will include enhancing data collection and quality, establishing comparable baselines, and further enriching our knowledge and expertise related to GHG emissions in our value chains through supplier assessment tools."

DEME initiated engagement with core and strategic suppliers using a supplier assessment tool to evaluate sustainability maturity, including environmental and GHG reduction aspects.

Climate resilience and financial impacts

DEME uses a dual approach to evaluate physical climate risks:

1. Assessing risks related to maritime operations and vessel operability
2. Evaluating resilience of structures (foundations, cables) delivered through offshore EPCI projects

"DEME's vessels are the company's main assets. A key result of the climate resilience analysis indicates that climate-related impacts may affect all of DEME's maritime operations through increased project downtime due to extreme weather conditions, leading to delays, higher costs, and safety risks."

Mitigation measures include:

• Monitoring weather conditions and using advanced forecasts
• Proactive operational adjustments
• Weather delay clauses in contracts
• Casualty insurance covering assets damage from extreme conditions

Financial reporting impact: "For the year ended 31 December 2024, no material impact on financial reporting judgment and estimates arising from climate change were identified and as a result the valuations of assets and liabilities have not been significantly impacted by climate change risks. Further, the group concludes that the climate change risk does not impact the going concern assessment for December 2024."

Challenges and limitations

DEME acknowledges several challenges:

• "The uptake quantity of low carbon fuels in 2024 indicates that sustaining these efforts on a voluntary basis presents substantial challenges"
• "Limited market for low carbon fuels in our operational region and the fact that there is no widespread adoption in our industry are significant obstacles"
• "Persistent uncertainties regarding the availability and scalability of new technologies, determining which specific (net) zero carbon fuel types will dominate future markets, their availability and the capacity for worldwide bunkering"
• "DEME has not yet established absolute outcome-oriented targets for GHG emissions reduction"

Policies related to climate change mitigation and adaptation

DEME has established one comprehensive policy addressing climate change mitigation. The company explicitly states that it currently does not have a specific policy on climate change adaptation.

Energy & Greenhouse Gas Emissions Policy

Scope: The policy is inclusive of all activities and applies universally across the organization, encompassing both upstream and downstream value chains.

Governance: The CEO holds the highest level of accountability for policy implementation. The DEME energy management team allocates resources to meet energy and emission targets.

Key content and principles:

The policy outlines DEME's objectives concerning energy efficiency and the reduction of GHG emissions. Specifically, DEME aims to:

• Enhance energy efficiency within its operations
• Achieve climate-neutral operations by 2050 (Scope 1 & Scope 2)
• Reduce GHG emissions from the operational fleet by 40% by 2030 compared to 2008 per unit of work
• Mitigate GHG emissions across project value chains (Scope 3)

The policy emphasizes collaboration across various departments, focusing on minimizing environmental impact and enhancing energy efficiency.

Under DEME's ISO 50001 Energy Management System, five significant energy users (SEUs) have been identified: vessels, buildings, machinery and equipment, transport of people, and purchasing goods and services. This framework integrates energy management with GHG emission management.

The DEME energy management team's strategy involves anticipating legislative changes, staying updated on new methods and measures, identifying energy-saving opportunities in processes and projects, and maintaining transparency about emissions.

DEME periodically reviews and adjusts performance indicators for its SEUs to maintain relevance and effectiveness. The annual Energy & Greenhouse Gas Emissions Management Review establishes the action plan, aligning it with significant energy users and considering internal and external contexts.

Alignment with international standards:

The policy commits to adhering to multiple standards:

• ISO 14001 (Environmental Management System)
• ISO 14064-1 (Greenhouse Gas Reporting & Verification)
• ISO 50001 (Energy Management System)

Public availability: Not disclosed.

Monitoring implementation:

DEME periodically reviews and adjusts performance indicators for its significant energy users to maintain relevance and effectiveness. The annual Energy & Greenhouse Gas Emissions Management Review establishes the action plan and prioritizes key energy users. The plan is implemented across various levels of the organization, with stakeholders and responsible individuals informed through structured processes.

---

Climate change adaptation:

The Energy & Greenhouse Gas Emissions Policy currently does not contain a specific policy on climate change adaptation.

Actions and resources in relation to climate change policies

Decarbonization Roadmap

DEME has implemented a roadmap based on three decarbonization levers:

1. Operational Efficiency

• Scope: Own operations (vessel fleet)
• Actions include: Increasing payload capacity, sailing at ecological speeds when feasible, and ensuring just-in-time arrivals
• Time horizon: Ongoing
• Link to policy: Energy & Greenhouse Gas Emissions Policy
• Expected outcome: Decrease in GHG intensity

2. Technical Efficiency

• Scope: Own operations (vessel fleet)
• Actions include: Incorporating fuel-saving technologies
• Time horizon: Ongoing
• Link to policy: Energy & Greenhouse Gas Emissions Policy
• Expected outcome: Decrease in GHG intensity

3. Fuel Shift

• Scope: Own operations
• Time horizon: Short to mid-term for transitional fuels; medium to long-term for zero carbon fuels
• Actions: Concentrating on integrating transitional low-carbon fuels such as (bio)LNG and (blends of) biofuels
• Link to policy: Energy & Greenhouse Gas Emissions Policy and Sustainability-Linked Loan Agreements since 2022 (detailed in Chapter 06, Note 21)
• Challenges noted: Limited market for low carbon fuels in operational region; uptake quantity of low-carbon fuels in 2024 indicates substantial challenges; no widespread industry adoption; persistent uncertainties regarding availability and scalability of new technologies; uncertainties about which (net) zero carbon fuel types will dominate future markets and their bunkering capacity

Value Chain Emissions Actions

• Scope: Upstream value chain (Scope 3)
• Time horizon: Coming years
• Actions planned:
  • Enhancing data collection and quality
  • Establishing comparable baselines
  • Further enriching knowledge and expertise related to GHG emissions in value chains through supplier assessment tools
• Link to policy: Energy & Greenhouse Gas Emissions Policy aim to mitigate GHG emissions across project value chains (Scope 3)

Transition Plan Development

• Status: DEME has not yet compiled its GHG emissions strategies into a Transition Plan as specified in ESRS E1
• Time horizon: Future
• Planned action: Align DEME's Transition Plan with the forthcoming Corporate Sustainability Due Diligence Directive (CSDDD) and any future clarifications or guidelines issued in the meantime

Resources Allocated

• Financial: Sustainability-Linked Loan Agreements since 2022 (further detailed in Chapter 06. Financial Statements – Note (21) Interest-bearing debt and net financial debt) - specific amounts not disclosed in excerpts
• Non-financial: Not specifically quantified in excerpts

Integration with Business Strategy

• Action: Further integrate and align decarbonization plan with DEME's overall business strategy and financial planning
• Purpose: Better understand how potential locked-in GHG emissions from key assets might affect current and future GHG emissions reduction targets
• Time horizon: Ongoing priority

Targets related to climate change mitigation and adaptation

DEME has established the following quantified targets related to climate change mitigation:

Target 1: GHG Intensity Reduction by 2030

Strategic pillars for achieving this target:

• Enhancing operational efficiency
• Improving technical performance
• Transitioning to more sustainable fuels

Target 2: Low Carbon Fuels Uptake by 2026

Long-term Target: Climate Neutrality by 2050

Scope 3 Value Chain Emissions

DEME has not yet set an absolute target for Scope 3 GHG emissions. The company is focusing on:

• Enhancing data collection and quality
• Establishing comparable baselines
• Engaging core and strategic suppliers through supplier assessment tools
• Progress metric: In 2024, engaged with suppliers representing more than a quarter of total annual procurement spend

Energy consumption and mix

Scope and methodology

Total energy consumption is measured in megawatt-hours (MWh), encompassing all energy consumed worldwide within the organization's operational control during the reporting period, aligning with the boundaries used for reporting GHG Scope 1 and Scope 2 emissions. Standardized conversion factors from the UK's Department for Environment, Food and Rural Affairs (Defra) are applied to ensure consistency and accuracy in measurement.

DEME does not consume energy directly from coal or nuclear sources, resulting in a reported value of zero for these energy types in 2024.

Energy consumption and mix (MWh)

Energy intensity

The energy intensity for 2024 was 909 MWh per million euro of net revenue.

Energy production

In 2024, DEME's total renewable energy production amounted to 2,602 MWh. This energy was generated from renewable sources, specifically wind and solar, at DEME's headquarters. DEME does not produce energy from non-renewable sources.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 & Scope 2 emissions

Worldwide Greenhouse Gas Emissions (Scope 1 & Scope 2) by significant energy user (2024):

Total Scope 1 & 2 emissions (kt CO₂e):

The report states that >90% of Scope 1 and Scope 2 emissions are derived from DEME's marine equipment and fleet. Buildings, machinery and equipment, and transport of people constitute the remaining <10%.

GHG intensity reduction progress:

The company tracks GHG intensity as greenhouse gas emissions per dredged cubic meter or installed megawatt. DEME has a target to reduce GHG intensity by 40% by 2030 using 2008 as the baseline year.

Low carbon fuels consumption (% of total volume, energy-based):

The decrease in low carbon fuel consumption in 2024 is attributed to limited availability of low carbon fuels in DEME's main regions of operations and non-generalized adoption in the industry.

Scope 2 breakdown (location-based vs market-based)

The report does not provide a separate breakdown of Scope 2 emissions into location-based and market-based figures.

Scope 3 emissions

Significant Scope 3 categories identified:

In 2024, DEME determined its significant Scope 3 categories. The majority of Scope 3 emissions in the project value chain come from:

• Purchase of goods and services (Category 1)
• Capital goods (Category 2)
• Upstream fuel- and energy-related activities (Category 3)
• Business travel (Category 6)
• Upstream leased assets (Category 8)

The report states: "In 2024 we have determined our significant Scope 3 categories to calculate our worldwide Scope 3 emissions" but does not disclose quantified Scope 3 emissions for the reporting year. DEME notes it plans to set dedicated targets and actions in due course.

Total GHG emissions

No total GHG emissions figure (Scope 1 + 2 + 3) is disclosed, as Scope 3 emissions are not yet quantified.

GHG intensity

GHG intensity is measured per unit of work (dredged cubic meter or installed megawatt), with 30% reduction achieved by 2024 versus the 2008 baseline.

Methodology and scope notes

Scope and boundaries: The report notes: "For 2024 numbers, scope, boundaries, and calculation methodology are reported according to CSRD, ESRS, and the EU Taxonomy Regulation." This is the first year reporting under CSRD.

Limited assurance: "The KPI's related to Headcount, Ratio male/female, GHG emissions and EU Taxonomy are subject to limited assurance for the first time for fiscal year 2024."

Scope 1 & 2 emissions reporting follows ISO 50001 energy management framework. The company identifies five significant energy users (SEUs): vessels, buildings, machinery and equipment, transportation of personnel, and procurement of goods and services.

EU ETS: "On 31 December 2024, no EU ETS emission allowances or renewable energy certificates are included in the group's consolidated balance sheet, nor has the group recognized a liability related to greenhouse gas emissions." DEME will commence reporting emissions under the EU ETS MRV from 1 January 2025, with 100% of offshore ship emissions reported in 2027 to be surrendered by 2028.

Biogenic CO₂: Not disclosed separately.

Regulated emissions: No EU ETS or other regulated emissions quantified for 2024.

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

Phase-in exemption applied

DEME applies the phase-in provisions outlined in ESRS 1 'General Requirements' (Section 10.4 - Transitional Provision) and Appendix C of ESRS 1 (List of Phased-in Disclosure Requirements).

As stated in the phase-in requirements table:

Current financial reporting status

In section 2.2.3 (Connection to the financial statements - climate transition risk), DEME states:

"No current material impacts on financial reporting judgement and estimates arising from climate transition risk were identified for the financial year 2024. Reference is also made to section 2.4.12. Anticipated financial effects from material physical and transitional risks and potential climate-related opportunities."

DEME has not recognized a provision related to emission allowance obligations in the consolidated statement of financial position, nor did the group account for a liability related to GHG emissions.

Cross-reference

The company references Chapter 06. Financial Statements - section disclosures related to climate related matters and Chapter 06. Financial Statements - Note (21) Interest-bearing debt and net financial debt, which mentions Sustainability-linked Loan Agreements since 2022.

Policies related to own workforce

DEME's policies related to own workforce are disclosed across multiple sections. The company applies phase-in provisions, limiting S1 disclosures to employees only (excluding non-employee workers).

Human Rights Policy

Scope:

• Applies to all directors and employees, whether full-time, part-time, permanent, or temporary
• Covers DEME's operations and business partners

International standards alignment:

• UN Guiding Principles on Business and Human Rights
• International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• United Nations Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social and Cultural Rights
• ILO's fundamental conventions

Key content/principles:

• Business conducted with respect, integrity, and compliance with all applicable laws and regulations
• Zero tolerance for slavery, child labor, forced labor, modern slavery or human trafficking
• Prohibition of hiring individuals under 18 for hazardous work, with age verification measures
• Commitment to living wages, working conditions and working time
• Freedom of association, including forming and joining trade unions, and right to collective bargaining
• Elimination of discrimination and harassment on grounds including racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction, social origin
• Equal opportunities in recruitment, career development, training, and rewards
• Occupational health and safety protections
• Compensation with wages and benefits meeting or exceeding legal requirements
• Voluntary work with right to terminate employment

Monitoring implementation:

• Procedures and controls to prevent human rights violations
• Age verification at recruitment
• Payroll checks to prevent child labor and forced labor
• Confidential counselors appointed for informal resolution through discussions, interventions or reconciliation attempts

QHSE-S Policy (Quality, Health, Safety, Environment and Security)

Scope:

• Applicable to all employees within the organization

Governance:

• Oversight responsibility lies with the Strategic Operations Director

International standards alignment:

• ISO 9001 (Quality Management System)
• Safety, Health, and Environmental Checklist for Contractors (SCC)
• International Safety Management Code (ISM Code)
• International Ship & Port Facility Security Code (ISPS Code)
• ISO 45001 (Occupational Health and Safety Management System, including workplace well-being)
• Safety Culture Ladder

Key content/principles:

• Zero Harm Goal to minimize negative impacts on workforce
• Risk-based approach to identify, reduce, and control risks in all aspects of work
• Workplace accident prevention
• Seven pillars of DEME's Safety DNA
• Culture where employees look out for one another and uphold best safety practices

Monitoring implementation:

• Annual QHSE campaigns (Safety Moment Day, Safety Week)
• Safety Committee meetings
• Risk review meetings
• Toolbox Talks (daily)
• Employee Performance Reviews
• QHSE Seminars and Meetings
• Apprise internal program for reporting observations, suggestions, comments and ideas
• Project-specific risk management meetings
• Each operating segment has annual QHSE Action Plan

Public availability:

• Policy is printed and displayed in offices and aboard vessels

Code of Conduct (regarding conflicts of interest)

Scope:

• Board of Directors and Executive Committee members

Governance:

• Published by the Board of Directors in the Charter (Articles 2.12 and 4.8)

Key content/principles:

• Policy on transactions between DEME Group NV or affiliated companies and Board/Executive Committee members (or their close relatives) that may give rise to conflicts of interest

Code of Conduct (regarding financial transactions)

Scope:

• Applicable to prevention of market abuse

Governance:

• Published by the Board of Directors in the Charter (Section 7.3)

International standards alignment:

• Aligned with Regulation (EU) no. 596/2014 on market abuse

Whistleblowing Policy

Key content/principles:

• Provides secure and confidential mechanisms for reporting irregularities
• Robust whistleblowing protection mechanisms
• Part of safeguards for reporting irregularities

Additional policy notes:

DEME states it has no specific policy related to inclusion and positive action for people from groups at particular risk of vulnerability within its workforce, though it commits to creating an inclusive culture with equal opportunities.

Taking action on material impacts on own workforce

Material topic: Occupational Health and Safety

DEME consistently strives to improve its safety performance and practices through continuous evaluation and enhancement efforts, guided by the seven pillars of DEME's Safety DNA and targeting a Zero Harm Goal.

Corporate-level initiatives implemented in 2024

Scope: Own workforce (all employees, offices, sites, and vessels)

Time horizon: Annual (2024)

Communication Plan and New Year's Resolution

• Launched at the beginning of 2024
• Traditional 'New Year's Resolution' campaign

Safety Week

• Theme: 'Gravity doesn't take a break'
• Action: In-depth analysis of near-misses, hazardous situations, and High Potential (HIPO) incidents related to people or objects falling from height
• Approach: DEME reviewed and summarized data and encouraged colleagues involved in HIPO situations to share their experiences
• Tools: Safety videos utilized in numerous toolbox meetings, reaching thousands of participants
• Topics covered: Open manholes, hand safety, standard lifts, maritime operations, dropped objects, and earthworks

Safety Moment Day

• Participation: More than 270 'Safety Success Stories' submitted by nearly 140 participating projects, vessels, and other locations
• Focus areas: Identifying hazards, establishing safe access, and technology-driven safety achievements
• Outcome: Most outstanding Success Stories were presented during the Safety Moment Day itself

Ongoing communication and consultation tools

• Annual QHSE campaigns (Safety Moment Day and Safety Week)
• Safety Committee meetings
• Risk review meetings and project-specific risk management meetings
• Daily Toolbox Talks for open communication about QHSE issues
• Employee Performance Reviews
• QHSE Seminars and Meetings
• Apprise program: Internal reporting system for observations, suggestions for improvements, comments and ideas (available to every DEME employee)

Frequency: Varies by tool - monthly, weekly, or daily depending on project milestones and specific requirements

Operating segment-level actions

Each operating segment of DEME has an annual QHSE Action Plan detailing the year's goals, initiatives, and actions.

Link to policies

All actions support DEME's Occupational Health and Safety policy, which strives to minimize negative impacts on the workforce and achieve the Zero Harm Goal. Responsibility lies with the Strategic Operations Director.

Compliance framework

• ISO 9001 (Quality Management System)
• SCC (Safety, Health, and Environmental Checklist for Contractors)
• ISM Code (International Safety Management Code)
• ISPS Code (International Ship & Port Facility Security Code)
• ISO 45001 (Occupational Health and Safety Management System)
• Safety Culture Ladder

Note: No quantified financial or human resources allocated to these actions are disclosed.

Characteristics of the undertaking's employees

Total workforce:

In 2024, the group's workforce reached a total of 5,822 people (headcount) at the end of the year, marking a 5% increase from the previous year.

Gender composition:

Workforce composition:

More than 40% of DEME's team consists of crew members operating DEME's specialized fleet of more than 100 vessels. The company continuously upgrades its fleet and introduces new concepts to enhance efficiency and performance. The expertise and dedication of the crew are critical in this demanding environment.

Talent acquisition and retention:

DEME continued to invest in retaining and attracting talent in 2024 to support its growth. Among several ongoing initiatives, the most prominent remains DEME's 'Where Next?' campaign - an international employer branding and recruitment program featuring targeted career days, participation in job fairs, and other events. In 2024, DEME welcomed more than 400 new talents.

Scope and assurance:

The KPI's related to Headcount and Ratio male/female are subject to limited assurance for the first time for fiscal year 2024.

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

Disclosure status

DEME has applied the phase-in provisions outlined in ESRS 1 'General Requirements' (Section 10.4 – Transitional Provisions) and Appendix C (List of Phased-in Disclosure Requirements). For the 2024 reporting period, all disclosures related to non-employee workers in own workforce are omitted.

As stated in Section 1.1.5.5 Phase-in requirements and transitional provisions:

"DEME utilizes the phase-in provisions outlined in ESRS 1 'General Requirements' (section 10.4 - Transitional Provision) and Appendix C (List of Phased-in Disclosure Requirements). Therefore, the disclosures of all requirements related to S1 – own workforce are limited to DEME 'own workforce – employees'."

The following specific metrics are explicitly noted as omitted:

Scope definition

DEME defines its 'own workforce' as including:

• Employees: persons in an employment relationship with the undertaking
• Non-employee workers: persons not in an employment relationship but whose work is controlled by DEME and who perform roles similar to employees or are engaged in core business

For 2024, only employee data is reported. Non-employee workers will be included in future reporting periods as the phase-in period concludes.

Future reporting commitment

DEME acknowledges that non-employee workers (contractors, agency workers, self-employed) working on vessels and project sites face similar occupational health and safety risks as employees. The company states that "health and safety risks apply regardless of employment type - whether they are employees, self-employed, or personnel provided by third-party contractors, as long as they are crew members on vessels and project sites."

Metrics for non-employee workers are expected to be disclosed in subsequent reporting periods following the transitional phase-in timeline.

Diversity metrics

Gender diversity:

Board diversity:

Ms. Gaëlle Hotellier and Ms. Marieke Schöningh have been appointed to serve as independent directors of DEME's Board each for a four-year term. This brings the total number of female directors to four out of eleven while maintaining representation across four nationalities, further enhancing the gender and international diversity of DEME's Board of Directors.

Scope and assurance:

The KPI's related to Ratio male/female are subject to limited assurance for the first time for fiscal year 2024.

Adequate wages

DEME's Human Rights Policy includes commitments regarding living wages, working conditions and working time, freedom of association, non-discrimination and occupational health and safety.

However, the company does not disclose a specific living wage benchmark used to assess whether employees earn an adequate wage. The disclosure states:

"DEME compensates employees with wages and benefits that meet or exceed legal requirements and ensures compliance with laws related to overtime."

This indicates that DEME's wage adequacy is benchmarked against legal minimum wage requirements, not a living wage standard.

No coverage data, methodology, geographic scope, or living wage targets are disclosed. The company does not provide information on what proportion of the workforce was assessed against a living wage benchmark, or any commitment to implement living wage assessments in the future.

Social protection

Retirement benefit obligations

DEME Group provides retirement benefits to employees across multiple countries, with obligations primarily relating to Belgian employees.

Pension plan types:

• Defined benefit plans - funded through group insurance branch 21 or company pension fund

• Defined contribution plans (Belgian employees) - entirely employer funded through group insurance branch 21, with legal interest rate guarantees:

  • 3.25% for contributions paid until 1 October 2016
  • Variable rate based on Belgian 10-year state bond for contributions from 2016 onwards (minimum 1.75%, maximum 3.75%)
  • Guaranteed rate increased from 1.75% to 2.50% for future projections as of 31 December 2024

• Netherlands defined benefit schemes - all plans insured with authorized insurance company, closed for new entries and accruals

Retirement benefit obligations by geography (in thousands of euro):

Funded status (Belgium and Netherlands) (in thousands of euro):

Contributions and costs (in thousands of euro):

Coverage: The document confirms retirement benefit schemes exist for Belgian and Netherlands employees. No explicit percentage coverage of total workforce is disclosed.

Public vs. private schemes: All disclosed arrangements are private employer-sponsored pension schemes (defined benefit and defined contribution plans).

Other social protection

No specific disclosure provided regarding coverage for other major life events including sickness, maternity, paternity, disability, unemployment, or employment injury.

Training and skills development metrics

Lifelong learning approach:

At DEME, we prioritize lifelong careers and lifelong learning. To empower our people, we invest heavily in tailored training programs that allow them to develop their expertise, shape their careers, and achieve their ambitions. We support our employees' professional growth by providing resources, opportunities, and support for their development.

Training program structure:

In 2024, DEME launched a revamped training program offering various formats, including classroom sessions, workshops, webinars, and e-learning courses. Our training is structured into five learning journeys, including leadership and technical training modules.

Specialized training initiatives:

• Safety training hubs: DEME has established local safety training hubs in various countries to organize company-specific safety training.

• Management development programs: Given DEME's growth and increasing presence in the US, Middle East and Asia, DEME also organizes management development programs with training courses for first-time, seasoned and strategic leaders, complemented with an accelerated track. DEME's internationalization is reflected in these programs.

• Career transition support: For seafarers looking to transition to shore-based roles, we make every effort to accommodate their aspirations.

• Technical summits: In 2024, the company once again organized the 'Captains and Chief Engineers' Summit, as well as the 'Chief Electrician Summit'. DEME recognizes the vital role the crew plays in contributing ideas that drive the company's sustainability efforts. Their firsthand experience on vessels and projects is invaluable in this process.

Health and safety metrics

Coverage by health and safety management system

96% of DEME employees are covered by an ISO 45001-based health and safety management system.

Fatalities

Recordable work-related accidents

Methodology notes:

• The TRIR quantifies workplace incidents requiring medical attention beyond first aid, including fatalities, lost time injuries, restricted work cases, and medical treatment cases. The TRIR is computed by multiplying the number of recordable accidents by 1,000,000 and dividing by the total hours worked (based on 2,779 hours per FTE).

• The Worldwide Lost Time Injury Frequency Rate (WW LTIFR) reflects accidents of DEME's permanent employees and temporary employees involving work incapacity (≥ 24 hours or ≥ 1 shift) multiplied by 200,000 and divided by the number of hours worked. The 'Worldwide' method is a risk-based method that combines 'risk level rate' (= event that resulted in the injury) and 'injury rate' (= type of injury).

• TRIR and WW LTIFR calculations at DEME account for different working schedules, distinguishing between staff and maritime personnel (including workers in maritime supporting functions). TRIR considers maritime personnel's full presence on board, while WW LTIFR is based on operational execution time.

Scope limitations:

For 2024, all safety metrics focus solely on DEME's own employees. Non-employees are omitted from all metrics based on phase-in provisions outlined in ESRS 1 'General Requirements' (Section 10.4 – Transitional Provisions) and Appendix C of ESRS 1 (List of Phased-in Disclosure Requirements).

The following metrics have not been reported due to phase-in provisions:

• Number of cases of recordable work-related ill health of employees
• Number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health
• Number of fatalities as a result of work-related injuries and work-related ill health of other workers working on undertaking's sites

Compensation metrics

Pay gap

Not disclosed. DEME has not reported the unadjusted gender pay gap.

Remuneration ratio

DEME discloses a ratio between the highest fixed compensation level (i.e., of the CEO) and the lowest gross base salary level for 2024:

Methodology

The ratio is calculated as the CEO's gross base salary divided by the lowest gross base salary level. The gross base salary refers to annual full-time equivalent employees employed in DEME's Belgian legal entities. This metric does not represent a CEO-to-median employee ratio as required by ESRS S1-16.

Incidents, complaints and severe human rights impacts

Disclosure status

DEME has assessed ESRS S1-17 Incidents of discrimination as not material.

According to the materiality assessment table:

• ESRS S1-17 Incidents of discrimination paragraph 103 (a) - Indicator number 7 of Table #3 of Annex 1: Not material
• ESRS S1-17 Non-respect of UNGPs on Business and Human Rights and OECD paragraph 104 (a) - Indicator number 10 of Table #1 and Indicator number 14 of Table #3 of Annex 1: Not material

Grievance mechanism

DEME provides a grievance mechanism through its Whistleblowing Policy, which offers a confidential channel for employees and other stakeholders to report any concerns about unlawful behavior or behavior that contradicts the Code of Ethics and Business Integrity.

Reporting process:

• Reports may be filed on a disclosed or anonymous basis
• Acknowledgement of receipt sent within 7 calendar days to reporting individuals who have disclosed their identity
• Reporting individuals informed within 3 months of conclusions reached and actions taken
• Reports handled by DEME's Compliance Department with preliminary investigations conducted objectively and confidentially

Reporting channels:

• Email or regular mail
• External whistleblowing channels available in many jurisdictions
• Internal reporting channels strongly encouraged

No quantitative data on the number of incidents, complaints, severe human rights impacts, or fines/sanctions is disclosed for 2024.

Business conduct policies and corporate culture

DEME has established policies on business conduct and corporate culture that apply to all employees, officers, directors, and business partners.

Code of Ethics & Business Integrity

• Policy name: Code of Ethics & Business Integrity
• Scope: All directors, company representatives, staff and crew, full- and part-time employees (permanent and temporary), whether working under a contract or on a freelance basis for DEME and its subsidiaries
• Key content/principles:
  • Guidelines for responsible business practices
  • Emphasizes ethical decisions, transparency, legal compliance, and a respectful work environment
  • Prioritizes fair treatment, health, safety, environmental protection, and data privacy
  • Upholds zero tolerance for corruption and bribery
  • Compliance with applicable laws and regulations
  • Act with integrity and honesty and avoid inappropriate behavior
  • Covers protecting people and company assets, principles on preventing discrimination and harassment, antibribery and anti-corruption, compliance with international trade laws, and accounting standards and records
• Implementation monitoring:
  • Regular obligatory training sessions are organized to ensure everyone understands the Code and applies it properly in their daily activity
  • Reports and investigations handled by DEME's Compliance Department
  • Compliance Program includes existing policies, procedures, training, whistleblower hotline, IT tools, internal controls and risk management
  • Monitoring by DEME's Compliance Department

Code of Ethics and Business Integrity for Business Partners

• Policy name: Code of Ethics and Business Integrity for Business Partners
• Scope: All contractors, suppliers, and other third parties working with or on behalf of DEME
• Key content/principles: DEME expects any third-party it does business with to respect and act according to the Code's principles
• Implementation monitoring:
  • Included in contracts with suppliers
  • Global due diligence procedure for third parties using a risk-based methodology to screen for sanctions, bribery, and corruption risks
  • Supplier safety performance monitored via internal audit system
  • ESG assessment tool deployed with core and strategic suppliers covering more than a quarter of annual procurement spend

Whistleblowing Policy

• Policy name: Whistleblowing Policy
• Scope: Internal and external stakeholders
• Key content/principles:
  • Provides a secure and confidential channel for employees and other stakeholders to report any concerns about unlawful behavior or behavior that contradicts the Code of Ethics and Business Integrity
  • Covers any form of unlawful behavior
  • Protection from retaliation for reporting in good faith
  • Maintains confidentiality of whistleblower's identity
  • Reports may be filed on a disclosed or anonymous basis
  • Acknowledgement of receipt within 7 calendar days for disclosed reports
  • Reporting individual informed within 3 months of conclusions and follow-up actions
• Public availability: Summary publicly available on DEME website; full text available to personnel and external parties upon request
• Oversight: Independent Reporting Committee oversees implementation, investigates allegations, and enforces compliance
• Implementation monitoring:
  • Preliminary investigations conducted by DEME's Compliance Department
  • Reporting Committee discusses further measures
  • May be handed over to police or other authorities if required

Related policies mentioned

• Compliancy Policy
• Procurement Policy
• Anti-trust Policy
• Anti-corruption Policy
• Tax control framework
• Human Rights Policy
• Sustainability Policy
• Remuneration Policy
• Corporate Governance Charter (includes policy regarding conflicts of interest and policy on prevention of market abuse)

Note: These related policies are listed in the governance framework but detailed content is not provided in the excerpts.

Prevention and detection of corruption and bribery

Anti-corruption Policy

The company has an Anti-corruption Policy listed among its corporate governance policies.

• Public availability: The policy is mentioned in the Corporate Governance Charter documentation but no specific URL or location is provided in the excerpts.

Compliancy Policy

The company has a Compliancy Policy listed among its corporate governance policies.

• Public availability: The policy is mentioned in the Corporate Governance Charter documentation but no specific URL or location is provided in the excerpts.

Code of Ethics and business integrity

The company has a Code of Ethics and business integrity.

• Public availability: The policy is mentioned in the Corporate Governance Charter documentation but no specific URL or location is provided in the excerpts.

Code of Ethics and Business Integrity for Business partners

The company has a Code of Ethics and Business Integrity for Business partners.

• Scope: Business partners
• Public availability: The policy is mentioned in the Corporate Governance Charter documentation but no specific URL or location is provided in the excerpts.

Whistleblowing Policy

The company has a Whistleblowing Policy.

• Public availability: The policy is mentioned in the Corporate Governance Charter documentation but no specific URL or location is provided in the excerpts.

The excerpts do not provide detailed information on the specific content, principles, approval and oversight mechanisms, links to international standards, or monitoring implementation for these policies related to corruption and bribery prevention and detection.

Incidents of corruption or bribery

Disclosure status

DEME Group has not disclosed quantitative metrics for ESRS G1-4 (Incidents of corruption or bribery) in its 2024 sustainability statement.

Investigation and speak-up mechanisms

DEME has implemented comprehensive safeguards for reporting irregularities through its Whistleblowing Policy, which provides a secure and confidential channel for employees and other stakeholders to report concerns about unlawful behavior or behavior contradicting the Code of Ethics and Business Integrity.

Key features of the whistleblowing mechanism include:

• Reports may be filed on a disclosed or anonymous basis (though self-identification is strongly recommended)
• Acknowledgement of receipt within 7 calendar days for disclosed reporters
• Preliminary investigation conducted by DEME's Compliance Department
• Reporting individuals informed within 3 months of conclusions and follow-up actions
• Strict prohibition of retaliation against good faith reporters
• Reports made in bad faith may result in disciplinary action

Reporting channels include email or regular mail, with many jurisdictions offering external whistleblowing channels. The company encourages use of internal channels first to allow for effective remediation.

Anti-corruption framework

DEME operates a global Compliance Program including:

• Code of Ethics & Business Integrity
• Anti-corruption Policy
• Anti-trust Policy
• Compliancy Policy
• Compliance Department oversight
• Regular obligatory training sessions on the Code of Ethics
• Zero tolerance policy regarding corruption

The company acknowledges risks related to "Legal and regulatory compliance risks regarding anti-trust, anti-money laundering and anti-corruption" in its risk assessment, noting that operations in emerging markets are "more prone to bribery, corruption and other compliance risks."

Phase-in provisions

DEME's phase-in table indicates that certain G1-4 metrics are assessed as "Not material" including:

• ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws (paragraph 24(a))
• ESRS G1-4 Standards of anti-corruption and anti-bribery (paragraph 24(b))

However, no specific quantitative disclosure of incidents, convictions, fines, disciplinary actions, or contract terminations for 2024 has been provided in the sustainability statement.

Payment practices

Payment terms and practices

According to the financial statements, trade and other payables are stated at amortized cost. Invoices and related payment terms depend on individual contractual terms with suppliers.

Working capital and trade payables

Trade payables as of 31 December:

Payment practices management

The group manages its cash and liquidity through various measures including:

• Negotiating payment terms with suppliers without straining relationships
• Spreading borrowing among several banks with a variety of repayment terms
• Maintaining payment guarantees including credit insurance policies with public credit insurers (such as Credendo) and private credit insurers, bank guarantees and letters of credit

The group acknowledges that while it applies strict financial policies and ensures a diversity of financing sources and repayment terms, it cannot be entirely ruled out that the non-payment of significant payment obligations by customers could have a negative impact on DEME's cash flow and liquidity.