Dia Group

The role of the administrative, management and supervisory bodies

Reference: page 61.

Dia Group is governed per the CNMV Code of Good Governance. The Sustainability function reports directly to the CEOs at Group level and in each business unit; the Board and the Audit and Compliance Committee (ACC) carry out periodic supervision.

The Board of Directors has 10 members (50% women, 70% independent) bringing over 150 years of retail experience; its Appointments and Remuneration Committee maintains a skills and knowledge matrix covering sustainability among other competencies (page 63).

Beyond the Board's two committees (ACC and Appointments and Remuneration), Dia lists a Management Committee, an ESG/Sustainability Committee created in 2024, a Risk Management and Internal Control Committee, an Ethics Committee, a Spending Committee, an Expansion Committee, and an Artificial Intelligence Committee (pages 65-67), each with defined ESG-relevant remits.

Information provided to and sustainability matters addressed by the administrative bodies

Reference: pages 68-70.

The Board and its committees are informed periodically of material IROs, per the DMA results in section 3.4.2. Risk management is run through a Comprehensive Risk Management System (CRMS) based on COSO ERM, digitalised in SAP GRC, with risks catalogued into financial, operational, strategic, compliance and reputational categories and reviewed at least annually.

In 2025 an Internal Control System over Sustainability Reporting (ICSR), implemented in 2024 and tested this year, covers the material matters from the DMA: customers and end-users, data security and privacy, employees, climate change, and circular economy. Section 2.2.1 sets out the full ESG information flow from the Board down through Financial, Compliance, People and Culture, Legal, and Communication and Sustainability Management.

Integration of sustainability-related performance in incentive schemes

Reference: pages 71-72.

Variable remuneration for the Steering Committee, executives, managers and part of technical/support staff is linked to sustainability objectives (diversity, gender equality, safe working environment), with specific weighted targets per area, e.g. Commercial Management's "decarbonisation of stores" (20% weight), Information Technology's "reduction in key risks associated to cybersecurity" (30%), and Communication and Sustainability Management's "implementation and validation of the... ICSR System" (20%).

The system is approved annually by the Management Committee. It does not, however, include a variable remuneration component tied directly to GHG emission reductions (confirmed again at page 126).

Statement on due diligence

Reference: pages 73-75.

Dia Group maps the five core elements of due diligence to report sections in a table: embedding in governance/strategy (GOV-2, GOV-3, SBM-3); engaging with affected stakeholders (GOV-2, SBM-2, IRO-1, MDR-P, S1-1/2/3, S2-1/2/3, S4-1/2/3, G1-1/2/5/6); identifying and assessing negative impacts (SBM-3, IRO-1, and the E1/E3/E5 topic-specific IRO-1s); taking action (MDR-A, E1-1, E1-3, S1-4, S2-4, S4-4, G1-1/2/3/5/6); and tracking effectiveness (MDR-M, MDR-T, E1-3 to E1-6, S1-5 to S1-17, S2-4, S4-4, G1-3/4/5/6).

The approach is grounded in the UN Guiding Principles on Business and Human Rights, the ILO fundamental conventions, and the OECD Guidelines for Multinational Enterprises.

Risk management and internal controls over sustainability reporting

Reference: pages 75-77.

Dia applies a three-lines-of-defence model: day-to-day operational controls (first line); internal control, risk management, compliance and ethics functions via the Risk and Internal Control Committee and the ESG Committee (second line); and internal audit (third line). The Risk and Internal Control Director reports to the CFO and the ACC on the full annual risk process, which is externally audited as part of financial and sustainability assurance.

Risks are scored on likelihood and on financial, strategic, regulatory, operational and reputational impact, each on a 1-4 scale. Seven named top risks are detailed with mitigation, including cybersecurity, cold-chain failure, business continuity, food safety, and "non-compliance with the Strategic Sustainability Plan... including compliance with... the CSDDD and the CSRD".

Business model and strategic pillars

Reference: pages 79-84.

Dia Group is the leading local-supermarket network in Spain and Argentina: 3,365 own and franchised stores (3,343 in 2024), 16,887 direct employees, 1,503 franchisees with 15,558 employees, net sales of EUR 5.715 billion (EUR 5.88 billion in 2024) and adjusted EBITDA of EUR 316 million. Franchises manage 70% of the store network (69% in 2024). Around 1,445 local suppliers provide 96% of purchases locally, distributed through 16 warehouses.

Dia's value chain runs from commercial suppliers and ancillary-material suppliers (previous phases), through own operations (own-brand production, packaging, logistics, marketing), to service providers, franchisees, and end customers (subsequent phases, pages 83-84). The company has no products or services prohibited in the markets where it operates.

Interests and views of stakeholders

Reference: pages 94-96.

Stakeholders are grouped as "affected stakeholders" and "users of the sustainability statements." Key groups include suppliers, shareholders, investors, partners, own employees, customers, franchisees, local communities, media, market agents, competitors and public administrations, each weighted for the DMA.

A detailed stakeholder-interaction table (pages 95-96) sets out the communication model and 2025 matters raised per group, e.g. for Franchisees: franchisee mailbox/portal/training, with 2025 matters including the VI Collective Agreement and digitalisation of compliance documentation (Dokify); for Investors and analysts: conferences and results presentations, with matters including "integration of ESG matters... feedback to the main ESG indices and rankings".

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

Reference: pages 106-114.

The 2025 DMA produced 34 IRO statements across E1-E5, S1-S4 and G1 (plus tax transparency, data security and innovation as entity-specific topics), shown with time horizon, anticipated financial effect and value-chain position in a full table (pages 106-111). Three sub-topics scored below the materiality thresholds and are excluded: soil pollution, marine resources, and "other work-related rights" under S1.

On resilience (page 111): Dia cites equity exceeding 2.93% of total liabilities, stable EBITDA-to-sales near 7%, and its GOV-5 risk system, concluding the strategy and business model are resilient. Year-on-year changes (pages 112-114) are tracked via a 2024-vs-2025 impact/financial materiality scorecard across 13 topics, with Data Security and Privacy newly entering the top-3 financial-materiality matters and Business Conduct entering the top-3 impact-materiality matters in 2025.

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

Reference: pages 98-105, 116.

Dia's Double Materiality Analysis runs four phases: (1) analysis of context and business model, including regulatory and sector-analyst review (MSCI, SASB, S&P); (2) identification of impacts, topics and sub-topics, cross-checked against prior-year materiality, competitors and the Dia Risk Map; (3) assessment of IROs, scoring impacts on scale, scope, remediability and likelihood, and risks/opportunities on scale, magnitude and likelihood; (4) stakeholder consultation and Board validation.

Materiality thresholds were set at 2.08/5 for impact materiality and 0.98/5 for financial materiality (25% of the mean score), a methodology change from 2024's "percentage of the maximum" approach. Results were presented to the ESG Committee and the Audit and Compliance Committee before Board approval (page 104).

ESRS disclosure requirements met in preparing the sustainability statement (IRO-2)

Reference: page 116; Appendix 2 (pages 314-317).

Dia Group states all ten cross-cutting and topical ESRS are material: ESRS 2 and E1 through G1, each marked "Yes" in a company-drawn table. Three specific datapoints are explicitly flagged as omitted rather than reported: E1-7 ("the company does not participate in carbon credit markets or carbon storage projects"), E2-6 ("Omitted, phase in") and E3-5 ("Omitted, phase in").

Appendix 2 provides a page-and-chapter content index for every other disclosure requirement across BP-1/BP-2, ESRS 2 GOV/SBM/IRO, and the ten topical standards, which is the basis for the "reported" classifications in this file.

Transition plan for climate change mitigation

Reference: pages 127-132.

Dia's voluntarily approved Transition Plan is built on SBTi-aligned (not yet SBTi-validated) pathways: -42% absolute Scope 1+2 emissions (2020-2030) and -49% Scope 3 intensity per euro of turnover (2023-2030), with measures assessed by abatement cost versus potential. Carbon footprint covers Spain and Argentina assets; Brazil and Portugal are excluded as divested in 2024.

Key levers: refrigeration decarbonisation (EUR 149 million CAPEX by 2030, propane/ammonia systems, 436 Spanish and 19 Argentine stores converted in 2025), renewable-electricity GO certificates (target 80% of Spanish electricity by 2030), fleet renewal, and a transport TMS. Abatement costs range from EUR 26.49/tCO2e (renewable electricity) to EUR 6,185/tCO2e (oven decarbonisation, Table 3, page 130). Taxonomy-eligible CAPEX is 72% of total CAPEX, with 56% aligned/total (Table 4, page 131). Locked-in emissions (company vehicles, non-renewable electricity, legacy refrigerant gases) are assessed as immaterial to target achievement (page 132).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 133-144). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Dia Group's report is prepared under the 2023 ESRS (Commission Delegated Regulation 2023/2772); the basis of preparation confirms the phase-in provisions of ESRS 1 Appendix C and the quick-fix timelines (page 58-59), with no native E1-2 section.

The climate risk process follows TCFD and ESRS guidance. Physical risk scenarios: RCP 8.5 ("+3.7C by 2100") and RCP 4.5 ("+1.8C by 2100"), applied via CNIG/Copernicus flood mapping in Spain and DESINVENTAR data in Argentina, and AdapteCCa for heatwaves. Transition risk scenario: the Net Zero pathway consistent with both countries' NDCs, projecting 1.5C by 2050, covering new climate regulation, energy transition, market/reputational and technology assumptions. Time horizons used: 2025 (SSP term), 2030 (decarbonisation milestone) and 2050 (Net Zero). Scope covers own operations and upstream/downstream value chain in Spain and Argentina (page 135-136). Analysis was carried out in 2025 via a specialised consultant (page 133).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (sections 5.1.3-5.1.3.1, pages 132-133). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Dia Group, unlike many first-time disclosers, did perform a resilience analysis: in 2024 it developed a Climate Resilience Plan via a specialised consultant, assessing climate risk situations by geography and activity type across all establishments. Results show "greater exposure to transition risks than to physical risks, with a residual financial impact that is not significant," and of ten potential climate events identified, four risk situations were considered relevant at business level.

The transition plan's decarbonisation levers (E1-1) and the resilience plan both feed Dia's general Risk Management System (Note 24 of the Consolidated Financial Statements). The conclusion: "the operating model is considered robust and resilient to climate change" (page 136), reassessed via the annual DMA and risk map update.

Policies related to climate change mitigation and adaptation

Reference: pages 145-146.

Climate sits within Dia Group's Environmental Policy, approved by the Board and updated in 2025, aligned to SDGs 7, 9, 12 and 13, and to "the Paris Agreement 1.5C temperature increase Scenario and the scenario of Net Zero Emissions by 2050." It sets eleven commitment lines: legal compliance, environmental management, control, efficiency, sustainable resource use, energy efficiency, decarbonisation, climate risk/opportunity management, collaboration, transparency, and value-chain/commercial-partner engagement on Scope 3.

The policy explicitly states Dia "is committed to a decarbonisation and sustainability strategy... by not investing in the expansion of fossil fuels." It applies group-wide in Spain and Argentina and extends to suppliers and franchisees; the Audit and Compliance Committee oversees it.

Actions and resources in relation to climate change policies

Reference: pages 147-148.

Actions are broken out by scope with financial resources assigned. Scope 1: refrigeration replacement (OPEX EUR 7.8m/CAPEX EUR 28m in 2025, rising to OPEX EUR 13.2m/CAPEX EUR 149m by 2030) and fleet renewal with Eco/Zero-label vehicles. Scope 2: oven renewal (CAPEX EUR 7m rising to EUR 39m by 2030) and hourly-consumption monitoring. Scope 3: recycled/recyclable packaging, renewable-energy purchasing, building renovation aligned with the EU Green Taxonomy (CAPEX EUR 75m rising to EUR 803m by 2030), transport-route optimisation, EV charging points, and supplier SBTi-commitment monitoring (Tables 5-7, page 147).

"The capacity to execute these actions depends in part on the assignment of financial resources," the report notes, tying the action set directly to IRO-1's decarbonisation-lever identification.

Targets related to climate change mitigation and adaptation

Reference: page 148-150.

Dia's decarbonisation pathway targets a 43% reduction in Scope 1 plus Scope 2 (market-based) emissions by 2030 in absolute terms, and a 51% reduction in Scope 3 emissions per euro of turnover by 2030, both against the relevant base years (2020 for Scope 1/2, 2023 for Scope 3, recalculated this year for new categories).

Detailed carbon-budget tables (pages 148-150) track actual emissions against annual budgets and 2030 targets by country: Spain's Scope 1 fell 9.1% against budget in 2025; Argentina's rose 13.1%, reflecting hyperinflation-driven cost dynamics rather than emissions growth. Scope 3 intensity in Spain fell 1.6% year-on-year. The company notes Dia "intends to pursue" SBTi validation but is not yet formally signed up (page 127).

Energy consumption and mix

Reference: pages 150-151 (Table 9).

In 2025 Dia Group consumed 948,041 MWh of energy (1,055,207 MWh in 2024), of which 24.07% was renewable (22.29% in 2024). Total renewable consumption was 228,195 MWh versus 719,846 MWh non-renewable; nuclear sources made up 12.77% of total consumption via the electricity mix.

As a distribution-sector company operating in a high climate impact sector (retail/distribution), Dia discloses energy intensity of 165.9 MWh per EUR million of sales (165.7 in 2024), split between 39.9 MWh/M€ renewable and 126.0 MWh/M€ non-renewable intensity, a 2.3% improvement in the non-renewable component.

Gross Scopes 1, 2 and 3 and Total GHG emissions

Reference: pages 151-156 (Tables 13-15).

Gross Scope 1: 195,470 tCO2e; Scope 2 market-based: 178,432 tCO2e (location-based: 183,623 tCO2e); Scope 3: 4,156,011 tCO2e, dominated by purchased goods (3,507,418 tCO2e, 76.5% of Scope 3, using Agribalyse product-level footprints for food). Total Scope 1+2(market)+3 emissions: 4,529,913 tCO2e in 2025 versus 4,681,237 tCO2e in 2024, a roughly 3% decrease.

Calculation uses the financial/operational control approach per the GHG Protocol across Spain and Argentina, with FOFO franchises reported in Scope 3 (category 14). The report states plainly: "None of Dia Group's activities are regulated under schemes that contemplate the use of emission rights, and therefore no disclosure is made under E1-7" (page 155).

Internal carbon pricing

Reference: page 156.

Dia Group uses a shadow pricing internal carbon price, informed by EU ETS, peer benchmarking and World Bank recommendations, used in investment decision-making but not booked in the Annual Accounts. Two rates are set: EUR 80-85/tCO2e for refrigeration-equipment purchases in Spain, covering 28% of gross Scope 1+2 GHG emissions, and EUR 50/tCO2e for electricity with a Guarantee of Renewable Origin, covering 50% of global Scope 2 emissions and 1% of Scope 3 (transportation/distribution of energy).

Rates are reviewed annually against market and regulatory changes and are intended to promote low-carbon investment and energy efficiency ahead of the SBTi-based 2030 targets.

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

Reference: page 156, cross-referring to section 5.1.4 (pages 133-145).

Dia Group states plainly: "The anticipated financial effects from physical and transition risks are detailed in section 5.1.4 Climate-related impacts, risks and opportunities (IRO-1)." That section quantifies residual financial impacts by named risk (PR1-PR5 physical, TR1-TR11 transition) against 2025/2030/2050 horizons, almost all assessed as "Slight (<EUR 3.7M)" after mitigation, versus inherent impacts as high as EUR 120 million (PR1, flood risk) or "Strong (>EUR 7.4M)" for TR1 (fluorinated-gas regulation).

Conclusion (page 144-145): "no material current or short-term physical risk has been identified" and "no significant climate transition risks have been identified," with opportunities similarly assessed as having no significant economic impact.

Policies related to pollution

Reference: page 159.

E2 materiality is scoped narrowly: Dia's Environmental Policy covers pollution prevention within the five-line structure (climate, pollution, water, biodiversity, circular economy), focused on refrigeration-equipment maintenance and the "Renewal" Plan for older, leakier equipment as the main source of direct Scope 1 pollution. Warehouses using ammonia or CO2 refrigerants have leak detectors and multi-level alarms with evacuation protocols and regular drills.

Notably, the company states: "given that it does not use substances of concern or of very high concern, it considers this aspect not relevant to its business model and therefore to its policy." The policy applies to all facilities and projects, including operations not directly managed by the group; the Audit and Compliance Committee oversees implementation.

Actions and resources related to pollution

Reference: page 159.

Pollution-mitigation actions are consolidated into the E1-1 Transition Plan (refrigeration renewal, fleet modernisation) rather than run as a separate pollution programme, since Dia's material E2 exposure is air pollution from refrigerant leaks and fleet emissions. In remodelling projects, "the Group raises awareness... with the operational chain of command assuming leadership and responsibility in the prevention of pollution," covering both waste generation and noise pollution at worksites.

No substances-of-concern action programme is disclosed, consistent with the company's assessment that this sub-topic does not apply to its business model (E2-1).

Targets related to pollution

Reference: page 159-160.

Targets are sub-topic specific. Air pollution (5.2.4.1): managed through the refrigeration Renewal Plan and vehicle maintenance described under E1-1/E1-3, with no separately stated numeric pollution target beyond the climate decarbonisation pathway. Water pollution (5.2.4.2): Dia cross-refers to its voluntary water-use objectives under E3-2. Soil pollution (5.2.4.3): no target is set, as the company states soil pollution "is not a material matter for the company" given its urban retail activity, though new builds and refits are aligned with EU Green Taxonomy "do no significant harm" pollution criteria for construction sites.

Pollution of air, water and soil

Reference: page 160.

Dia reports no sanctions for environmental violations in 2025. Air: non-GHG air pollution is attributed mainly to fleet-vehicle combustion; the report states 99.99% of the Group's total emissions breakdown corresponds to greenhouse gases reported under E1-6, implying non-GHG air pollutants are immaterial in volume. Water: "Dia Group has not recorded any environmental incident in terms of accidental discharges into the aquatic environment." Soil: "Dia Group has not recorded any environmental incident involving substances and pollutants spilled on the soil," consistent with the company's determination that soil pollution is not material given its predominantly urban retail footprint.

Substances of concern and substances of very high concern

Reference: page 160.

Dia Group reports a nil return for this sub-topic: "Dia Group's activity is not covered by the REACH Regulation (EC no. 1907/2006)." This is consistent with the company's E2-1 materiality scoping, which explicitly states it "does not use substances of concern or of very high concern" in its retail/distribution operations, unlike manufacturing-sector companies whose material IROs on this sub-topic concern chemical inputs to production.

Policies related to water and marine resources

Reference: pages 162-163.

The Water and Marine Resources chapter of Dia's Environmental Policy (Board-approved) commits to: complying with water legislation and international benchmark standards; managing water resources "efficiently and responsibly"; setting indicators and monitoring protocols for direct operations; integrating water into ESG risk management; communicating results transparently; and monitoring the indirect blue water footprint across the value chain.

New-build and refit water-saving measures aligned with the EU Green Taxonomy were introduced in 2025 for Spain: taps capped at 6 litres/minute, showers at 8 litres/minute, toilets at a 3.5-litre average flush, and urinals at 2 litres/hour, delivering an average 38.9% consumption saving versus standard-measure stores, with EUR 179.75 thousand CAPEX in 2025 rising to an estimated EUR 956 thousand by 2030.

Actions and resources related to water and marine resources

Reference: pages 163-164.

Actions centre on compliance, efficient management, ESG risk integration and value-chain engagement. The company uses both the FAO 1,700 m3/person threshold and the WRI Water Risk Atlas to classify facilities by water stress; 52% of Dia's activity occurs in water-stressed areas, with total consumption there of 557,088 m3, though the probability of a material water-availability risk is assessed as low since use is mainly sanitary/cleaning.

A marine-resources initiative, the "Circular Seas" collaboration with Coca-Cola, focuses on cleaning aquatic environments and circular-economy promotion, extending Dia's commitment "beyond direct marine pollution" despite its landlocked Madrid headquarters.

Targets related to water and marine resources

Reference: pages 163-164.

Dia targets a reduction in its water-consumption-to-net-sales ratio from 153 m3/EUR million (2024) to 130 m3/EUR million by 2030; the 2025 figure was already down to 152 m3/M€. All stores incorporate telemetry to monitor consumption and detect leaks, overseen by the Real Estate and Procurement Department with support from a specialised consultancy.

On marine resources, there is no quantified consumption target, but the Circular Seas partnership (see E3-2) serves as the company's conservation and sustainable-use initiative for marine resources.

Water consumption

Reference: page 164.

Total own-operations water consumption (freshwater withdrawn from the municipal network) was 1 hm3 (1,000,000 m3) in 2025, down from a restated 1.2 hm3 in 2024. Total water intensity was 214.0 m3 per EUR million of sales in 2025 (203.5 m3/M€ in 2024), calculated against Ordinary Income from sales per Note 19 to the Consolidated Annual Accounts (EUR 5,715 thousand in 2025; EUR 5,880 thousand in 2024).

Water consumption in water-risk and high-water-stress areas is calculated per facility and cross-referenced to the WRI Aqueduct platform classification (see E3-2 for the stress-category breakdown).

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: pages 182-186.

Dia's 2025 Resilience Plan for biodiversity follows the TNFD LEAP framework and is explicitly aligned to the Kunming-Montreal Global Biodiversity Framework and EU Biodiversity Strategy 2030. The underlying TNFD analysis identified 82 potential risks out of 105 analysed across the value chain, prioritising 15 potentially critical risks concentrated in meat, dairy and beverages, with water identified as the dominant cross-cutting natural asset (both provision and quality risk).

The plan runs on three horizons: short-term (1-3 years, data/traceability consolidation), medium-term (3-7 years, supplier diversification and efficiency), and long-term (over 7 years, full strategic integration and ecosystem-restoration objectives). Five named action lines cover knowledge-building, integration into the corporate risk map, supplier mitigation-measure tracking, protected-area store monitoring, and continuous review. The company is explicit about current limitations: traceability "is not equivalent to an official or verifiable supplier by supplier traceability," relying instead on public, industry and proxy geographic data (page 185).

Policies related to biodiversity and ecosystems

Reference: page 187.

The Biodiversity chapter of the Environmental Policy sets two goals: supporting best practice via certification programmes, and reducing raw-material risk through supply-chain traceability. Commitments include deforestation-free and ecosystem-conversion-free sourcing for soy, palm oil, cocoa, coffee and timber, consistent with EU deforestation deadlines; preference for RSPO, Rainforest Alliance, MSC, ASC, FSC and Animal Welfare-certified products; and stakeholder collaboration on biodiversity.

Dia Group states it "does not carry out biodiversity offsetting activities and does not work with indigenous communities." The policy summary is cross-referenced in chapter 4.3 MDR-P.

Actions and resources related to biodiversity and ecosystems

Reference: pages 187-189.

Dia applied EUR 30 thousand to the TNFD risk analysis and Climate/Biodiversity Resilience Plan in 2025. Notable sourcing actions: 8% of seafood from MSC/ASC-certified sources; 1,700 tonnes of national aquaculture fish purchased (+21% year on year, EUR 37 million spend); 2 new ASC-certified frozen fish products; 19 certified organic/bio/eco products (EUR 11 million sales); 100% of cellulose products FSC-certified (EUR 181 million sales); 253 animal-welfare-sealed meat/egg/dairy items, with cage-egg purchasing cut from 80% to 33% of Dia's egg supply (EUR 0.5 million investment).

On deforestation, 51,074 tonnes of EUDR-regulated commodities were marketed in 2025, with EUR 81 thousand CAPEX applied to an internal due-diligence tool ahead of the Regulation's entry into force.

Targets related to biodiversity and ecosystems

Reference: pages 190-191.

No explicit ecological thresholds were set in this first TNFD iteration; Dia instead completed "its first strategic goal in relation to biodiversity" by finishing the supply-chain LEAP evaluation. Seven forward targets are tabled with deadlines: extend TNFD analysis to more suppliers/categories by 2030; complete the meat-category TNFD evaluation by 2027; implement impact-minimisation measures in 100% of stores near protected areas (IBAs, SPAs, Natura 2000) by 2028; reduce own-operations water consumption via Taxonomy-aligned efficiency measures from 2024; prioritise MSC/ASC-certified fishing and aquaculture suppliers by 2029; guarantee 100% EUDR-compliant traceability when the Regulation applies; and reduce dependency on suppliers in critical-water-stress regions (Murcia, Valencia) by 2030.

Impact metrics related to biodiversity and ecosystems change

Reference: page 192.

Following the TNFD LEAP methodology (section 5.4.1), Dia identifies indirect biodiversity impacts concentrated in agricultural and livestock supply-chain practices dependent on ecosystem services, rather than direct impacts from its own urban retail operations. Five named structural risk types are tracked (R01 freshwater provision loss, R02 biomass/soil service loss, R05 water-quality degradation, R06 stable-energy-service failure, R07 regulatory access restriction), each mapped to a specific legal framework, region and likelihood assessment, with impacted assets quantified at EUR 31.1-84.6 million per risk.

The company states these impacts "do not immediately compromise the business's operational continuity" but "influence the resilience of suppliers and the stability of natural resource inflows."

Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities

Reference: pages 193-194.

Built on the TNFD LEAP "Assess" phase, Dia's biodiversity-risk financial assessment finds potential effects via increased operational costs, investment needs (supplier diversification, reutilisation technology) and reputational/compliance risk, though "these risks do not always entail a direct interruption of operations." Mitigation relies substantially on supplier-side measures: "all the analysed suppliers have measures to mitigate these risks."

Two deforestation-specific transition risks are quantified: TR1 (EUDR compliance, EUR 577 million / 12.5% of impacted assets, EUR 0.08 million allocated to mitigation in 2025) and TR2 (raw-material cost increases from EUDR), both with residual financial impact assessed as "Slight (<EUR 3.7M)" across 2025, 2030 and 2050 horizons.

Policies related to resource use and circular economy

Reference: pages 195-196.

Dia's Environmental Policy dedicates a chapter to circular economy, approved in 2024 and updated in 2025, overseen by the Audit and Compliance Committee and applicable to all business units without exception. Commitments cover: reducing virgin-material use and using renewable/recycled materials; planning and intensifying technology to reduce material/energy consumption and food waste; focusing on equipment maintenance to extend asset life; applying the waste hierarchy with a Zero Waste ambition for all warehouses; and setting and publishing circularity targets.

A detailed waste-hierarchy breakdown is cross-referenced under the E5-5/Waste section of this report.

Actions and resources related to resource use and circular economy

Reference: pages 196-203.

Eco-design: nearly 3,000 own-brand products analysed for recyclability since 2021; 86% of analysed Spanish own-brand products meet recyclability criteria; 491 SKUs redesigned under the ITENE sustainability guide, cutting virgin plastic by approximately 5.2 million kilogrammes. Checkout bags fell 9% year on year; Argentina launched 100% home-compostable checkout bags (TUV AUSTRIA Home/Industrial Compost and IRAM certified) in 2025.

Food waste prevention: a full Article 1/2025-aligned prevention hierarchy runs from order definition through reverse logistics; donations reached 1,549,477 kg globally (1,255,608 kg in 2024), with 631,674 kg in Spain alone via Food Banks and Caritas.

Circular waste management: all waste routed through warehouses at EUR 5.3 million annual OPEX, 100% Green-Taxonomy aligned.

Targets related to resource use and circular economy

Reference: pages 203-204.

Own-brand packaging: 20% less material by 2025 vs 2020 (Spain); 40% reduction in virgin plastic by 2030 vs 2020; 100% recyclable, reusable or compostable own-brand packaging by 2030 in Spain; 100% compliance with the incoming Packaging and Packaging Waste Regulation (2026-2029); 25% recycled plastic already incorporated into own-brand beverage bottles in 2025.

Food waste: reduce waste below 0.3% by 2029 (after already exceeding the prior 30%-by-2030-vs-2020 goal). Circular waste: 100% of Spanish warehouses "Zero Waste" certified (SAICA) by 2030 -- 9 of 11 already certified in 2025.

Resource inflows

Reference: pages 204-206 (Tables 24-26).

Material resource inflows for own operations in 2025: 94 new stores, 598 refrigeration units, 402 ovens, 408 furniture units and 1,277 computer units acquired; refrigerant gases consumed totalled 78,765 kg (down 7% from 85,050 kg in 2024); ancillary materials (paper/cardboard and plastic) totalled 8,585 tonnes (8,186 t in 2024), with recycled-content shares of 30% (paper) and 34% (plastic).

Purchased products for resale totalled 2,518,638 tonnes (Table 25), of which 2,510,045 t were non-plastic. Packaging purchased separately totalled 47,490 tonnes (10,478 t paper/cardboard, 37,012 t plastic; Table 26). Dia does not centrally track materials used by manufacturer-brand suppliers across its 10,702 marketed product items.

Resource outflows

Reference: page 207.

"As we do not accumulate significant stocks between years, we equate the information on products sold to the purchased products" disclosed under E5-4 (Table 25: 2,518,638 tonnes). Detailed waste-hierarchy outcomes for what leaves the organisation as waste, rather than as sold product, are disclosed under the Waste entry of this site (sourced from section 5.5.7.2, "Responsible waste management").

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Reference: pages 208-209.

Using the same Net Zero-by-2050 scenario basis as the climate analysis (1.5C by 2050 per both countries' NDCs), Dia assesses circular-economy transition risk from tightening EU packaging regulation. TR1 (non-compliance with national/EU packaging and packaging-waste rules): impacted assets of EUR 2,794 million (58% of relevant base), residual financial impact "Slight (<EUR 3.7M)" across 2025/2030/2050. TR2 (Deposit and Return System non-compliance): EUR 0.15 million allocated to mitigation via Dia's participation in the ASEDAS/AECOC sector DRS working group.

The packaging eco-design opportunity (O1) is assessed at the same EUR 2,794 million impacted-asset base, similarly "Slight" in residual financial terms, reflecting effective mitigation already in place.

Waste

Reference: page 207-208 (Table 27).

Dia's Zero Waste model, managed centrally through its warehouses at EUR 5 million annual OPEX, had 9 of 11 Spanish warehouses SAICA Natur-certified in 2025, certifying at least 95% diversion from landfill; 100% of bakery waste goes to animal feed and 100% of fruit/vegetable/organic waste to composting. Total non-hazardous waste: 72,619 tonnes in 2025 (65,509 t in 2024), up mainly due to store-network expansion (+7,109.84 t). Destination breakdown: 78.87% recycled, 4.36% energy valorisation, 9.10% composted, 0.85% reused, 6.82% landfill/incineration (Table 27).

Food waste specifically fell from 5,581,760 kg (2024) to 2,873,305 kg (2025), a 36%+ reduction, via redistribution systems at dark stores and expanded donation channels.

Policies related to own workforce

Reference: pages 217-218.

Own-workforce policies are Board-approved (via the Appointments and Remuneration Committee) and apply group-wide. The Code of Ethics commits to the International Bill of Human Rights, ILO fundamental conventions, OECD Guidelines, UN Guiding Principles and the Seoul Declaration on Safety and Health at Work, backed by an Ethics Channel with an investigation procedure. The People and Culture Policy, updated in 2025, and the Diversity, Equality and Inclusion Policy (approved 2024) govern working conditions, development and inclusion.

Additional related policies include the Directors' Remuneration Policy, Anti-Bribery Policy, Crime Prevention Model, Conflict of Interest Policy, and Crime Prevention and Anti-Corruption Policy, all applicable across Spain and Argentina.

Processes for engaging with own workers and workers' representatives about impacts

Reference: pages 218-219.

Labour Relations Directors in each country manage daily dialogue with workers' representatives. Employee engagement is measured via annual Employee NPS: Spain rose to 31.3 in 2025 from 23.40 in 2024; Argentina fell from 54.00 to 48.00. Participation was 64%, with lower engagement among shorter-tenured younger employees, a finding channelled into Dia Growth, a 2025 leadership and culture programme launched for all staff.

Channels include the corporate portal (95% registration in Spain, 87% in Argentina), tailored newsletters, the Ethics Channel, regular and biennial surveys, a middle-management network, and direct senior-leadership communications. In 2025, 8 employee conflict-of-interest cases were reported to the Ethics Channel (4 in 2024), of which 1 was confirmed.

Processes to remediate negative impacts and channels for own workers to raise concerns

Reference: page 218.

The Ethics Channel ("Ethics Line") is available to all employees, anonymously or identified, run by an external provider and managed internally by Regulatory Compliance. The Ethics Committee opens a file, verifies information, hears affected parties and witnesses, and issues a final report with recommendations. This process is the same mechanism described under S1-17 and the Group-wide G1-3 corruption-prevention model.

The People and Culture Plan addresses working-condition, satisfaction and turnover impacts identified in the materiality assessment (SBM-3), with continuous listening (focus groups, surveys) feeding directly into remediation actions such as the Dia Growth leadership programme.

Taking action on material impacts on own workforce

Reference: pages 220-221.

Actions span health and safety (risk assessments, PPE, audits, wellbeing programmes including Pilates, nutrition talks and 24/7 psychological support), work-life balance (1,768 annual working-hour cap, extended Sunday/holiday time off, flexible/remote work), and pay (10-20% wage increases in stores/warehouses by 2028 in Spain, up to EUR 120/year transport assistance, 10% staff discount, Flexible Remuneration Plan with 15% more enrolees in 2025).

Dia Argentina earned Top Employers Institute certification in 2025 (one of only 18 companies in Argentina, the first supermarket chain to do so); Dia Argentina and Dia Spain (74th) were recognised in Merco Talento 2025; Dia Spain ranked among InfoJobs Awards 2025's top 50 employers. A corporate volunteering programme, "Every Day Counts" (EUR 1 million annual OPEX), engaged 200 volunteers reaching almost 6,500 beneficiaries in 2025.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 222-223.

The People and Culture strategy runs on "3 Golden Rules" (Dream Big, Share the Vision, Move Fast) and eight cultural transformation goals (Celebrate, Promote Innovation, Continuous Learning, Recognise Customer Centricity, Embrace Growth Mindset, Power the Dream, Ignite Passion), phased 2024 (Best of Both), 2025 (Dream Big) and 2026-2029 (Experience).

No single numeric workforce target anchors this section; instead, effectiveness is tracked via the metrics detailed at S1-6 through S1-17 (turnover, NPS, pay gap, training hours, safety indices), consistent with Dia's acknowledgment elsewhere that "not all identified material IROs have associated targets" in the strict MDR-T sense.

Characteristics of the undertaking's employees

Reference: pages 226-227 (Tables 31, 36).

Total workforce at 31 December 2025: 16,887 employees (16,896 in 2024): 13,701 in Spain (81%), 3,186 in Argentina (19%); 10,375 women (61.4%), 6,512 men. By category: 86 Directors, 1,483 Managers, 15,318 Employees. By contract: Spain is 93% permanent/7% temporary; Argentina is 99% permanent/1% temporary. Full-time/part-time split: 13,806 full-time, 3,081 part-time group-wide.

Annual average contracts: 15,890 permanent and 1,363 temporary (2025); full-time 14,085, part-time 3,169. Employee turnover (Table 39) reached 190% for men and 244% for women in certain age/category segments at Group level, reflecting the high-turnover nature of store and warehouse retail employment, particularly pronounced in Argentina.

Characteristics of non-employee workers

Reference: page 230.

In 2025, Dia Group had 983 non-employee workers (974 in 2024), 100% supplied via temporary employment agencies and consulting companies registered on a corporate portal, working mainly in cleaning, security, online sales, inventory-taking, customer service and IT development. This category excludes third-party-company workers without a direct placement relationship, who are covered instead under ESRS S2 (value-chain workers).

Collective bargaining coverage and social dialogue

Reference: page 230.

100% of Dia Spain's employees were covered by a collective agreement in both 2025 and 2024 (company or sector level); Argentina's coverage was 74% (73% in 2024), giving 95% Group-wide coverage. Dia has 577 trade union representatives in Spain and 45 in Argentina (638 combined in 2024) across 58 Works Councils. No European Works Council agreement exists.

In May 2025, Dia Spain signed its VI Collective Agreement (2025-2028) with trade unions, covering almost 14,000 employees: guaranteed annual pay rises, a new 24-hour psychological/social service, gender-violence protection measures, extended Sunday/holiday time off, and expanded remote-working and paid-leave provisions.

Diversity metrics

Reference: pages 231-234.

Workforce diversity: 68 nationalities across 2 countries; 61.4% women overall, 48.88% women in leadership (directors/managers); gender balance at the Board reached parity in 2025 after three new female directors joined. Generational split: 2% Boomers, 39% Gen X, 45% Millennials, 14% Gen Z. 2.91% disability-equivalent employment rate (2.53% in 2024), against a legal 2% minimum requirement.

DEI initiatives include the "Women in warehouses" plan, the "Sumate: no-label inclusion" disability plan, a renewed TOP DIVERSITY COMPANY certification (third consecutive year), the INTRAMA 2025 Gender Diversity Award, and in Argentina a "Connecting Opportunities" employability programme and LGBTQ+ alliance with Mocha Celis. Women leaders up to CEO-3 level in Argentina reached 34%.

Adequate wages

Reference: page 234.

Dia Group "always ensures compliance with at least the minimum wages established by law and in the workers' collective agreements," factoring in purchasing power, national productivity trends, and collective-agreement pay tables. In 2025, Dia applied EUR 407 million to employee wage payments. Average remuneration by gender: men EUR 27,254 (EUR 26,201 in 2024), women EUR 22,247 (EUR 21,510); by professional category: Directors EUR 291,871, Managers EUR 43,786, Employees EUR 20,320.

Social protection

Reference: pages 234-236.

Dia Group guarantees social protection against illness, unemployment, work accidents, acquired disability, parental leave and retirement through public programmes plus company benefits: accident insurance, life insurance (death/disability per collective agreements), global business-travel assistance, a 10% staff discount, and the Flexible Remuneration Plan (health insurance, food/childcare vouchers, transport cards, training), which saw a 15% rise in enrolment in 2025. An employee salary-advance app is also available. Directors' remuneration for 2025-2028 consists of a fixed cash allocation plus deferred share-based remuneration (details incorporated by reference to the Annual Report on Directors' Remuneration).

Persons with disabilities

Reference: pages 236-237 (Tables 44-45).

Disability-hiring rate rose from 2.53% (2024) to 2.91% (2025): 103 male and 115 female direct employees, plus 181 full-time equivalents via Special Employment Centre contracts (total 399 equivalent employees, Table 44), against the legal minimum of 2% for companies above 50 employees (Royal Legislative Decree 1/2013). Disabled employees in the workforce by category and age (Table 45) total 218 direct employees (66 under-30, 104 aged 30-50, 48 over-50), concentrated in the Employees category.

Training and skills development metrics

Reference: pages 238-241.

Dia Group provided 156,951 training hours in 2025 (269,923 in 2024). Performance evaluation covered 2,285 Employees, 1,410 Managers and 68 Directors (Table 46). Notable 2025 programmes: Dia Growth reached 1,990 people via 50+ speakers; 9,000 people trained in LGBTQ+ diversity; 25 Certificates of Professionalism completed; 43% of franchisees (521) completed Dia Campus training and 88% of own teams plus 89% of franchises engaged with strategic-planning training.

Recruitment, skills development and promotion run through a job-evaluation model compliant with Royal Decree 902/2020's appropriateness, completeness and objectivity criteria, supported by the Dia Academy training catalogue.

Health and safety metrics

Reference: pages 242-244 (Table 50).

A Joint Prevention Service covers Safety at Work, Industrial Hygiene, Ergonomics and Applied Psychosociology internally, with an external provider for health monitoring; the CEO holds ultimate policy responsibility. 2025 figures: 456 accidents (men) / 421 (women); accident frequency rate 37 (men) / 24 (women) per million hours; severity index 1.25% (men) / 0.80% (women); zero work-related deaths; 100% of employees covered by the health and safety system. Absenteeism hours totalled 966,100 (men) and 2,046,553 (women), with a dedicated absenteeism-prevention programme in Spain covering management training, local monitoring, recurring-absence action plans and a post-leave return-to-work support service.

Work-life balance metrics

Reference: page 244-245 (Table 51).

All Group employees (100%) are entitled to parental and family leave. In 2025, 471 employees (3%) took parental leave (664 in 2024), with a 97% return rate and 92% retained in post after 12 months. 15,592 employees (92%) were entitled to family-reason leave; 13,701 (81%) to reduced working hours, of which 1,039 used it for legal guardianship. The right to disconnect is codified in Article 73 of the Collective Agreement, applicable regardless of working-day type, per Spanish Act 3/2018.

Compensation metrics (pay gap and total compensation)

Reference: pages 245-246 (Tables 52-53).

Group-wide gross pay gap: 15.60% in 2025 (18.76% in 2024), calculated per AR 98 methodology. By country and category (Table 53): Spain's Directors gap is 42.24% (driven by seniority distribution), Managers 9.76%, Employees 16.08%; Argentina's overall gap is markedly lower at 4.63%. Women comprise 61.44% of the workforce and 48.88% of leadership positions, up from 48.59% in 2024. The CEO pay ratio (highest-paid individual to median employee) is 170.67.

Incidents, complaints and severe human rights impacts

Reference: pages 246-247 (Table 54).

In 2025, the Ethics Channel processed 23 admitted communications (60 in 2024), including 15 complaints against the company (55 in 2024). 2 discrimination/harassment cases were confirmed (1 in 2024); all reported persons left the Group; no associated sanctions were received. No OECD National Contact Point complaints were filed. 8 conflict-of-interest communications were logged, 1 confirmed.

The Code of Ethics, updated in 2023, underpins the channel, which is managed internally by Regulatory Compliance via an external reporting platform guaranteeing confidentiality, whistleblower protection and non-alterable traceability.

Policies related to value chain workers

Reference: pages 250-251.

Dia's Policy on Human Labour Rights in the Value Chain, aligned to the UN Guiding Principles and ILO fundamental conventions, applies to all suppliers and franchisees ("partners") across all regions. The CEO leads implementation; the Audit and Compliance Committee monitors progress; ultimate responsibility sits with the Board. Dia's stated approach favours remediation over termination: "Dia's approach... is not based on terminating the business relationship when a problem is found, as the Company recognises that it may deprive people who suffer oppression of crucial income."

In 2025, Dia detected no breach of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines involving value-chain workers. The policy is complemented by a Corporate Franchise Policy and a Mandatory Rule on franchisee selection and relationship management.

Processes for engaging with value chain workers about impacts

Reference: pages 251-253.

Dia participates in AECOC's Sustainability Committee and measures supplier satisfaction annually via NPS: 60 in 2025 (58.4 in 2024) in Spain; Argentina uses the Advantage Report, ranking Dia 4th in the retail sector (5th in 2024). In 2025 Dia joined the UN Global Compact's future "Sustainable Suppliers" skills programme (launching 2026). Franchisee engagement achieved an NPS of 57 (58 in 2024), supported by Dia Campus (109,301 training hours, 4.9/5 rating), the Multi-Franchise Talent Plan, and a Franchisee Selection and Onboarding Service.

Suppliers complete a detailed questionnaire covering food, nutritional, commercial, environmental and social/governance quality criteria.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 253-254.

Suppliers, franchisees and contractors are informed of the Code of Ethics and the Ethics Channel, available to them "with the same guarantees as any employee," using the same investigation procedure described under S1-17 and section 7.1.1.2 (Ethics Committee). Franchisee satisfaction is additionally tracked via NPS (89 points Group-wide in 2025), with the Franchise Director responsible for integrating survey feedback into strategy. Where an incident is confirmed, "Dia will establish action plans and will engage with the suppliers to address the root causes."

Taking action on material impacts on value chain workers

Reference: pages 255-256.

99% of suppliers have formally committed to the Human Rights Policy (91% in 2024). Dia works with Sedex for risk-based supplier due diligence: of 3,118 total suppliers, 294 carry inherent risk, of which 176 have completed due diligence. Higher-risk suppliers (by country and product-type risk) are prioritised for self-assessment. Planned 2026 actions (EUR 0.3 million annual OPEX) include expanded social/labour audits, stronger supplier relationships and broader approval criteria beyond human rights (work-life balance, equality).

The Management Committee and Audit and Compliance Committee conduct regular monitoring of action implementation.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 256.

Strategic Sustainability Plan 2026-2029 targets for value-chain workers: 70% franchisee NPS; create 1,400 new franchise jobs; maintain at least 95% local suppliers; establish CSDDD-aligned sustainability due-diligence control mechanisms; and reach a MERCO reputation score of 7.3. For 2026 specifically, Dia plans 1,200 new jobs in Spain (30% more than the 900 created in 2025), including 200 positions at the new Leon warehouse.

Policies related to affected communities

Reference: page 260.

Community-facing commitments are distributed across the Policy on Labour Human Rights in the Value Chain, the Responsible Marketing Policy, the Franchise Policy, the Code of Ethics (Ethics Channel described under S1-17) and the Diversity, Equality and Inclusion Policy, all group-wide and accessible on the corporate website with periodic internal-dissemination campaigns. Dia commits to respecting community human rights per the International Bill of Human Rights, UN Guiding Principles, OECD Guidelines and ILO Declaration, including providing redress for adverse impacts.

Processes for engaging with affected communities about impacts

Reference: page 260.

Dia measures social impact using the Prosper4ALL tool (developed by CODESPA within the Business Observatory for Inclusive Growth), scoring 62 questions across internal (S1), immediate-external (S2/S4) and wider-external (S3/society) scopes on four values: economic value, social value, ethical practices, and promoting shared prosperity, generating a consolidated Inclusive Growth Indicator aligned to ESRS and SDG frameworks.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 260-261.

The Ethics Channel, described fully under S1-17, is available to communities and any external third party to report concerns or breaches, with the same confidentiality and non-retaliation guarantees extended to employees. Suppliers, franchisees and contractors are likewise informed of its existence, per section 7.1.1.2 (Ethics Committee).

Taking action on material impacts on affected communities

Reference: pages 261-264.

Dia's community strategy runs three lines: the "Eat Better Every Day" programme (healthy, affordable food access); stimulating franchise and local-supplier entrepreneurship; and generating positive local impact. In 2024, Dia's activity contributed EUR 6.8 billion to Spanish GDP (0.43% of the total, EUR 3.5 generated per euro of direct activity), supporting roughly 100,000 direct, indirect and induced jobs, including 25,000 direct franchise jobs; 1,455 local suppliers received EUR 4,250 million in purchases.

To minimise construction disruption, Dia follows EU Green Taxonomy-aligned measures (work-hour restrictions, dust suppression, covered waste containers, silent-wheel delivery equipment). The "Eat Better Every Day" survey (20,000 contacts) found 95% of respondents concerned about their food but only 3 in 10 managing a healthy diet, with price cited as the main barrier by 73%.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: pages 264-268.

Following Board approval of the Sustainability Plan 2026-2029, Dia prioritises Eat Better Every Day actions (nutrition reformulation, alliances with FEN/SENC, supplier nutrition initiatives) and measures community effectiveness via Prosper4ALL. Sector alliances span CEOE, AEF, ASEDAS, AECOC, Ecoembes, Foretica, the UN Global Compact (joined 2025) and the Argentine AAMF.

2025 social-action campaigns with AECC, Red Cross, FESBAL and others raised funds (e.g. EUR 0.2 million for the Big Collection) and together with food donations and volunteering benefited 78,323 people in Spain and Argentina; corporate volunteering reached 6,441 people and employability programmes supported 567 beneficiaries. No community human-rights incidents were recorded in 2025.

Policies related to consumers and end-users

Reference: page 271.

Consumer-facing policies include the Responsible Marketing Policy (honesty and integrity in communications), the Corporate Information Security Policy (confidentiality, integrity and availability of customer data, GDPR-aligned), and Dia Group's Food Safety Policy governing product safety principles. Dia commits to respecting consumer human rights per the International Bill of Human Rights, UN Guiding Principles, OECD Guidelines and ILO Declaration, summarised in chapter 4.3 (MDR-P).

Processes for engaging with consumers and end-users about impacts

Reference: pages 271-272.

Food safety: 88.7% of suppliers held Global Food Safety Initiative certification in 2025 (87.9% in 2024); 3,227 internal/external audits were conducted (3,500 in 2024, of which 216 related to divested Portugal); 28,668 training hours were delivered to 7,167 Spanish store/warehouse employees on food handling.

Communications: the Customer Experience department manages engagement; customers are informed of the Ethics Channel (0 admitted customer complaints in 2025 versus 4 in 2024). The Double Materiality Analysis includes an annual customer/consumer survey feeding directly into the Strategic Sustainability Plan.

Processes to remediate negative impacts, and channels for consumers and end-users to raise concerns

Reference: pages 273-274 (Table 59).

Dia's Customer Relations Centre handled 580,415 communications in 2025 (599,532 in 2024), of which 179,000 were complaints/grievances (201,203 in 2024); 99% were closed. Three main channels operate: telephone (51% of Spanish contacts, 43% Argentina), email and WhatsApp, the last growing significantly in 2025. Customer NPS reached 51.0 in Spain and 76.9 in Argentina, both improved on 2024. Social media reach spans six platforms (e.g. 3.75 million Facebook followers, 1.37 million TikTok). Physical Complaints Forms are available in all stores, and the Ethics Channel remains available per S1-17.

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and opportunities

Reference: pages 275-276.

Dia dedicates over EUR 2 million annual OPEX to customer management across 123+ agents and four service agencies. 2025 actions include: Argentina's online-order improvements (consolidated delivery loading, tamper-evident bag seals, digital dispatch and delivery-validation-code pilots); Spain reaching 864,084 online orders (+11.66% year on year) and fully eliminating paper from online-order fulfilment; and "Olimpiadas Saludiables," a nutrition-education programme for employees' children in Argentina.

Promotional investment rose 17% to EUR 175 million in Spain, enabling discounts up to 40% on 200+ products and up to EUR 500/year in customer savings via Dia Club. No consumer human-rights complaints were received in 2025.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 276 (Table 60).

The Strategic Sustainability Plan sets a Customer NPS Spain glidepath from 51% (2025) to 58% (2026), 62% (2027), 66% (2028) and 75% by 2029. For 2026, Dia will increase promotional spend to EUR 180 million (up EUR 5 million), with fresh products representing almost 40% of weekly offers. Over the last five years Dia has dedicated more than EUR 700 million to promotions and its 10-million-member loyalty club. Additional "Affordable wellbeing" actions include vulnerable-group food access via Food Banks, Caritas and Women Foundation, and further nutrition alliances with FEN/SENC.

Business conduct policies and corporate culture

Reference: pages 284-285.

Dia Group's Regulatory Compliance division operates under a Compliance Policy alongside a Conflict of Interest and Related-Party Transactions Management Policy, an International Sanctions Policy (centrally validated supplier screening since 2021), a Crime Prevention and Anti-Corruption Policy, an Anti-Bribery Policy and a Gift Policy. An Anti-Fraud and Anti-Corruption Programme identifies risks by jurisdiction (bribery, facilitation payments, money laundering, conflicts of interest, political-party financing, influence peddling), noting higher inherent risk in Argentina than in Europe and in procurement/expansion activities.

The Ethics Channel, compliant with EU Directive 2019/1937, underpins all of this; it is described fully under S1-17. All policies apply without exception to every Group company, Board member, manager, employee and contracted person.

Management of relationships with suppliers

Reference: pages 285-287.

Suppliers engage via a portal (historical databases, billing, inventory status), regular management meetings, a sales/support team and a satisfaction survey. Relevant policies: the Corporate Quality and Food Safety Policy, the Policy for Respect of Human Rights in the Supply Chain, and the International Sanctions Policy. Dia "does not have a specific supplier payment policy" but follows legally set payment terms.

Given the agricultural sector's elevated human-rights risk, 99% of suppliers and franchisees have formally committed to Dia's human-rights principles (91% in 2024). In 2025, Dia invested EUR 275 million to acquire 78,000 tonnes of meat from local suppliers (+40% year on year) and applied EUR 4,250 million to Spanish/Argentine supplier purchases overall, of which 96% was local procurement.

Prevention and detection of corruption and bribery

Reference: pages 287-288.

Dia Group's Crime Prevention Model (CPM), applicable to its Spanish companies, combines the Code of Ethics, a Compliance Policy, risk assessment and monitoring, a dedicated compliance body (the Audit and Compliance Committee), formation-of-will protocols, a financial-resources-management model, a Supervision Plan verifying control effectiveness, mandatory training, the Ethics Channel and a disciplinary system.

In 2025, 10,443 employees were trained in ethics (10,915 in 2024), reaching 70% of the Group's headcount; anti-corruption-specific courses "Zero tolerance of corruption" (1,610 employees, 4.7/5 rating) and "Dia's second ethical principle: Integrity" (1,547 employees, 4.6/5) were delivered. Dia states: "no cases of corruption or bribery were detected or have come to be known in which actors in Dia Group's value chain are implicated."

Targets related to business conduct

Back-filled: this report is prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a standalone G1-3 disclosure requirement.

Dia Group does not state a single numeric target for corruption prevention; instead, effectiveness is tracked through its Supervision Plan, which "verifies regularly" that CPM control measures remain effective (page 287), and through annual monitoring of outcomes: zero confirmed corruption or bribery incidents in both 2025 and 2024 (G1-4), and training coverage tracked year over year (70% of headcount trained in ethics in 2025, up from 72% the prior year, with named course-level completion and satisfaction scores for anti-corruption modules, page 288).

The Audit and Compliance Committee receives written documentation on ethics-training content, and ongoing Regulatory Compliance training has been embedded as a standing strategic objective of the Board (page 288), consistent with MDR-T's "effectiveness tracked in the absence of a stated target" limb.

Incidents of corruption or bribery

Reference: page 288.

"In 2025, no incidents of corruption or bribery have occurred in any of the jurisdictions in which Dia Group operates. Consequently, the organisation has not been exposed to any monetary sanctions, nor has it been required to adopt any specific actions in relation to this aspect." The Ethics Channel, available to employees and the stakeholders defined in Spanish Act 2/2023, recorded no confirmed corruption/bribery complaints implicating Dia Group's value chain in either 2025 or 2024 (Table, page 283: 2 corruption-related communications closed in 2025, none confirmed).

Political influence and lobbying activities

Reference: pages 288-289.

Dia Group engages public administrations directly and via sector organisations on three lines: environment/energy transition (deforestation regulation, packaging/DRS rules), workforce and production-system standards, and consumer-rights communication regulation. Per its Code of Ethics, "Dia Group does not make financial contributions for political purposes or to obtain preferential treatment," nor does it sponsor or donate for such purposes.

Dia states it "is not registered in any of the transparency registers established at European Union, national or autonomous community level," and confirms none of its Board/management-body members held a public post in the two years before appointment.

Payment practices

Reference: pages 289-290 (Table 62).

Dia Group's average payment period to suppliers was 41 days in 2025 (44 days in 2024), per the methodology of Spanish Act 15/2010 (as amended). Total payments made: EUR 4,280,716 thousand (EUR 4,172,269 thousand in 2024); total pending payments: EUR 419,474 thousand. 82% of 2025 payments (EUR 3,517,201 thousand, 945,000 invoices) were made within the legal maximum term, up sharply from 67% in 2024. Dia had 1 disciplinary proceeding for late supplier payment in 2025. No specific supplier-payment policy exists beyond adherence to statutory payment terms (see G1-2).