Deoleo, S.A.

Governance roles

Reference: pages 32, 166.

As of 31 December 2025, Deoleo's Board of Directors has seven members: one executive director, three proprietary directors, two independent directors and one non-executive chairman. The board "is the Company's highest governing body, and as such it is ultimately responsible for supervising the sustainability strategy and for managing impacts, risks, and opportunities (IROs)" (p.32).

It delegates functions to: the Nomination and Remuneration Committee (oversees the sustainability strategy, reports to the Board at least twice a year); the Audit and Control Committee (ensures reliability of non-financial information, supervises ESG risk integration); the Multidisciplinary Sustainability Group, led by the Head of Sustainability, who reports to the Sustainability Steerco and to the Nomination and Remuneration Committee; and the Sustainability Steerco itself, which meets quarterly and reports to the CEO.

Gender composition: two women sit on the Board (29%), unchanged from 2024, and "currently there are no workforce representatives on the Board of Directors" (p.32). For business conduct specifically, the governance framework is elaborated again at p.166 ("Key administrative bodies"), citing the Audit and Control Committee's oversight of compliance and ethics.

Information provided to governing bodies

Reference: pages 35-36.

"The Multidisciplinary Sustainability Group and its sponsors, under the leadership of the Head of Sustainability, are responsible for sharing the pertinent information with the administrative, management, and supervisory bodies," through detailed reports and regular meetings covering material IROs, due diligence progress, and the effectiveness of policies and targets (p.35).

"In 2025 the Nomination and Remuneration Committee addressed sustainability issues on a half-yearly basis," presenting the 2024 Integrated Sustainability Report ahead of publication and the full year's progress. The Board "approved the new materiality analysis, which updated the material impacts, risks, and opportunities of the previous analysis, conducted in 2024" (p.36). Governing bodies "addressed a wide range of material IROs," including climate change, biodiversity, workforce welfare and value-chain management.

Sustainability in incentive schemes

Reference: page 36 (cross-referenced under E1 at page 81).

"In 2025, we continued to incorporate sustainability into our variable remuneration systems... members of the executive committee, the leadership team and the multidisciplinary sustainability group worked on specific objectives related to this area" (p.36). Variable remuneration carries individual sustainability targets that "may represent up to a maximum of 50% of the variable remuneration," though the exact weighting "varies significantly across different positions and functions."

2025 targets spanned all three pillars: Environment ("Zero Waste" certification and waste recovery, packaging impact), Social (the People Survey and engagement) and Governance. The E1 chapter cross-references this section directly ("INFORMATION on variable remuneration in section ESRS-2 GOV-3... of this report," p.81) rather than stating a separate climate-specific weighting.

Statement on due diligence

Reference: page 38.

The report maps its due-diligence coverage across the statement: "Integration of due diligence into governance, strategy, and the business model" sits under GOV-1/IRO-1; "Co-operation with affected stakeholders" under IRO-1/SBM-2; "Identification and assessment of the adverse impacts" under IRO-1; "Adoption of measures to counter these adverse impacts" under E1-3, E3-2, E4-3, S2-3/S2-4 and G1-2/G1-3/G1-4; and "Monitoring of the effect of these efforts" across the E1-4, E2-3/E2-4, E3-2/E3-3, E4-3/E4-4, E5-2/E5-3, S1-2/S1-3/S1-4, S2-3/S2-4, S4-2/S4-4/S4-5 and G1-1 disclosures (p.38).

Risk management and internal controls

Reference: page 38.

"Our Risk Control and Management Policy sets out the core principles for managing and periodically assessing the risks that could arise in connection with the nature of our" business. The risk assessment methodology "combines the analysis of historical data, the experience of our specialist personnel, and feedback from stakeholders," followed by a prioritisation stage using "a well-structured risk matrix."

The report discloses a gap plainly: "Deoleo does not currently have a dedicated internal control over sustainability information system (ICSIS)." It states the company is instead "carrying out the necessary internal analyses to assess its future implementation," with a roadmap to develop the system "over the coming years." The Nomination and Remuneration Committee supervises verification procedures and audits in the interim.

Strategy, business model and value chain

Reference: pages 38-39.

Deoleo describes itself as "the world's leading olive oil company," with "a footprint in 68 countries and a portfolio of 29 brands, including Bertolli (the world's best-selling olive oil brand), Carapelli and Carbonell." Its purpose, "Caring for what cares for you," underpins the 'EVOOlution 2025-2028' strategic roadmap, "geared towards profitable growth and additional EBITDA generation, with a special focus on high-potential markets such as the US and India."

"Our business model encompasses all stages of the value chain: from partnerships with farmers and oil mills to packaging, distribution and direct engagement with consumers." Products include extra virgin, virgin and other olive oil categories, seed oils, table olives, vinegars, dressings and a cosmetic-oil line. Products sold under its brands are made "at our own facilities or by third parties (copackers)."

Interests and views of stakeholders

Reference: page 47.

"The opinions of our stakeholders help us to understand their viewpoints in relation to the real or potential impacts that our Company and value chain could cause to people or the environment." Main stakeholder groups and engagement channels listed: farmers and oil mills (via the Sustainability Protocol for EVOO production); suppliers (assessments and partnership agreements); clients/consumers (the Customer Care Channel and regular consumer research); employees (biennial surveys and trade-union dialogue); and administrations and regulatory bodies (ongoing transparent dialogue on relevant legislation).

This general process is cross-referenced from the E5 (p.148), S1 (p.131) and S4 (p.156) chapters, where topic-specific stakeholder engagement is elaborated further.

Material impacts, risks and opportunities

Reference: pages 50-53 (general); cross-referenced under E1 (p.82), S1/S2 (p.131), S3 (phase-in) and S4 (p.156).

The double materiality matrix sets out material impacts, risks and opportunities topic by topic. Material items span E1 (climate change adaptation/mitigation, energy), E2 (microplastics only), E3 (water extraction/discharge), E4 (biodiversity loss drivers), E5 (resource inflows/outflows, waste), S1 (working conditions, equal treatment), S2 (value-chain working conditions, human-rights risk in the agronomic phase), S3 (affected communities' economic and social rights), S4 (consumer information and health impacts) and G1 (corruption and bribery, supplier relationships).

A threshold is applied: "establishing 18 for the materiality of the impact and 12 for financial materiality," based on "the third quartile of the results of the general assessment." Climate-change risks feed into this matrix from the 2024 Climate Risk and Opportunity Analysis (cross-referenced to E1 IRO-1).

Process for identifying and assessing IROs

Reference: page 55.

"In this chapter we present a general overview of the process for assessing double materiality carried out to identify, assess, and determine both the real and potential impacts on people and the environment, and the risks and opportunities that could give rise to material financial effects," in response to ESRS and EFRAG materiality-assessment guidance.

The process runs four stages: Understanding (the Company's activity at each value-chain stage); Identification (positive/negative impacts, risks and opportunities over short/medium/long term); Assessment (severity – scale, scope, irremediable character – and probability for impacts; magnitude and probability of occurrence for financial materiality, following OECD due-diligence guidance); and Determination (consolidating corporate, factory and stakeholder input against the quartile-18/quartile-12 thresholds). "It is important to note that... a gross approach was applied, i.e., the assessment was carried out before considering any mitigation actions."

ESRS content index

Reference: pages 195-197 ("List of ESRS Information Requirements").

The report carries a three-page content index, titled "List of ESRS Information Requirements regarding the preparation of the Sustainability Statement following the materiality analysis results," listing each disclosure requirement (BP-1 through G1-6) with a Materiality column (Yes/No) and a Page column, or "Phase-in" where materiality is Yes but the information is deferred. This index is the authority used throughout this file to classify each of the 84 disclosure requirements as reported, not material, or omitted under phase-in relief.

Separately, BP-2 explains the scope of two transitional reliefs taken: the sub-750-employee exemption for E4/S1/S2/S4 (voluntarily reported anyway) and the "Stop the Clock" Omnibus phase-in for anticipated-financial-effects disclosures and for the S3 standard (p.30-31).

Transition Plan for Climate Change Mitigation

Reference: page 81.

Deoleo states the plan "incorporates various targets and actions that are aligned with" a 1.5C pathway, validated by the Science Based Targets initiative (SBTi): "this validation recognizes that Deoleo is moving forward on a path compatible with limiting global warming to 1.5C" (p.81-82). Decarbonisation levers include 100% renewable electricity at the Spanish and Italian facilities, a new photovoltaic self-consumption plant in Italy (20% of that factory's power), and fleet renewal to ECO/zero-emission vehicles.

2025 eligible climate CapEx exceeded EUR 1,320,000 (EU Taxonomy-aligned investment in renewable energy, facility efficiency and fleet electrification). "Furthermore, we have no business or economic activity in the fossil fuel, fossil gas, chemical products, arms or tobacco sectors," and "the Company is not exempt from EU benchmarks in line with the Paris Agreement." The Phase-in Plan was last updated and approved by the Sustainability team in November 2025, and is "fully integrated into and consistent with the Group's financial strategy and planning."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (climate section), where this content is disclosed at pages 83-85 of the FY2025 report. This disclosure requirement did not exist as a standalone code under the 2023 ESRS the report was prepared against.

Risk classification: physical and transition risks are assessed separately. Physical risk methodology: based on 28 physical climate hazards from the EU Taxonomy, narrowed to seven most relevant (temperature variation, heatwave, water stress, drought, heavy rain, soil degradation, soil erosion), using CMIP6/IPCC AR6 climate models. Two scenarios were used: SSP2-4.5 (intermediate) and SSP5-8.5 (high emissions) – satisfying the requirement to use at least one high-emission scenario for physical risk. Time horizons: short (2021-2040), medium (2041-2060), long (2081-2100), chosen as "more representative than those indicated in... ESRS."

Transition risk methodology: IEA scenarios – STEPS and NZE 2050, the latter 1.5C-aligned, satisfying the scenario requirement. Horizons: 2030/2040/2050, using World Energy Outlook 2024 data. Scope: own assets plus seven key suppliers. Four transition risks were identified (GHG price rises, new regulations, market-signal uncertainty, raw-material shortages), rated low criticality. No explicit temperature-projection figure per scenario is stated.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (climate section), disclosed at page 82 of the FY2025 report. This disclosure requirement did not exist as a standalone code under the 2023 ESRS the report was prepared against.

The company states plainly that no formal resilience analysis has been performed: "Adaptability and resilience [are] part of Deoleo's values. Despite not currently having a formalized resilience analysis, due to our business model's dependence on the availability of raw materials, we have faced various scenarios arising from climate risks" (p.82).

In its place, the report describes adaptation capacity: contingency plans addressing "the limited availability of raw material," geographic diversification of provisioning sources, and adjustments "from procurement planning to logistics and marketing." It adds that "no significant penalties have been imposed in 2025" for breaches of environmental law. The E4 chapter separately states the Company does not yet have "a formalised analysis of ecosystem resilience to climate change" either, and "plan[s] to develop one in coming years" (p.116).

Policies related to climate change mitigation

Reference: page 88.

Climate policy is carried in the Comprehensive Environmental Policy and the Transition Plan rather than a stand-alone climate policy document. Coverage includes the 1.5C-aligned SBTi-validated targets, decarbonisation levers (renewable sourcing, electrification, biogenic/eco-fuel substitution) and the EU Taxonomy-aligned investment programme described under E1-1. The policy is cross-referenced to the general ESRS 2 MDR-P section ("Policies adopted to manage material sustainability matters"), which carries the standard policy datapoints (scope, responsible party, third-party alignment) applied consistently across topics.

Actions and resources in relation to climate change policies

Reference: page 90.

Key 2025 decarbonisation actions: 100% renewable electricity at the Spanish and Italian plants; a new Italian photovoltaic self-consumption plant supplying 20% of that factory's power; continued renewal of the ECO/zero-emission vehicle fleet with new charging points; and the SBTi-validated target programme covering Scopes 1, 2 and 3 (categories 1, 3, 4 and 8). Decarbonisation levers are "detailed in E1-3 of this chapter," covering electrification, renewable sourcing, energy efficiency and supplier engagement. Investment in FLAG (forest, land-use and agriculture) emissions-removal calculation tools for the agricultural value chain is also described as an earlier-year initiative carried forward.

Targets related to climate change mitigation and adaptation

Reference: pages 92-93.

Three SBTi-aligned targets from a 2022 base year: Target 1 – Scopes 1 and 2, absolute reduction of 50.4% by 2032 (sub-target 1a: Scope 1 -43%; sub-target 1b: Scope 2 -98%). 2025 progress: Scope 1 "increase of 3.1% with respect to the base year," Scope 2 "reduction... with respect to the base year is 60.1%." Target 2 – Scope 3 non-FLAG (categories 1, 3, 4, 8), -38% absolute / -58.1% intensity by 2032; 2025 progress "29.5% [reduction] in absolute terms... and... 32.8% in relative terms." Target 3 – Scope 3 FLAG (category 1, procurement), -36.4% absolute by 2032; 2025 progress "21% compared to 2022."

"Modifications: there have been no substantial modifications to the parameters defined initially." SBTi validation of the near-term targets underpins all three.

Energy consumption and mix

Reference: page 97.

Headline metric: "14.49% increase in renewable sources in total energy consumption from 2024 to 2025." Total fossil-fuel energy consumption was 10,012.79 MWh in 2025 versus 10,107.9 MWh in 2024, made up of coal (0.00), crude oil/petroleum products (2,352.66 MWh), natural gas (3,784 MWh), other fossil fuels (0.00) and purchased fossil-sourced electricity/heat/steam (3,876.13 MWh). The proportion of fossil-fuel sources in total energy consumption fell from 52.01% (2024) to 48.34% (2025).

Gross Scope 1, 2, 3 and Total GHG emissions

Reference: page 99 (table), with detail to page 104.

2025 gross emissions versus base year and 2024: Scope 1 (location-based) 965.68 tCO2e (base year 936.8, 2024: 995.9, change +3.1% vs base year); Scope 2 location-based 1,984.0 tCO2e (2024: 1,735.1, +14.3%); Scope 2 market-based 55.3 tCO2e (2024: 53.1, +4.1% vs 2024, -60.1% vs base year); Scope 3 309,654.1 tCO2e (base year 444,763.2, 2024: 381,831.9, -18.9% vs base year).

"For 2025 and at the date of this report, we are able to disclose the scope 3 emissions of categories 1 and 4, which account for about 96% of scope 3 emissions." Categories 2, 6, 11, 13, 14 and 15 are addressed individually; categories 14 and 15 "do not apply to the organization because Deoleo does not have franchises" / "investments" respectively. GHG intensity per net revenue: 380.78 tCO2e/monetary unit (location-based, 2025) versus 385.87 (2024).

GHG removals and carbon credits

Reference: page 104.

Deoleo has not yet implemented removals or purchased carbon credits. It discloses the status directly: "We have initiated the analysis on the viability of offsetting projects using insetting strategies, in order to identify viable opportunities within our own value chain that contribute to reducing and neutralizing emissions." The stated purpose is to "assess initiatives aligned with our sustainability commitments, ensuring their technical integrity, positive environmental impact and consistency with corporate standards" before any removal or credit-financed project is adopted.

Internal carbon pricing

Reference: page 104.

A direct nil disclosure: "We do not currently use internal carbon pricing systems as a tool to manage our emissions" (heading printed in the report as "E1-8. System for setting the internal price of [carbon]").

Policies related to pollution

Reference: page 106.

"We have identified microplastic pollution as the sole material aspect in our double materiality analysis" for E2. The Comprehensive Environmental Policy commits to "minimize the use of virgin plastics, to boost the recyclability of our packaging and to increase the use of recycled materials," targeting 40% rPET packaging by 2030 and a 15% reduction in PET weight in key reference codes. The Sustainability Protocol addresses waste and by-product management at oil mills and farms.

On substances of concern, the report states directly: "As we have not identified any substances of concern used in our own operations or in those of the value chain, we did not consider it relevant to establish specific emergency plans in our pollution policies." Headline figures: -11.4% reduction in virgin plastic purchases versus 2020; target -15% PET weight reduction by 2030.

Actions and resources related to pollution

Reference: page 107.

Three action lines: (1) Packaging optimisation – progressive rPET introduction and PET weight reduction, with extra cost of rPET over virgin PET "exceed[ing] EUR925,000 (OpEx)" in 2025; (2) Plastic-waste management improvements – collaboration with oil mills on collection/recycling systems, 12 workshops to 247 attendees on packaging disposal and recycling; (3) Innovation and value-chain collaboration – R&D into sustainable PET alternatives and inclusion of plastics-reduction requirements in the Supplier Sustainability Program, with "50 suppliers analyzed" in 2025. Targets for these actions run to 2030.

Targets related to pollution

Reference: page 108.

"Most of Deoleo's pollution prevention and control targets are voluntary and aligned with standards such as the SBTi," while regulated areas (waste management, industrial emissions, plastics/chemicals use in agriculture) are addressed through regulatory-compliance inclusion in the sustainability strategy. The targets link directly to the E2-1/E2-2 rPET and PET-weight-reduction programme (40% rPET by 2030, -15% PET weight in key codes by 2030).

Pollution of air, water and soil

Reference: page 109.

The only E2 sub-topic the company's DMA found material is microplastics (not general air/water/soil pollution). On that sub-topic, the company reports a measurement gap rather than a figure: "We were unable to establish a system for measuring the microplastics generated or used in our operations during the reporting period. Therefore, we have not implemented any data collection process for accounting purposes, nor has this been reflected in any report."

Policies related to water and marine resources

Reference: page 111.

Four key initiatives: "systematic water monitoring and control; streamlining use and raising awareness; smart irrigation and digitalization; and innovative solutions," including leak detection, irrigation-equipment calibration, wastewater treatment/reuse and rainwater harvesting. The Comprehensive Environmental Policy "establishes a clear commitment to sustainable water management," backed by ISO 14001 certification; the Sustainability Protocol addresses precision irrigation, consumption monitoring and agrochemical-use practices to protect groundwater/surface water.

"Many olive-producing areas are in regions with water stress, according to the National Drought Observatory," and the protocol covers "a sustainability certification program involving 95 mills and 61,270 farmers." Joint projects with the Unión de Pequeños Agricultores (UPA) and the University of Jaén exceeded EUR38,000 in 2025.

Actions and resources related to water and marine resources

Reference: page 112.

Key actions: systematic water monitoring and control; efficient-use and awareness-raising campaigns (including with UPA and the University of Jaén); smart irrigation and digitalisation; and innovative solutions. Twelve workshops were given to 247 farmers across Spain, Portugal and Greece. Action 2 promotes "the evolution of physical irrigation systems towards more efficient models," favouring underground irrigation over superficial drip systems.

Targets related to water and marine resources

Reference: page 114.

Deoleo states plainly that it has not set a quantified target: "Currently, Deoleo has not established quantifiable objectives with regard to water at oil mills, due to our limited capacity to have a direct influence." It explains the limitation: "As a bottler and retailer of extra virgin olive oil, we have no direct control over oil mills and olive groves, which are the initial links in our supply chain. Therefore, we are not in a position to set or impose specific targets." Its actions instead promote voluntary adoption aligned with the EU Water Framework Directive (2000/60/EU) and the EU Biodiversity Strategy for 2030, with particular focus on water-stressed areas such as Alcolea (Córdoba).

Water consumption

Reference: page 114.

Total water consumption: 75,778 m3 (2025) versus 43,462 m3 (2024). Consumption in water-risk areas, including high water-stress areas: 70,858 m3 (2025) versus 40,962 m3 (2024). Total water recycled and reused: 0 m3 in both years. In 2025 the company recorded EUR1.2 thousand in waste charges "for compliance with regulatory requirements linked to the control and treatment of effluents."

Transition plan and consideration of biodiversity

Reference: page 116.

"We continue to strengthen our focus on biodiversity and ecosystems, aware of their essential role for the sustainability of our business. Ecosystem health directly impacts the availability and quality of our raw materials, especially in the agronomic phase." The company maintains ISO 14001-certified environmental management systems in Spain and Italy, requires equivalent standards of suppliers, conducts environmental impact assessments of new projects and carries insurance for potential environmental damage.

On resilience specifically: "Although we do not yet have a formalised analysis of ecosystem resilience to climate change, we plan to develop one in coming years as part of our commitment to ongoing improvement and alignment with ESRS standards." Collaboration partners include local communities, trade unions, oil mills, academic institutions, NGOs and industry specialists. The index cross-references this section to ESRS 2 SBM-3 and IRO-1.

Policies related to biodiversity and ecosystems

Reference: page 118.

Managed through the Comprehensive Environmental Policy (commitment to prevent deforestation, protect ecosystems, foster regenerative practices, and alignment with the EU Regulation on Deforestation-Free Products) and the Sustainability Protocol (reducing chemical use, preserving soil health, optimising water management, developing biodiversity plans with suppliers, and digital traceability). Policy aspects addressed: changes in land use, invasive species, pollution, impacts on species, land degradation/desertification, soil sealing and GHG-driven biodiversity loss, the last tackled through the Climate Transition Plan "one of the five main pressures that drive biodiversity loss."

Actions and resources related to biodiversity and ecosystems

Reference: page 119.

Four action lines: (1) Soil O-Live collaboration (European consortium led by the University of Jaén since 2023) – in 2025, "characterizing 4,281 ha. of olive groves and carrying out in-person interviews of 213 farmers," cumulative 1,110 interviews, 12 workshops in Spain, Portugal and Greece; (2) Conservation and restoration of agricultural soil – plant cover, cover cropping/biofertilisers, minimum/no tillage, gully control and native-species reforestation; (3) Biodiversity management – green infrastructure (dry-stone walls, nesting sites), biodiversity islands in fallow land, beehives, and partnerships with conservation NGOs/universities; (4) Training and monitoring – field visits and periodic indicator tracking under ISO 14001.

"We currently have 95 certified mills, seven more than in 2024, on which more than 60,000 farmers work on more than 349,000 ha."

Targets related to biodiversity and ecosystems

Reference: page 121.

Target: "Ensure that 70% of EVOO acquired comes from certified sustainable oil mills by 2030." Base year 2017-2018: 23.18% certified; 2025 progress: 36.0%; interim milestones 55-60% (2027-2028) and 65-70% (2029-2030). Scope: EVOO supply chain (mills and groves) across Spain, Portugal, Italy, Greece, Tunisia, Argentina and Chile.

The company discloses a limitation directly: "whilst no ecological threshold was established and no provisions were made for biodiversity loss compensation in the initial definition of this target, we acknowledge the importance of incorporating more robust ecological criteria into future reviews." Mitigation-hierarchy levels addressed: avoidance, minimisation and restoration/rehabilitation; offsets are only "evaluate[d]... in the case of residual impacts," not yet implemented.

Impact metrics related to biodiversity and ecosystems change

Reference: page 122.

A scoped nil disclosure: "At Deoleo we do not own, or lease, or have under our management sites that could have a negative biodiversity-related impact. For this reason we have not identified material negative impacts with respect to changes in land use or on the extent and condition of ecosystems at sites under these conditions." Impacts are instead tracked upstream via the Soil O-Live and mill-certification programmes described under E4-3.

Policies related to resource use and circular economy

Reference: page 125.

The Comprehensive Environmental Policy commits to "minimizing the use of virgin plastic materials and progressively increasing the use of secondary resources, such as recycled materials (for example, rPET)," recyclable-packaging design, and "Zero Waste" certification at Deoleo's own facilities. The Sustainability Protocol addresses waste/by-product management (valorisation of olive washing and milling waste as fertiliser), single-use-input reduction, and ISO 14001-based monitoring of supplier environmental performance.

Actions and resources related to resource use and circular economy

Reference: page 125.

Four action lines: (1) rPET use – "In 2025, 40% of the PET used by Deoleo in its packaging came from 100% recycled plastic"; (2) packaging recyclability – "79.2% of our SKUs (references) are now recyclable, economically viable and meet legal recyclability criteria"; (3) primary-plastic reduction via eco-design; (4) factory/mill waste reduction, including a new food-waste mitigation plan planned for 2026. Extra OpEx cost of rPET over virgin PET "exceeds EUR925,000" in 2025. Targets run to 2030, set since 2023.

Targets related to resource use and circular economy

Reference: page 126.

Targets are framed around the same circular-economy metrics disclosed under E5-2 (rPET share, SKU recyclability, primary-plastic reduction and Zero Waste certification), with headline 2025 figures of -11.4% primary plastics versus 2020, 94.4% of factory operations certified "zero waste," -3.6% reduction in factory waste, and 40% rPET as a proportion of global PET use.

Resource inflows

Reference: page 127.

Total overall weight of technical and biological products and materials used: 200,745,475 kg (2025) versus 22,186,812 kg (2024) [auxiliary and raw materials: EVOO/virgin olive oil, refined olive oil, olives, seeds and refined seed oil]. The report notes a comparability caveat: "The data reported for 2024 are not comparable with those of 2025, as the 2024 figures did not include the accounting of raw materials." Reused/recycled secondary-component tracking is limited to rPET "due to the availability of reliable data," as glass and cardboard recycled content could not be reliably quantified this year.

Resource outflows

Reference: page 127.

"The waste generated mostly comes from packaging – cardboard, cans, glass, plastic and plastic film – as well as laboratory waste and solvents." Management approach: "elimination of food waste by recovering anything rejected on the production line," improved management of non-conforming packaged product, and reduction of packaging material. Deoleo works with suppliers and an external company "to recycle or reuse" this waste rather than send it to landfill.

Waste

Reference: page 127.

Total amount of waste generated: 76,994 kg (2025) versus 74,764 kg (2024). Percentage of non-recycled waste: 5.6% in both years. Hazardous and radioactive waste: 0 kg in both years. Non-hazardous waste diverted from disposal includes recycling/other recovery operations (e.g. 1,301,975 kg in 2025 versus 1,241,108 kg in 2024 under one recovery category). Waste sources are mainly packaging materials and laboratory solvents, managed under the reduction/reuse/recycling approach described under E5-5.

Policies related to own workforce

Reference: pages 132-133.

Core policies: the Code of Conduct ("guides the behavior of all employees, executives, and members of the governing bodies"); the Human Rights Policy (rejection of forced/child labor, respect for labor rights, occupational safety, non-discrimination); the Equality Plan (gender equality, work-life balance); the LGTBI Plan ("ensuring an inclusive, safe workplace that is free from any form of discrimination or harassment," with a 2026 review scheduled); the Protocol against Harassment (renegotiated in 2024 with Spanish employee representatives); and the Occupational Risk Prevention Policy. The Equality Plan, LGTBI Plan and Harassment Protocol apply "to workers forming part of Deoleo's workplaces in Spain."

Engaging with own workforce

Reference: page 134.

Channels include email, notice boards, the corporate intranet, the PARTICIPA platform, anonymous whistleblowing and video screens. Social dialogue runs through three Workers' Committees (two in Spain, one in Italy), with negotiating-committee meetings every two to three months.

The biennial People Survey, run by Willis Towers Watson since 2019, achieved a 91% participation rate in 2025. Results: Engagement 84% (4 points above sector average); Employee Experience 83% (8 points above average); 91% report a discrimination-free environment; eNPS of 25 (first year measured, 11 points above average); Communication 70% (up 5 points). The Chief People Officer owns the relationship with employees.

Remediation processes and channels

Reference: pages 135-136.

Three channels for labor-related complaints: direct communication with managers/HR; trade unions or workers' committees; and the Ethics Channel, managed jointly by Internal Audit, Legal Affairs and HR, open to employees, contractors, trainees and former staff. "In 2024, Deoleo approved its Human Rights Policy, which consolidates our commitment to identifying, preventing, mitigating, and repairing the negative impacts on the rights of working people," aligned with the UN Guiding Principles on Business and Human Rights. Effectiveness is tracked via case follow-up, satisfaction surveys and internal review.

Taking action on material impacts on own workforce

Reference: page 138.

Five action lines: (1) Working conditions (PayFlow early-wage access, Ayvens mobility agreement); (2) Equality and diversity (LGTBI Protocol, Women Leadership Mentoring, Deoleo Parents Program, unconscious-bias training; EUR9,000+ on the LGTBI Plan); (3) Training – "hours of training given increased by 27% compared to 2024, reaching a total of 27,267 hours, 5,880 hours more than the previous year" (~EUR400,000, 0.8% of personnel costs); (4) Talent attraction (~EUR200,000); (5) Cybersecurity/data protection (NIS2 compliance in 2025, DSPM and CERT 24x7 planned for 2026; OpEx EUR340,000/CapEx EUR40,000).

Targets related to own workforce

Reference: page 141.

Target 1: 91% People Survey participation and >85% Commitment score by 2029-2030 – "A 91% participation rate was already achieved in 2025, and 84% for Commitment; target practically met ahead of schedule." Target 2: 43% women in the global workforce and 40% in leadership teams by 2030 (base year 2022: 38%/37%) – "In 2025 women made up 39.56% of our global workforce and 40.55% on leadership teams," with women in factories rising from 25% to 29%.

Characteristics of the undertaking's employees

Reference: page 142.

"As of 31 December 2025, the total number of employees was 642 – 634 salaried personnel and 8 unsalaried personnel." The 634 salaried employees span 11 countries on three continents: women are 39.49% of the workforce, and 97.79% hold permanent contracts. By gender: 384 men / 250 women (2025) versus 372/243 (2024). Permanent salaried staff: 620 (2025) versus 604 (2024); temporary: 14 versus 11.

Characteristics of non-employee workers

Reference: page 143.

The heading is given as "S1-7. Characteristics of non-employees in the undertaking's own workforce." The company's headcount disclosure distinguishes "634 salaried personnel and 8 unsalaried personnel" within its 642-person total workforce (p.142), with the 8 non-salaried workers reported as a distinct category for the purposes of this disclosure.

Diversity metrics

Reference: page 143.

Age breakdown of salaried employees: under 30: 48 (2025) / 42 (2024); 30-50: 373 / 366; over 50: 213 / 207. Gender breakdown of senior management (2025): women 1 (8%), men 11 (92%); (2024): women 2 (18%), men 6 (82%), i.e. women's senior-management share fell from 18% to 8%. "Senior management" is defined as positions answering directly to the Board or the Company's senior executive function, plus internal audit. Workforce gender split: women 39.56%, men 60.44%.

Adequate wages

Reference: page 144.

"We pay adequate remuneration to 100% of our workforce in every country where we operate." The company benchmarks against Mercer's Worldwide Benefits & Employment Conditions report; where Mercer does not cover a market (India), "we resorted to local advisory teams, thus ensuring that our salaries meet the minimum standards in these countries."

Persons with disabilities

Reference: page 144.

"In Spain, this is achieved through direct hirings or by commissioning services from special employment centres, through the declaration of exceptional circumstances and the adoption of alternative measures, to comply with the quotas relating to employees with disabilities (Royal Decree 364/2005)." In 2025 the Directorate-General of the Public State Employment Service "approved, for one more year, the said alternative measures." Percentage of salaried personnel with a disability: 0.5% (2025) versus 0.7% (2024). Accessible facilities are maintained in Spain and Italy.

Training and skills development metrics

Reference: page 144.

"We have increased the hours invested in training by 27% compared to 2024, which now total 27,267 hours, 5,880 more than in the previous year (21,387)." Percentage of employees with periodic performance/career-development reviews: men 87.8% (2025) vs 93.2% (2024); women 88.3% vs 93.0%. Average training hours per employee: men 37.5 (2025) vs 32.0 (2024); women 49.3 vs 24.2.

Health and safety metrics

Reference: page 145.

"The Rivas, Alcolea, and Tavernelle workplaces have ISO 45001 certification, in relation to the Occupational Health and Safety Management System (OHSAS). In total, these installations employ a total of 428 workers, representing 68% of Deoleo's global workforce." Fatalities: "In the 2025 and 2024 reporting periods, no deaths resulting from recordable workplace accidents or work-related illnesses were registered." 2025 saw training expanded across physical, emotional/mental and reproductive/hormonal health topics.

Work-life balance metrics

Reference: page 146.

"At our workplaces in Spain, 100% of Deoleo staff are entitled to leave for family reasons. In the other countries where the Company operates, such leave is regulated by national legislation or by the applicable collective-bargaining agreements, and as such it is not possible to provide a consolidated percentage." The report notes "widespread use of these rights among the persons working for the Group" during 2025, covering maternity/paternity, dependent care, medical leave and flexible-working/digital-switch-off measures.

Compensation metrics (pay gap and total compensation)

Reference: page 146.

Average remuneration per hour: men EUR36.22 (2025) / EUR36 (2024); women EUR33.73 (2025) / EUR34.97 (2024). Gender pay gap: 18.51% (2025) versus 13.96% (2024). Remuneration ratio (highest to median): 18.6 (2025) versus 18.9 (2024). The calculation basis includes fixed and theoretical variable remuneration and benefits in kind (company vehicle, lodging, medical insurance, school allowance), excluding the highest-paid individual at the Company.

Incidents, complaints and severe human rights impacts

Reference: page 146.

"During 2025, 14 incidents have been reported via the Ethics Channel (2 in 2024) within the scope of employment matters relating to human rights among our own employees, and none of these have led to an investigation being launched." No further incidents were reported through other channels, including OECD National Contact Points. "Likewise, in 2025 we have not receive any fines, penalties, or pay-outs for serious incidents related of a monetary nature relating to human-rights infringements in relation to our in-house staff."

Policies related to value chain workers

Reference: page 149.

Headline policy: the Sustainability Protocol, which "addresses issues such as training, occupational risk prevention, freedom of association rights, vulnerable groups, and more." Deoleo identifies two groups of value-chain workers exposed to material impacts: agricultural/agronomic-phase workers (risk of labor exploitation, unlawful recruitment, unfair treatment, particularly from seasonal crop work) and co-packer/external production-centre staff (exposure to machinery, intense working days, inadequate prevention measures). The Company notes purchases from regions with a risk of child or forced labor (e.g. parts of South America), controlled through the Suppliers Code of Conduct.

Engaging with value chain workers

Reference: page 150.

Engagement runs through union organisations in the agronomic phase (e.g. the Unión de Pequeños Agricultores y Ganaderos, UPA) and certified oil mills acting as a communication channel. Mechanisms vary by supply-chain phase: regular meetings with unions/mills in the agronomic phase; occupational-safety assessment and rights training at production/bottling sites; and compliance verification with logistics/distribution partners. The Chief Operations Officer is ultimately responsible. Effectiveness is measured "by way of the feedback received by the representatives of the farmers and regular visits to the oil mills," with the Ethics Channel covering the rest of the chain.

Remediation processes for value-chain workers

Reference: page 151.

Preventive measures include continuous training in workplace safety/compliance/human rights, the Sustainability Protocol's audit and monitoring framework (particularly health and safety "at source"), supplier auditing and the supplier-approval process (with particular emphasis on co-packers). Workers may raise concerns through the Ethics Channel, available to "staff employed, suppliers, and other third parties." The company discloses a monitoring gap directly: "Currently we have no process to assess the extent to which value chain workers are aware of and trust the Ethics Channel."

Taking action on material impacts on value chain workers

Reference: page 152.

Two strategic action lines: (1) annual training for certified oil mills on regenerative agriculture, health & safety and regulatory compliance – "in 2025 we gave 12 workshops to 247 farmers in Spain, Portugal and Greece"; (2) ESG questionnaires and in-person audits of key suppliers (co-packers and MAux) – "in 2025, 100% of our copackers and suppliers of auxiliary material have been assessed in ESG matters through our questionnaire," using IRCA-certified auditors. "At Deoleo we have not received any notifications of serious issues or cases relating to human rights" in the value chain. The company cannot yet report a precise OpEx/CapEx figure for these actions.

Targets for workers in the value chain

Reference: page 153.

Target 1: annual training for 100% of certified oil mills – "Training sessions were held at the 95 certified oil mills in 2025... An estimated coverage rate of 100% of all certified oil mills was attained." Target 2: ESG appraisal of 100% of key suppliers annually, emphasising social criteria – "During 2025 we appraised 100% of our key suppliers by way of ESG questionnaires," begun in 2024. A digital monitoring tool is planned for 2026.

Policies related to consumers and end-users

Reference: page 157.

Consumer-facing commitments sit in the Code of Conduct ("transparent and honest communications") and the Human Rights Policy, which "laid the foundations for protecting the human rights of our customers and consumers in marketing the end product." Material risk/opportunity context: "Consumers could switch away from olive oil with options that are less healthy when faced with inflationary pressures," with effects skewed toward "consumers with lower economic resources," while sustainability-aware consumers represent an opportunity.

Engaging with consumers and end-users

Reference: page 158.

Engagement channels: annual surveys, focus groups, external agency research and the Customer Care Centre. A flagship study, "Demand Spaces," analysed olive-oil consumer behaviour in the US, Germany and Spain. Accessibility and vulnerable-consumer needs are addressed through packaging/communication design and certifications (e.g. halal, kosher) in relevant markets. AI tools were introduced in 2025 "into the analysis of certain studies... to streamline the extraction of conclusions." The Customer Care department, reporting to the CEO-led consumer-centric strategy, manages the process.

Remediation processes for consumers and end-users

Reference: page 159.

"As a result of the double-materiality analysis, no negative incidents of relative significance caused by or aggravated by Deoleo have been identified in relation to consumers or end users." Complaints are tracked via the Orion and Isometrix tools; claims fell from 765 (2024) to 518 (2025), "a 32% reduction." "During 2025, we have received only one penalty with regard to labelling, and the fine has already been paid." The Customer Care Channel centralises requests by email, phone and social media.

Taking action on material impacts on consumers and end-users

Reference: page 160.

Two action lines: (1) Communication campaigns – Bertolli/Carbonell/Carapelli campaigns on Mediterranean-diet benefits; "In 2025 we have impacted 97 million people, reaching 123 million since we began this initiative," targeting 150 million by 2030; (2) Transparency in product information – blockchain QR traceability implemented across "51 brand references, equivalent to 36% of our annual volume of extra-virgin olive oil," via a new partner, Telefónica (switched from IBM). "The double materiality assessment did not detect any material negative impact," and "we have not detected any severe human rights incidents relating to consumers and/or end users."

Targets related to consumers and end-users

Reference: page 162.

Target 1: reach 150 million people with olive-oil benefit campaigns by 2030 (base year 2022: 40 million) – "we have reached over 123 million people," with an interim 2027 milestone of 129 million. Target 2: 30% of EVOO marketed to carry QR/blockchain traceability by 2030 – "digital traceability has already been implemented for 51 brand references, representing 36% of our annual volume," meeting the 2027 milestone (25%) ahead of schedule in 2025; 70 of a targeted 300+ suppliers are active on the blockchain platform.

Business conduct policies and corporate culture

Reference: page 166.

Policy suite: the Corporate Social Responsibility Policy, the Anti-Corruption Policy ("establishes a regulatory framework to prevent, detect and impose penalties for corruption and bribery"), the Code of Conduct and the Human Rights Policy. Oversight sits with the Audit and Control Committee, whose members "specialize in accounting, auditing and risk management," which "oversees the implementation of regulatory compliance policies and the management of ethical and financial risks." The report states: "We have a sound corporate culture, based on the principles of sustainability, ethics and commitment to quality."

Management of relationships with suppliers

Reference: page 169.

A documented late-payment/debt-management procedure covers SMEs, using the Client Management Reporting Procedure and the Doubtful Debt Management Procedure. Mechanisms: early debt monitoring from invoice issue to due date, customer risk classification with credit limits, credit insurance (90-day claim window), quarterly centralised reporting on debts beyond 60 days, and trade-discount supervision. Applies to "all commercial operations of the Deoleo Group in Spain and internationally." Responsible functions: Cash Management, the Credit & Risk Manager, and the Client Care Service.

Prevention and detection of corruption and bribery

Reference: page 170.

"We have specific procedures to prevent, detect and address complaints or incidents of corruption and bribery," anchored in the Anti-Corruption Policy (bans facilitation payments and bribes in public and private contexts) and a Crime Risk Prevention Manual (segregation of duties, entertainment-expense controls, prohibition of irregular payments). The Ethics Channel receives reports, investigated independently by the System Manager with Internal Audit, Legal Affairs and HR; the Audit and Control Committee receives an annual report on complaints, investigation outcomes and disciplinary measures, and "may recommend additional actions to enhance the effectiveness of the system."

Targets related to business conduct (part of MDR-T/GDR-T disclosures)

This FY2025 statement is prepared under the 2023 ESRS, under which business-conduct targets fell within MDR-T rather than a standalone G1-3 Targets code; no "G1.MDR-T" cross-reference tag appears in the report (unlike E1/E2/E3/E4/E5/S1/S2/S4, which each carry one), confirming no numeric business-conduct target is stated.

Effectiveness is instead tracked in the absence of a stated target, the other limb of MDR-T: the Audit and Control Committee "receives a report each year prepared by the Internal Audit department indicating the number of complaints received, their origin, type, the results of the investigations, and proposed actions" (G1-3, p.170). Anti-corruption "Progress 2025" reporting states: "In 2025 no additional significant advances were recorded given that the measures implemented over previous years were in accordance with a long-term structural approach," with the priority "on maintaining it and applying it properly, rather than on the addition of new initiatives" (p.172).

Incidents of corruption or bribery

Reference: page 172.

"Deoleo did not have any confirmed cases of corruption or bribery in 2025, nor was it sentenced or fined for violating the applicable corruption and bribery prevention laws." Preventive mechanisms cited include the Anti-Corruption Policy, Code of Conduct, supplier-approval ESG screening, internal controls (segregation of duties, joint signatures, gift restrictions) and the Ethics Channel. "Corrective measures: no corrective measures were required for any of these actions."

Payment practices

Reference: page 173.

"The average supplier payment period in 2025 was 52 days (58 days in 2024)." Under Spanish Law 3/2004, the legal maximum is 30 days (extendable to 60 by agreement); "we have agreements with most of our suppliers to make payments within the maximum term of 60 days." Compliance: "In 2025, 87% of payments were made within the period stipulated in regulations on delinquent payments (92% in 2024)... 82% complied with the required deadlines (88% in 2024)" by invoice count. "At the reporting date for the year, there are no open legal proceedings in relation to delays in payments to suppliers."