Dino Polska

The role of the administrative, management and supervisory bodies

Management Board

The corporate body that manages the Company's operations and assets and represents it externally before courts, authorities and third parties, is the Company's Management Board. The Management Board makes decisions in all matters, including the management of material impacts, risks and opportunities in relation to sustainability matters that are not reserved by the law or the Articles of Association as exclusive powers of the Supervisory Board or the Shareholder Meeting. Management and oversight of sustainability-related impacts, risks and opportunities is a shared responsibility of all Management Board members and is based on their general mandates of management board members.

Professional experience of the Management Board Members of Dino Polska is mainly related to the food retail sector. The expertise of the Management Board Members in business conduct and sustainability matters is the result of their work for Dino Polska over the past 20 years. Additionally, the Company's Management Board has permanent access to experts from the Company's departments: Environmental Protection, Human Resources, Health and Safety, Product Quality Development and the Management Board Office, who have experience and training related to sustainability. The Management Board is free to engage external experts as needed.

Management Board Composition

At the end of 2024 the Management Board consisted of three members: Izabela Biadała, Michał Krauze and Piotr Ścigała. On 11 December 2024 the Company's Supervisory Board adopted a resolution appointing Marcin Jędraszak as a Member of the Management Board of DINO POLSKA S.A. for the joint term of office of the Management Board, which began on 1 January 2025.

As at the date of publication of this Statement, Dino Polska is represented by a Management Board consisting of the following four people:

• Ms. Izabela Biadała (51), Management Board Member, Chief Logistics and Distribution Center Officer: Has worked for Dino Polska since 2002. She has held managerial functions since 2011. She was responsible for the implementation of the IT sales system in the Dino store network and headed the Database Management Department. From 2020 to 2024, she was the Director of Operations and Administration. She is currently the Chief Logistics and Distribution Center Officer. She oversees the operation of departments related to transport and logistics, distribution centers and IT. She has been a member of the Management Board since 2020.

• Mr. Marcin Jędraszak (42), Management Board Member, Director of the Sales Department: Has worked with Dino Polska since 2004. Initially, he was employed as a warehouse employee / cashier, then he served as a Dino store manager from 2005 to 2006 and as the manager in Dino's central distribution center from 2007 to 2012. He also worked in the administration, car fleet and non-commercial procurement areas. From 2013 to 2018 he served as a buyer, and from 2020 to 2022 he managed the functioning of the Dino store network. He has served in the capacity of Sales Director since 2018, followed by Director of the Sales Department. In January 2025 he became a Member of the Company's Management Board.

• Mr. Michał Krauze (42), Management Board Member, Chief Financial Officer: Has worked for Dino Polska since 2002. In 2002-2016, he was an accountant, then an independent accountant and a financial controller. Since 2016 he has been the Chief Financial Officer responsible for managing finance, control and risk. He oversees the operation of departments involved in the geographic expansion of the Dino network. He has been a Management Board Member since 2014.

• Mr. Piotr Ścigała (68), Management Board Member, Chief Control Officer: Has worked for Dino Polska since 2003. From 2003 to 2004 he was a Dino store manager and then from 2004 to 2014 he served in managerial functions in the head office where he was responsible for supporting current and new Dino stores and for the operational control of stores. In 2014 he took the post of Director of the Control Department to organize and supervise the operation of departments engaged in quality assurance and the operation of Dino stores and distribution centers. He has been a Management Board Member since 2022.

Women represent 25% of the Management Board members of the current term of office. In 2024, due to the lower number of Management Board Members, this ratio was 33%.

Governance of Sustainability Matters

The management of sustainability matters in Dino Polska is part of the general governance system over the Company's operations, which is based on the principles of the Polish Commercial Company Code.

The Company's long-term development strategy sets out the main directions of Dino Group's development, but does not define precise goals. The Company's ambitions in the key impact areas are pursued in a similar manner: the Management Board of the Company defines the directions for action, particularly in issues such as reducing the intensity of environmental impact, ensuring the highest quality and safety of products offered in Dino stores, preventing food wastage, or reducing employee turnover, but it does not set specific targets.

Supervisory Board

The Dino Polska Supervisory Board consists of 5 members: The Supervisory Board exercises ongoing joint oversight of the Company's activities, including the implementation of the Company's sustainability-related policies. The expertise of the Supervisory Board Members in business conduct and sustainability matters results primarily from their previous professional experience.

As at the publication date of this Statement, the Dino Polska Supervisory Board consists of five members:

• Mr. Tomasz Biernacki (51) – Supervisory Board Chairman: Tomasz Biernacki is the founder and the main shareholder of DINO POLSKA S.A. He has been building the Dino brand since the beginning of his professional career. Tomasz Biernacki is also a member of corporate bodies of numerous companies in various sectors of the economy.

Independence and Committees

Two out of five members (40%) of the Supervisory Board (i.e. Piotr Borowski and Sławomir Jakszuk) satisfy the criteria for independence prescribed by the Best Practices of WSE Listed Companies and the independence criteria set out in the Act on Statutory Auditors. There is one committee operating as part of the Supervisory Board, the Audit Committee. In addition to overseeing financial reporting, the Audit Committee also monitors the sustainability reporting process, participates in decisions regarding the selection of the audit firm to review the Statement, and oversees corporate governance issues.

The Company's management and supervisory bodies do not include representatives of employees or other workers.

Integration of sustainability-related performance in incentive schemes

Covered roles

Compensation for the Members of the Company's Management Board includes fixed and variable compensation. Supervisory Board Members receive fixed monthly compensation and are not covered by incentive programs.

Incentive structure

Variable compensation may be paid in the form of quarterly and annual bonuses. The bonuses are discretionary in nature and are awarded for performing the budget planned and adopted by the Supervisory Board before the beginning of a given financial year.

Linkage to sustainability performance

The key budget items forming the basis for awarding the annual bonus are set in accordance with the Company's main strategic objectives as presented and updated in the Company's annual reports. When awarding a bonus, the Supervisory Board also takes into consideration the effective operation of quality and safety procedures with regard to the quality and safety of products offered in the Dino stores as well as initiatives undertaken by the Company to reduce its environmental impact, however it is not based on specific targets.

Linkage to financial performance

The annual bonus depends on the amount of the Company's consolidated net profit earned in the financial year for which it is paid.

Remuneration policy basis

In accordance with the Compensation Policy for Management Board and Supervisory Board Members of DINO POLSKA S.A., compensation of the Members of the Company's Management Board is set in a way that supports the achievement of strategic objectives and ensures the maintenance of the Company's secure financial standing.

Strategy, business model and value chain

Business profile and products/services

Dino is a nationwide network in Poland consisting of medium-sized grocery supermarkets located close to customers' places of residence. The Company is one of the fastest growing retail grocery networks in Poland measured by the number of stores and revenues.

Dino Polska's business model combines the advantages of the format provided to customers by medium-sized stores situated in convenient locations, in most cases close to their places of residence or featuring much more traffic, with the ability to open new stores quickly and an attractive product range, comprising primarily branded and fresh products at competitive prices.

As at 31 December 2024, the Dino network consisted of 2,688 stores with a total selling area of 1,061,214 square meters. Dino Polska has many years of experience and a proven capacity to open new stores, enabling it to grow its store count by 873, i.e. 48%, in the period of three years up to 31 December 2024.

A standard Dino store is 400 square meters in size and has a parking lot for customers, including parking spots for people with disabilities and a bicycle parking rack. Most of the stores are outfitted with their own PV installations whereby they can benefit from electricity generated by renewable energy sources.

Dino's product range comprises about 5 thousand stock keeping units (SKU), including mainly fresh products in the fruit and vegetable, dairy, meat and bakery sections, as well as other food, chemical and cosmetic products sold under well-known brands. To provide customers with products of the highest quality Dino's stores are supplied with fresh products daily.

Every Dino store has a traditional fresh meat counter with counter staff. Agro-Rydzyna, a Dino Polska wholly owned subsidiary operating a meat processing plant, supplies its high-quality meat and cold cuts to these counters. Agro-Rydzyna is the sole supplier of fresh meat and the main supplier of cold cuts to the Dino stores. The whole production of Agro-Rydzyna is sold through the Dino store network. The meat processing plant operated by Agro-Rydzyna is located in Kłoda and Jastrowie (Wielkopolskie voivodship).

Significant groups of products/services and revenue share

The core business is retail sales through a network of non-specialized stores, with food and beverages predominating. This business generated revenues of PLN 29,084,011 thousand in 2024, which represented 99.4% of total revenue.

The major product categories sold by the Dino network include the following:

• Fresh groceries, including the meat products supplied by Agro-Rydzyna: 40% of sales revenue in 2024
• Other groceries: 48% of sales revenue in 2024
• Non-grocery products: 12% of sales revenue in 2024

In 2024, 14.2% of the consolidated sales of the store network came from the sales of products of the Agro-Rydzyna meat processing plant. 85.8% of the retail chain's revenue came from the sale of goods supplied by companies over which Dino Polska has no control and for which it competes with other retail networks. In 2024, out of the foregoing 85.8% of revenue, 79.3 percentage points came from the sale of goods under manufacturers' brands, which are generally well recognized by Polish consumers. The remaining 6.5 percentage points came from sales of Dino Polska private label products.

Fresh products accounted for 40% of sales revenue in 2024. Dino focuses on offering branded products at attractive prices. In 2024 they accounted for the vast majority of revenue (net of fresh products, including the products of the Agro-Rydzyna meat processing plant).

Significant markets/geographies

Dino Polska's operations are conducted in Poland. The offer of Dino stores is addressed to all consumers. The Dino Group's operations are conducted in Poland. As at 31 December 2024, the Dino network consisted of 2,688 stores with a total selling area of 1,061,214 square meters.

Dino stores are located close to customers' place of residence to ensure that customers are able to shop for their first-need articles quickly and conveniently. The rapidly growing Dino store network shortens the distance between consumers and a modern, organized grocery retail network enabling them to save time and save on the costs associated with traveling to more distant stores.

Employees by geography

At the end of 2024, the Dino Group had 49,887 employees and created 8,004 new jobs during the year. All operations and employment are in Poland.

Value chain description

Upstream value chain

The Dino Group's value chain, in addition to its own operations (the Dino store chain, distribution centers and meat plant), includes upstream entities, in particular:

• Suppliers and producers of agricultural, food products and other FMCG products
• Raw material suppliers to the Agro-Rydzyna meat processing plant
• Suppliers of materials, utilities and service providers
• Transport companies (transporting goods between the Group's distribution centers and stores)
• General contractors responsible for the construction of Dino stores and distribution centers

The Dino Polska Group has a diversified supplier base including above all producers and their main representatives. Developing and strengthening existing ties with suppliers and expanding the supplier base to include local producers and producers of lesser-known brands, is a regular element of Dino Polska's activities.

Key suppliers of Dino Polska are producers of food and other fast-moving consumer goods (FMCG) and suppliers of agricultural products with annual sales exceeding EUR 50 million. They are generally Polish producers or Polish subsidiaries of international FMCG producers. None of Dino Polska's suppliers accounts for more than 5% of sales in Dino stores. Top 10 suppliers (without the Agro-Rydzyna meat processing plant) accounted for 14.4% of the network's sales.

The main raw material used by Agro-Rydzyna for production is pork half carcasses, sourced from Polish producers of this raw material. Neither Agro-Rydzyna nor other Dino Polska subsidiaries are involved in animal husbandry and slaughtering business.

Downstream value chain

Downstream entities in particular include: consumers of food and FMCG products (customers of Dino stores).

Key inputs and outputs

Dino stores are supported by ten distribution centers owned by the Dino Group and the transport network comprised by independent transport companies and managed by Dino Polska.

Dino sources most products directly from producers or their main representatives. The large and constantly growing volumes of orders we place with suppliers accrue benefits in the form of economies of scale. They enable Dino to make purchases on favorable terms that should improve steadily as the sales network continues to expand.

Dino Polska's operating strategy is based on a standard store design, equipped with parking places for its customers and supplied with fresh products every day of the week. Most stores have a selling area of 400 square meters. Each store offers its customers approx. 5 thousand stock keeping units (SKUs), for the most part well-known branded products and fresh products as well as a meat counter manned by store staff.

Strategy and sustainability-related goals

Dino Polska's strategy calls for continued growth by focusing on three key areas:

1. Continuation of rapid organic growth in the number of stores (+283 new stores in 2024)
2. Continued growth in LFL sales revenue in the current store network (LFL +5.3% in 2024)
3. Consistent improvement in profitability (-0.8 p.p. movement in the EBITDA margin in 2024)

Dino Polska's intention is to execute its growth strategy by further utilization of the Dino Group's strengths and its competitive advantages, while taking into account the sustainability-related impacts, risks and opportunities, in particular by:

• Respecting human rights and maintaining a good workplace for Dino Group employees and associates – the Dino Group is one of the largest employers in Poland, and its effective operation and further development depend on its ability to retain existing employees and attract new ones

• Building long-term business relationships based on trust, responsibility and honesty – Dino Polska is the third largest food retailer in Poland in terms of revenue, but it is significantly smaller than the other two dominating store networks; the ability of the Dino network to maintain an attractive product assortment in its stores, to adapt effectively to changing consumer preferences and to achieve satisfactory financial results depends to a significant extent on the quality of the Dino Group's relationships with its suppliers and the commercial terms agreed

• Reducing the intensity of environmental impacts – the Dino Group is a large and rapidly growing business entity with a significant demand for electricity, which is the main source of the Group's Scope 2 greenhouse gas emissions; the Dino business model, which entails ownership and a high level of standardization of stores and distribution centers, allows the Company to effectively implement solutions that reduce demand for electricity or generate electricity in its own renewable energy sources

• Ensuring the high quality of services and products offered in Dino stores – Dino Polska's main commitment to customers is to make the product assortment of Dino stores match their needs, while ensuring the safety and the highest quality of the products offered; this commitment can only be fulfilled with the active participation of Dino employees and by using the strict procedures and quality standards in place at each level of Dino Group's operations; the effects of these activities are reflected in consumer confidence in Dino stores and, consequently, in growing sales revenues

• Activity in line with the idea of "Dino – Closest to You" – The Company's mission statement is executed mainly through location of the stores. The advantages of this growth strategy work on several levels:

  • Making a positive contribution to local labor markets – every store gives jobs to roughly a dozen people
  • Convenience and savings for consumers – reducing the distance separating consumers from a grocery store, which frequently enables them to reach the stores on foot or by bike
  • Reducing burdens on the natural environment – stores are well suited to the places where they operate; due to the local nature of Dino stores and the growing density of the network, Dino employees and customers traverse shorter distances to work and do their daily shopping, thereby cutting emissions of greenhouse gases

Development incorporating the natural environment

Dino Polska gives consideration to risks related to its climate impact and the climate's impact on the business model selected by the company. The execution of Dino Polska's environmental policy focusing on gradually curtailing the Dino Group's environmental impact calls for maintaining a high level of standardization and refining Dino's store format and distribution centers to facilitate the implementation of environmentally-friendly initiatives and enhance their effectiveness. These initiatives are followed in particular in the following three areas:

• Using electricity originating from renewable sources, in particular by installing PV panels on store rooftops and distribution centers and curtailing electricity consumption by implementing electricity management systems and consistently replacing equipment with equipment that saves more and more energy and facilitates energy recovery

• Improving the effectiveness of the transport network by doing the following: i) shortening the distance between stores and distribution centers (in line with the growing density of the Dino store network and the development of the network of distribution centers; ii) using a fleet of trucks that meet more and more stringent environmental standards, especially with ever lower exhaust emissions; and iii) optimizing the usage of delivery vehicles and loading space and collaborating with Dino Polska's suppliers to reduce the number of trips made by trucks that do not carry a full load or are empty (return travel)

• Following rational waste management and minimizing the mass of waste produced in particular by doing the following: i) adhering to and promoting waste segregation procedures in all areas of its business; ii) recycling all return packaging made using film, cardboard and glass; iii) reusing selected return packaging in the order assembly process; iv) using multi-use packaging in product distribution (subject to appropriate disinfection), to prevent the emergence of disposable plastic waste with every delivery; v) cooperating with suppliers to employ multi-use packaging for fruit and vegetables so that waste is not created in the form of disposable bulk packaging

Business model scalability

Dino Polska's business model is scalable to a large extent. It comprises centralized management supported by suitable IT systems, a logistics network based on ten distribution centers (as at the end of 2024) and the transportation network managed by Dino. These drivers, combined with operational leverage and store network maturation form a robust foundation for growing the Dino Polska Group's profitability.

Interests and views of stakeholders

The Dino Group is an element of the environment in which it operates – it is an employer, business partner, part of the local community, where it recruits employees and to which it directs the offer of Dino stores, and an organization whose activity exerts an impact on society and the natural environment. The main stakeholders that impact and are impacted by the Dino Group are: store customers (consumers), employees and associates, suppliers of raw materials and commercial merchandise, the company's shareholders and the natural environment.

Dino store customers (consumers)

Key interests and concerns: The core business and, at the same time, the key responsibility of Dino Polska is to satisfy consumer needs in line with the highest standards. This commitment is understood as providing consumers with merchandise and products that are safe and of high quality, offering a diverse assortment at attractive prices, and locating stores close to where people live.

Engagement approach: Dino's cooperation with consumers is reflected by the Company's willingness to consider their voice in the process of improving various aspects of Dino stores and their product offering. For this purpose, the company has a dedicated organizational unit, the Customer Service Office, whose role is to receive comments and handle all reports, including customer complaints. This process is regulated by an internal procedure.

Engagement channels:

• A form on the www.marketdino.pl website
• Reports to a dedicated phone number and e-mail address
• Reports sent in by mail

Communication channels:

• A promotional newspaper presenting the offering of products with price promotions
• Dino's social media profiles
• Notice boards in Dino stores
• A periodic e-mail newsletter
• Website at www.marketdino.pl

Integration into strategy: Dino Group's development strategy and business model are well refined and generally do not change significantly, but the successful implementation of the strategy and business model depends on their acceptance by consumers. Accordingly, the Company listens to the voices of consumers and strives to meet their needs with respect to the product range and store format. The Company respects all consumer rights and their human rights. The Company believes that further development of the Dino store network will increase the scope of positive impact on consumers by shortening the distance between them and the grocery store.

Employees and associates

Key interests and concerns: Employees and associates are the people who directly contribute to the intensive development of Dino Polska, the execution of its strategy and building competitive advantages and market power. The employees and associates of Dino Group are key assets in the Dino Group on account of their knowledge, skills and competences. Key needs include: adequate remuneration, space for professional development, work-life balance, and opportunities for people with disabilities.

Engagement approach: In order to ensure a friendly working environment, the Group observes all employee rights and acts with respect for human rights, which is governed by internal regulations and the Code of Conduct. The development strategy and business model are well refined and generally do not change significantly, but in terms of hiring policy, recruitment and working conditions, the Group is making efforts to listen to the needs of employees and make appropriate changes to strengthen its position as an attractive employer.

Engagement channels:

• Direct submission of comments to the Store Operations Office
• Comments to immediate supervisors during daily interactions
• The Intranet
• Employee mailings
• Notice boards
• An internal system of rules and regulations, policies and procedures

Integration into strategy: The Company believes that the continued rollout of the Dino store network will lead to a significant increase in the number of Dino Group employees in the future, which will increase the positive impact exerted on employees by providing them with stable jobs.

Suppliers

Key interests and concerns: The key needs of this stakeholder group are: predictability and long-term character of the cooperation, timely payments and adequate prices for products, determined through a negotiation process.

Engagement approach: The goal of cooperation with suppliers is to ensure that the customers of the Dino network have access to the widest possible range of products that meet safety and food quality standards. In its relations with suppliers, the Group focuses on partnership, responsibility, honesty and long-term cooperation, which allows it to effectively address the key needs of this stakeholder group. The material sustainability values that guide Dino Polska are collected in the Dino Polska Code of Conduct for Suppliers, which forms an attachment to the commercial contracts concluded with these entities.

Engagement channels: The main channel of communication with suppliers is the bilateral relationship managed by a separate organizational cell, i.e. the Procurement Department.

Shareholders

Key interests and concerns: Dino Polska's commitment to its owners is to develop the Dino Group's business in a stable and secure manner, with a clearly defined long-term strategy and with respect for the interests of other major stakeholders (interested parties).

Stakeholder composition: Dino Polska's shareholders, in particular its founder, who serves as the Supervisory Board Chairman and owns shares representing 51% of the Company's share capital, have provided the Company with the necessary experience and financial resources to develop its business. Since April 2017, Dino Polska has been a public company listed on the Main Floor of the Warsaw Stock Exchange. Dino Polska is majority-owned by Polish capital; in addition to the founder, our shareholders (co-owners) include Polish investment and pension funds that manage the savings of Poles (including the network's employees and customers), retail investors on WSE and foreign investors.

Engagement channels:

• Current and financial reports (as required by law)
• Website at www.grupadino.pl
• Conference calls after the publication of financial results
• Direct meetings with shareholders
• Shareholder meetings

Natural environment

Identified as a main stakeholder that impacts and is impacted by the Dino Group.

Use of stakeholder views in materiality assessment

The process of understanding impacts and assessing their materiality was supported by the conclusions from the following consultations with stakeholders:

• Customers: The process to handle customer comments and reports, conducted by the Customer Service Office, which provides a better understanding of the impacts on Dino network customers
• Communities: Reports on the operation of Dino stores, received by the Company through channels other than the Customer Service Office, which provide a better understanding of the impacts on the stores' neighbors
• Employees: Dialogue with the trade union of Dino Polska employees, conclusions from reports and comments received from employees in the course of their daily work by the HR Department and the Store Operations Department, and conclusions from the annual anti-bullying survey, in order to better understand the impacts on employees
• Suppliers: Dialogue with the Group's suppliers, conducted in the course of their daily cooperation and negotiation processes, to obtain a better understanding of the impacts exerted by the Dino Group on these entities, their employees, and the impacts of the suppliers and the products manufactured by them on the natural environment
• Shareholders: Dialogue between the Company and its shareholders at Shareholder Meetings and during one-on-one meetings, in order to understand the expectations of this stakeholder group that go beyond financial performance
• Survey: A survey created for the materiality analysis process, addressed in 2024 to the Company's employees, suppliers and customers and examining the Dino Group's assessment of the impact of specific sustainability matters on these stakeholder groups

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

All identified material impacts, risks and opportunities are covered by the Disclosure Requirements related to ESRSs. The Group has not found material impacts, risks and opportunities related to the individual entities.

ESRS E1 – Climate change

Climate change – climate change mitigation (environmental impact)

Type: Actual negative environmental impact

Time horizon: short, medium and long term

Value chain location: The impact is due to the activities of the Group and its value chain

Description: The impact is related to greenhouse gas emissions, in particular:

• from the combustion of fuels in the means of transport used (in own operations and at every stage of the value chain)
• from escaping refrigerants (in own operations and at every stage of the value chain)
• from the generation of purchased electricity (in own operations and at every stage of the value chain)

Although the EU Taxonomy does not include the sector, in which Dino Group conducts its core business, among the largest contributors of greenhouse gas emissions in Europe, given the large and growing scale of its operations, climate change mitigation has been identified by the Company as a matter that has material impact on the environment.

Resilience and interaction with strategy/business model: The Group believes that its strategy and business model are highly resilient to the material impacts and risks arising from climate change mitigation, but it recognizes that the mitigating measures may result in significant additional capital expenditures, depending on the rate of implementation.

Opportunities: Opportunities to mitigate the negative impacts are related to increasing the energy efficiency of own operations, developing own renewable energy sources, and increasing the use of electricity from renewable sources, using refrigeration equipment with refrigerants with the lowest possible global warming potential or natural refrigerants, and using vehicles with the lowest possible or zero greenhouse gas emissions.

Dino Polska's business model, which requires a high level of store standardization, is conducive to the effective implementation of the above initiatives. Additionally, the Company's business model, which allows it to open stores in less urbanized areas and closer to consumers' homes, reduces the distance consumers have to travel to reach a grocery store, often enabling them to walk or bike to Dino stores, or reducing the distance they have to travel by car or other means of transport powered by fossil fuels.

Value chain considerations: The largest part of value chain GHG emissions is related to the growing or manufacturing of products that Dino Polska purchases from its suppliers and sells in Dino stores. These are mainly food products, and the opportunities for supply chain entities to mitigate these emissions are similar to those described above for the Group's own operations. In the longer term, depending on changing preferences and financial capabilities of consumers, Dino Polska may also become more influenced by the level of a product's carbon footprint when selecting suppliers and the product range for Dino stores.

Climate change – climate change mitigation (financial risk)

Type: Financial risk

Time horizon: medium and long term

Value chain location: Concentrated in the Group's own operations

Description: This risk is associated with the potential regulations that, in connection with the European Union's climate obligations may obligate various businesses to implement specific capital-intensive solutions or solutions requiring the incurrence of major operating expenditures. As of the date of this Statement, the Company does not identify any significant new regulations linked directly to the issue of climate change mitigation, compliance with which could have a material impact on the Dino Group's financial position, financial performance or cash flows.

Climate change – energy (environmental impact, financial risk)

Type: Environmental impact and financial risk

Time horizon: medium and long term

Value chain location: Concentrated in the Group's own operations

Description: Purchases of electricity from fossil fuel sources covers the majority of the Dino Group's demand for electricity. This is one of the reasons for the actual negative environmental impact described above.

At the same time, the Company identifies significant financial risks that is concentrated in the Group's own operations and may materialize in the medium and long term. This risk is associated with the large volumes of electricity used by the Dino Group. Electricity prices are highly volatile, and it cannot be ruled out that, if they increase significantly in the future, the Group will be unable to reflect such costs in a corresponding change in the prices of the goods and merchandise it offers, which can ultimately have a significant negative impact on its financial results.

Mitigation: To prevent this risk, the Group is undertaking initiatives to optimize and reduce its electricity consumption and to develop its own renewable energy production capacity.

Physical risks and opportunities: The climate-related risks described above are only climate-related transition risks. The Dino Group monitors physical risks and climate-related opportunities. The Company is of the opinion that the climate-related physical risks and opportunities are not material in the short and medium term. Simultaneously, the Group thinks that, in the short and medium term and as part of its current strategy, it will be able to prevent the emerging risks, among others by pursuing an active product assortment policy and a flexible policy in respect of creating inventories.

The short-term risks related to climate-change pertain in particular to the intensification of extreme weather phenomena such as extremely high ambient temperatures, extreme rainfall and windstorms. They may lead to higher operating expenses related to disruptions in the supply of electricity, or the need to store food in safe conditions and in the right temperature; they may also cause damage to the Group's property and adversely affect the timeliness of food supplies to distribution centers and stores. The Company has the pertinent action plans in the event of extreme weather-related phenomena. These same factors may cause damage to crops and disrupt food production and therefore they may ratchet up the volatility of the prices of foodstuffs.

In the long term and with the intensification of climate change, the physical risks may require additional initiatives to be undertaken within the current business model. In the long-term, the warming of the climate may pose a threat to crops, reduce the area and yield of crops, which in the face of climbing global food demand contributes to the risk of limited availability and substantial price growth. As a result, the Company may be compelled to search for alternative products and incur incremental expenses, which it may not be able to offset through efficiency gains or suitable price hikes. These phenomena may affect in a similar way the production capabilities of the Dino Group itself, which is the owner of the Agro-Rydzyna meat processing plant. In accordance with the Company's evaluations made to date, the impact of these phenomena should not be of a material nature for the Dino Group in the long term.

Scenario analysis: In addition to the assessment outlined above, the Company does not deem it necessary to conduct advanced resilience or scenario analyses related to climate impacts on Dino Group's activities.

ESRS E3 – Water and marine resources

Water and marine resources - intensive use of water in agricultural activities and food production processes (environmental impact)

Type: Actual negative environmental impact

Time horizon: short, medium and long term

Value chain location: The impact results from upstream activities in the value chain

Description: The impact is linked to products offered in Dino stores. Food production and agricultural activities use large amounts of water, which can have an adverse environmental impact and the availability of this resource, especially in areas exposed to water-related risks.

Own operations: Water withdrawal in Dino Group's own operations, per employee, was 1.2 m3 per month in 2024. The corresponding ratio for water consumption was 0.2 m3. Taking into account the dispersed nature of its operations and the fact that water withdrawal is mainly for utility purposes of employees and for food production at the Agro-Rydzyna meat processing plant, the Company considers its water withdrawal to be below the accepted standards for these operations and does not consider its environmental impact to be material in this context.

Risk assessment: The Company has a diversified supplier base, a high degree of flexibility in its supply chains and offers a wide range of products in its stores. Accordingly, water-related issues do not pose a significant risk to the Group's operations.

ESRS E5 – Resource use and circular economy

Circular economy – waste (environmental impact)

Type: Actual negative environmental impact

Time horizon: short, medium and long term

Value chain location: Due to the Group's activities

Description: The impact is related to the fact that it generates a significant amount of waste, mainly packaging and organic waste.

Resilience and interaction with strategy/business model: The Group believes that its strategy and business model are highly resilient to the material impacts and risks arising from waste-related issues, but it recognizes that the mitigating measures may result in significant additional capital expenditures, depending on the rate of implementation.

Mitigation: Ways to mitigate the negative impacts include using reusable packaging; implementing selective waste collection in all areas of the Group's operations, and transferring waste to specialized companies for recycling; working with suppliers to optimize packaging; and using fully recyclable materials in the production of packaging.

Current and expected impacts: Current and expected impacts on the business model and value chain include, in particular, the need for consistent implementation of the principles of a circular economy, which may generate additional operating expenses and capital expenditures in the short to medium term, but will ensure regulatory compliance in the long term and should result in reduced costs of waste disposal.

Circular economy – waste (financial risk)

Type: Financial risk

Time horizon: medium and long term

Value chain location: Concentrated in the Group's own operations

Description: This risk is associated with the potential regulations that, in connection with the European Union's climate obligations may obligate various businesses to implement specific capital-intensive solutions or solutions requiring the incurrence of major operating expenditures. As at the publication date of this Statement, an example of such regulations is Directive 2019/904 of the European Parliament and of the Council of the European Union on the reduction of the impact of certain plastic products on the environment, which forms grounds for introducing the "deposit system" in Poland. The deposit system obliges stores with an area of more than 200 square meters to organize the collection of plastic packaging, glass bottles and metal cans. Accordingly, each Dino store will have to be equipped with an appropriate device serving this purpose.

ESRS S1 – Own workforce

As a result of the double materiality analysis, Dino Polska has identified the following impacts related to the entire workforce of the Dino Group. All employees that may be affected by the following entity are included in the scope of disclosure in accordance with ESRS 2. The Group has not identified any material negative impacts to which individuals with specific characteristics, working in specific contexts or undertaking specific activities may be exposed to). The identified material IROs do not require a change in strategy or business model. Dino Group's employees are primarily employed under an employment contract (a detailed characteristics of Dino Group's employees is provided in Note ESRS S1 (S1-6) - Characteristics of the undertaking's employees). The company does not have any transition plans and therefore does not identify any transition-related impacts on employees. The Dino Group does not operate in locations with a significant risk of incidents of forced labor, compulsory labor or child labor.

Own workforce – certainty of employment (employee impact)

Type: Actual positive impact on employees

Time horizon: short, medium and long term

Value chain location: Own operations

Description: This impact is related to the Company's approved development strategy. Dino Polska is one of the fastest growing retail grocery networks in Poland. So far, the number of Dino stores has increased by at least a dozen percent each year, which was accompanied by the creation of new jobs. In 2024, the workforce of the Dino Group workforce increased by 8 thousand employees, from 41,883 to 49,887. The Company expects to be able to maintain its high growth rate in the long term, which, in addition to a significant creation of new jobs, including new jobs for people with disabilities, will create conditions for secure employment of current employees, their professional growth and promotions (these matters are discussed in more detail in ESRS S1 - Own workforce).

Own workforce – working conditions, equal treatment and opportunities for all (employee impact)

Type: Potential negative impact on employees

Time horizon: short, medium and long term

Value chain location: Each area of the Dino Group's own operations

Description: The impact is exerted on all employees and relates to each area of the Dino Group's own operations. The Dino Group has almost 50 thousand employees and is one of the largest employers in Poland. Incorrect management of the human resources function, particularly in terms of working conditions and employee training, may expose employees to workplace accidents or excessive working hours. Possible incidents of unequal access to promotions and training or incidents of discrimination may have a negative impact on the psychological well-being of employees. Since the success of the Group's development strategy relies on its ability to retain existing employees and attract new ones, this impact obliges the Company to continuously develop and improve its processes for managing the human resources area. These processes include efficient recruitment of new employees, proper scheduling of working hours, training to enable professional development and health and safety training, and a well-functioning channel of communication with employees. The company will allocate adequate organizational and financial resources and believes that it can effectively counteract these impacts. However, if the above-mentioned impact materializes, and given high demand for new employees and the very low unemployment rate in Poland, this may cause problems in finding new employees and create financial risks for the Group. Given the decentralized nature of the Company's operations (2,688 stores in more than 2,200 towns and cities) and the effectiveness of its recruitment processes to date, the Group does not consider this risk to be significant.

ESRS S4 – Consumers and end-users

As a result of the double materiality analysis, the Dino Group has identified the following consumer-related impacts. All consumers that may be affected by the following entity are included in the scope of disclosure in accordance with ESRS 2. Consumers affected by the company are those who shop in Dino stores. The company addresses its offering to all consumers regardless of age, gender, social status or membership in specific groups. The Company has not identified any specific groups of consumers who are subject to separate impacts other than those listed below. The identified material IROs do not require a change in strategy or business model.

Consumers and end-users – social inclusion of consumers (consumer impact)

Type: Actual positive impact on people

Time horizon: short, medium and long term

Value chain location: Own operations (result of adopted development strategy and business model)

Description: The impact is a result of the adopted development strategy and business model, which enables the Group to build its distribution network in areas with a relatively low level of urbanization, including small towns and rural locations. In these areas, it is often necessary to use transportation and travel to distant locations to reach a grocery store that offers a wide assortment in all relevant product categories, attractive prices, and high-quality fresh products (fruits, vegetables, cold cuts, meat, bread, and dairy products). Geographic expansion of the Dino network exerts a positive impact on people and, to a certain extent, the environment by shortening the distance between consumers and a modern, organized grocery retail network enabling them to save time and save on the costs associated with traveling to more distant stores. This also means that they have to use their cars to a lesser degree.

Dino Polska expects to be able to continue its geographic expansion strategy in the long term, which, in addition to the positive effects for consumers, creates and will create opportunities for growth in the value of the business conducted, sales revenues generated and profits.

Consumers and end-users – food quality and safety (consumer impact)

Type: Potential negative impact on people

Time horizon: short, medium and long term

Value chain location: Due to the Company's core business (own operations and value chain relationships)

Description: The impact is related to the food offered in Dino stores. The impact may materialize in particular through incidental violations of the requirements of food law and in the area of the quality of products offered. It may have a negative impact on the health of consumers. The Group may be involved in this impact both through its relationships in the value chain (failure of product manufacturers to ensure appropriate food quality and safety characteristics) and through its own operations (production of fresh meat and cold cuts; food quality and safety procedures during transport and sale, in particular ensuring proper cold chains).

Resilience and interaction with strategy/business model: The Group believes that its strategy and business model are highly resilient to this impact. It has a refined business model based on its own network of stores with a highly standardized format, its own warehousing facilities and a centrally managed network of transportation companies. The high quality requirements for product suppliers and the level of standardization of stores and distribution centers allow the Group to implement product quality and safety procedures efficiently and effectively. A dedicated Product Quality Development Department oversees this process at every stage of the Company's activities.

Current and expected impacts: Current and expected impacts on the business model and value chain include, in particular, the need to maintain adequate resources (Product Quality Development Department, Procurement Department) and efficient processes to select the product assortment for Dino stores, and the need to manage quality and safety at the stage of storage, transportation and sale of food products.

ESRS G1 – Business conduct

Business conduct - corporate culture; protection of whistleblowers; prevention and detection of corruption and bribery; management of relationships with suppliers, including payment practices (financial risks)

Type: Financial risk

Time horizon: medium and long-term

Value chain location: Concentrated in the Group's own operations

Description: Dino Polska operates on a large scale. It is one of the largest grocery retail networks and one of the largest employers in Poland. The Company cooperates with a very large number of suppliers. Cooperation with these companies is crucial to the success of the Dino Group's growth strategy. Dino Polska is also a public company listed on the Warsaw Stock Exchange. Improper practices in the areas of corporate culture, protection of whistleblowers, anti-corruption and supplier relationship management can result in penalties, loss of confidence of key stakeholders, financial performance and shareholder value of the Company. Accordingly, the Company has implemented a number of policies and procedures in the above areas to prevent the above risks from materializing. These risks have no ongoing financial impact on the Dino Group.

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

In 2024, Dino Polska performed the double materiality analysis for the first time based on the ESRSs and the EFRAG Implementation Guidance Materiality Assessment (IG1, May 2024).

The ESRSs require this Statement to include sustainability information related to all impacts, risks and opportunities ("IROs") arising from environmental, social and governance issues that are considered to be material from in terms of impact materiality, financial materiality or both. Impact materiality is understood as the impact of a company on society or the environment through sustainability matters. Financial materiality refers to the risks or opportunities that sustainability matters present to the company and its financial results.

Governance of the process

In 2024, the Company established an internal group of experts (the "ESG Committee"; composed of heads or directors of the following departments: Environmental Protection, HR, Legal, Investor Relations, Management Board Office and internal auditors) to review the Company's existing understanding of the impacts, risks and opportunities related to sustainability matters in its Group and value chain in the context of the requirements of the ESRS, and to conduct a double materiality analysis compliant with the ESRS.

Step-by-step methodology

The process defined in the ESRSs for identifying IROs and assessing their materiality was performed by the ESG Committee. The ESG Committee relied on the results of the Group's general management and risk management systems. In these systems, risks, impacts and opportunities are identified and managed at the level of each organizational cell in the ordinary course of business and in reference to the tasks and objectives of those cells. In order to support the Company's risk management system, a central risk matrix is established as a tool for monitoring and prioritizing the internal audit process.

The process used by the ESG Committee to identify and assess IROs consisted of three stages:

Stage I - Analysis of operations and value chain

Analysis of all areas of the Group's operations, its strategy, financial statements, assets, products, services and business relationships, as well as the upstream value chain, and identification of stakeholders (i.e., parties that can impact or be impacted by the Dino Group).

The purpose of this stage was to properly and fully understand the entire value chain, to identify the impacts in which the Dino Group is involved through its own operations and business relationships, and to identify key stakeholders. Given that the Group operates in Poland and its business entails the sale of food and, to a lesser extent, other FMCG products, it was not considered necessary to focus on specific operations, geographic areas, business relationships or other factors that could increase the risk of negative effects.

The outcome of this stage of work is described in the following notes: ESRS 2 (SBM-1) – Strategy, business model and value chain and ESRS 2 (SBM-2) – Interests and views of stakeholders.

Stage II - Identification of sustainability matters and IROs

Identification of sustainability matters, their actual and potential IROs and mapping of these matters on the sustainability matters defined in the topical ESRS.

As a first step, the ESG Committee reviewed and completed the sustainability matters identified in previous years. This resulted in a list of approximately 70 IROs. These IROs were determined on the basis of the following sources of knowledge:

• i) the risk management process
• ii) the internal audit process
• iii) the internal control process
• iv) the management controlling and internal reporting process
• v) the general business management processes, in particular the management processes in the environmental, HR and procurement areas
• vi) the product quality and safety management process
• vii) the process for handling customer comments and reports

In a second step, the IROs identified in this way were mapped to the sustainability matters defined in the topical ESRS and presented in ESRS Standard 1 - Appendix A - Application Requirements - item AR16 ("Table AR16").

The mapping of the list created in the first stage to Table AR16 enabled the identification of possible matters specific to the Group's operations that are not included in the topical ESRS.

Stage III - Assessment and identification of material IROs

The ESG Committee analyzed the materiality of the impact of all matters using the methodology presented below in this chapter. At the same time, the same methodology was used to analyze and assess all sustainability matters defined in Table AR16. This approach made it possible to identify any discrepancies and gaps between the materiality assessment of the impacts resulting from the matters defined by the company and the impacts resulting from the matters defined in the topical ESRS, and to verify the accuracy of the assessment accordingly.

Inputs to the assessment

The process of understanding impacts and assessing their materiality was supported by the conclusions from the following consultations with stakeholders:

• the process to handle customer comments and reports, conducted by the Customer Service Office, which provides a better understanding of the impacts on Dino network customers
• reports on the operation of Dino stores, received by the Company through channels other than the Customer Service Office, which provide a better understanding of the impacts on the stores' neighbors
• dialogue with the trade union of Dino Polska employees, conclusions from reports and comments received from employees in the course of their daily work by the HR Department and the Store Operations Department, and conclusions from the annual anti-bullying survey, in order to better understand the impacts on employees
• dialogue with the Group's suppliers, conducted in the course of their daily cooperation and negotiation processes, to obtain a better understanding of the impacts exerted by the Dino Group on these entities, their employees, and the impacts of the suppliers and the products manufactured by them on the natural environment
• dialogue between the Company and its shareholders at Shareholder Meetings and during one-on-one meetings, in order to understand the expectations of this stakeholder group that go beyond financial performance
• a survey created for the materiality analysis process, addressed in 2024 to the Company's employees, suppliers and customers and examining the Dino Group's assessment of the impact of specific sustainability matters on these stakeholder groups

Other sources of the ESG Committee's knowledge of the potential impacts of the Group through its links in value chains were reports from external experts, in particular: international research and rating agencies (MSCI, S&P, Morningstar Sustainalytics) and a reporting standards development organization (SASB), which identified key impact areas for the food retail sector. The ESG Committee also analyzed the most recent sustainability reports of four companies operating in the same sector as Dino Polska, and in some cases used selected research and academic publications.

Scoring criteria for impact materiality

In accordance with the requirements of ESRS 1, the assessment of impacts was based on their severity (in the case of negative impacts) and scale and scope (in the case of positive impacts). In the case of a potential impact, its probability was also determined.

The severity was assessed from the perspective of affected individuals or the environment and determined on the basis of:

• the scale of severity, by which the Group means determining how severe the impact is
• the scope of the impact, that is, how extensive the impact is
• the irreversibility of the impact, i.e., the potential to repair the effects

For the purpose of assessing each of the above three characteristics, the Group used a 5-point classification, as described in the tables below.

Classification for environmental impact assessment

(in the case of scale, examples of definitions for negative impacts are given in parentheses)

Classification for human impact assessment

(in the case of scale, examples of definitions for negative impacts are given in parentheses)

Probability classification

Probability classification used in the process of assessing the materiality of potential impacts, risks and opportunities (note: the full table showing frequency descriptions was referenced but not fully reproduced in the excerpts).

Frequency and timing

In 2024, Dino Polska performed the double materiality analysis for the first time.

Transition plan for climate change mitigation

Formal transition plan status

The Company does not have a formal transformation plan. As of the date of publication of this Statement, there is no decision on when to adopt such a plan. Notwithstanding the above, the Company is making efforts to reduce its greenhouse gas emissions intensity, which is explained in ESRS E1 (E1-2) and ESRS E1 (E1-3).

Policy approach

Dino Group's environmental policy is aimed curtail gradually the environmental impact exerted by the Group. It calls for maintaining a high level of standardization and refining Dino's store format and distribution centers to facilitate the implementation of environmentally-friendly initiatives and enhance their effectiveness.

During the period of Dino Group's rapid growth, the gradual reduction of environmental impact, in terms of greenhouse gas emissions, is understood to mean:

• i) the reduction of greenhouse gas emissions associated with the Group's existing assets (mainly the existing stores, distribution centers and the Agro-Rydzyna meat processing plant, and
• ii) the reduction of the greenhouse gas intensity (the amount of CO₂ per unit of revenue) of Dino Group's Scope 1 and 2.

Key decarbonization levers

Dino Polska's climate impact mitigation efforts are based on two main decarbonization levers: energy efficiency and the use of renewable energy.

Relevant activities include:

• Increasing the use of renewable energy in the Group's operations by installing photovoltaic panels on stores and distribution centers (in 2024, the Company installed photovoltaic panels on the roofs of 338 stores, thereby increasing the total capacity of its own renewable energy installations from 82.9 MW to 98.9 MW; by the end of 2024, its own photovoltaic installations were operating on the sites of 2,476 stores and 3 distribution centers of the Group).
• Reducing electricity consumption by optimizing and gradually replacing equipment and lighting with increasingly energy-efficient and energy-recovery equipment, as well as implementing advanced

Policies related to climate change mitigation and adaptation

Environmental Policy

Dino Group's environmental policy is aimed at curtailing gradually the environmental impact exerted by the Group. It calls for maintaining a high level of standardization and refining Dino's store format and distribution centers to facilitate the implementation of environmentally-friendly initiatives and enhance their effectiveness.

Scope: The policy applies across the Dino Group's operations.

Governance:

• Implementation of the Policy is the responsibility of the head of the Environmental Protection Department
• The Management Board of Dino Polska and the Subsidiaries provide the necessary financial, technical and organizational resources for the implementation of the Policy

Key content / principles:

• Identification of applicable legal and other environmental requirements and consistent compliance with them
• Rational management of materials and utilities and reduction of utility consumption, especially electricity and water
• Proper waste management and minimization of the mass of waste generated
• The use of reusable packaging and the optimization of packaging
• Minimizing commodity and production losses
• Increasing the efficiency of the transportation network
• Increasing the use of renewable energy
• Commitment of own workforce (in the Code of Conduct) and suppliers (in the Supplier Code) to the economical and efficient use of natural resources
• Improving store and warehouse procedures and technological processes
• Investments and equipment upgrades aimed at reducing adverse environmental impacts
• Constant supervision of machinery, equipment and technical infrastructure
• Monitoring of environmental aspects
• Improving competence in environmental impact management

Public availability: The policy was pursued by the Dino Group in 2024 and previous years. It was adopted by Dino Polska in the form of an official document in 2025.

Links to international standards: Agro-Rydzyna, Dino's meat processing plant subsidiary, implemented an ISO 14001 environmental management system in 2022, certified accordingly.

Implementation monitoring: In applying and periodically updating its environmental policy, the Dino Group takes into account internal and external factors relevant to the Group's business purpose and strategy, including:

• Ensuring the Group's continued growth, liquidity and adequate financial results
• Meeting legal and normative requirements
• Demand for the Group's products and services and satisfaction of customer expectations
• The impact of service providers
• Technological factors
• Factors related to suppliers of goods and raw materials

Climate Change Adaptation Policy

The Company does not have a separate policy on climate change adaptation and physical and transition risk management. Based on past assessments made by the Company, climate-related risks are not expected to have a significant impact on the Group's activities.

Transition Plan

The Company does not have a formal transformation plan. As of the date of publication of this Statement, there is no decision on when to adopt such a plan. Notwithstanding the above, the Company is making efforts to reduce its greenhouse gas emissions intensity.

During the period of Dino Group's rapid growth, the gradual reduction of environmental impact, in terms of greenhouse gas emissions, is understood to mean: i) the reduction of greenhouse gas emissions associated with the Group's existing assets (mainly the existing stores, distribution centers and the Agro-Rydzyna meat processing plant, and ii) the reduction of the greenhouse gas intensity (the amount of CO₂ per unit of revenue) of Dino Group's Scope 1 and 2.

Actions and resources in relation to climate change policies

Dino Polska's climate impact mitigation efforts are based on two main decarbonization levers: energy efficiency and the use of renewable energy.

Main actions and activities

1. Increasing the use of renewable energy in the Group's operations by installing photovoltaic panels on stores and distribution centers

Scope: Own operations (stores and distribution centers)

Progress in 2024:

• The Company installed photovoltaic panels on the roofs of 338 stores in 2024
• Total capacity of own renewable energy installations increased from 82.9 MW to 98.9 MW
• By the end of 2024, own photovoltaic installations were operating on 2,476 stores and 3 distribution centers
• Generated 86.6 GWh of electricity in 2024, reducing Scope 2 greenhouse gas emissions by 54,200 tons of CO₂

Resources allocated: Not quantified; the Company states "these activities do not require significant additional operating and capital expenditures"

Expected outcomes: Reduction of Scope 2 greenhouse gas emissions; future reductions will depend on the rate of growth in capacity of installations and changes in emission factors

2. Reducing electricity consumption by optimizing and gradually replacing equipment and lighting

Scope: Own operations (store chain)

Description:

• Replacing equipment and lighting with increasingly energy-efficient and energy-recovery equipment
• Implementing advanced monitoring, energy management and equipment control systems in the store chain

Progress in 2024:

• Energy management and control system expanded to 2,375 stores (from 853 at end of 2023)

Resources allocated: Not quantified

Additional ongoing actions (not considered key by the Company)

3. Regular monitoring of electricity consumption, renewable energy production, and energy efficiency

Progress in 2024:

• Each of Dino's 283 newly opened stores in 2024
• Two new distribution centers
• The new Agro-Rydzyna meat processing plant
• All obtained energy performance certificates

4. Improving the efficiency of the transport network (upstream value chain)

Scope: Upstream value chain

Activities include:

• Shortening the distance between stores and distribution centers (aligned with growing density of store network and development of distribution center network)
• Using a fleet of trucks that meet increasingly stringent environmental standards, especially with lower exhaust emissions
• Optimizing the usage of delivery vehicles and loading space
• Collaborating with suppliers to reduce the number of trips made by trucks that do not carry a full load or are empty

5. Identifying changing regulatory requirements and adjusting operations

Focus areas:

• Emission standards for transportation and passenger vehicles
• Phase-out of cooling agents with high greenhouse effect potential

6. Testing and implementing new solutions to reduce carbon footprint

Progress in 2024:

• Tested solutions based on electricity storage of approximately 50 kWh combined with additional off-grid photovoltaic installations
• Such systems were installed in 3 stores

General resource considerations

Financial resources: The Company states that these activities do not require significant additional operating and capital expenditures. The Group's ability to continue implementation depends mainly on the availability at an affordable cost of appropriate technology (such as photovoltaic panels). In the short and medium term, the Company does not assume significant changes in this availability.

Non-financial resources: Implementation of the Policy is the responsibility of the head of the Environmental Protection Department. The Management Board provides necessary financial, technical and organizational resources.

Nature-based solutions: The Group's climate change mitigation efforts do not include solutions based on natural resources.

Link to policies and targets

These actions support the environmental policy aimed at gradually curtailing environmental impact through rational management of materials and utilities, reduction of utility consumption (especially electricity and water), and increasing the use of renewable energy. The Company pursues reduction of greenhouse gas intensity (CO₂ per unit of revenue) for Scope 1 and 2 emissions, though it does not set specific numerical targets.

Targets related to climate change mitigation and adaptation

The Company's long-term development strategy sets out the main directions of Dino Group's development, but does not define precise goals. Similarly, the Company's ambitions related to key areas of impact are being pursued - the Company's Management Board defines courses of action specifically addressing issues such as:

• Reducing the intensity of greenhouse gas emissions
• Increasing the use of electricity from renewable sources
• Increasing the efficiency of electricity use
• Keeping refrigeration equipment in good condition to reduce cooling agent failures and leaks

However, the Company does not set specific numerical targets.

Monitoring approach

The Company monitors the effectiveness of its policies and actions taken on a continuous basis, as part of the general procedures in place in the Environmental Protection Department and the Management Controlling Department, Transportation Department, and as part of the Management Board's oversight process of strategy implementation. The indicators used for this purpose include those presented in:

• ESRS E1 (E1-5) Energy Consumption and Mix
• ESRS E1 (E1-6) Greenhouse Gas Emissions

Energy consumption and mix

Energy consumption and energy mix (2024)

Scope and methodology:

• Purchased electricity (line 5) calculated based on invoices from power companies. Due to different billing cycles and delays, the Company estimated total volume for sites without complete data based on monthly distribution of electricity consumption.
• Self-generated non-fuel renewable energy (line 10) includes electricity generated by Dino Group's RES facilities: 63,410 MWh used directly by the Group and 23,200 MWh fed into the power grid and consumed at a later date.
• Total capacity of PV installations was 99 MW at end of 2024 (installed on 2,476 stores and 3 distribution centers).

Energy intensity

Note: All Dino Group revenues are derived from sectors classified as having significant climate impact (NACE Sections A-H and L), including retail and wholesale, transportation and warehousing, and manufacturing operations.

Data assurance: Measurement of energy consumption and energy mix metrics were not validated by an assurance provider.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1, 2 and 3 GHG emissions

The table below presents information on Scope 1, 2 and 3 GHG emissions by the Dino Group:

Total GHG emissions

The table below presents information on total GHG emissions by the Dino Group:

GHG emissions intensity

The table below presents information on the intensity of GHG emissions based on Dino Group revenues:

Methodology notes:

Scope 1: Emissions result from: (i) cooling agents, (ii) stationary gas combustion, (iii) fuel combustion in vehicles, and were calculated using emission factors published by the National Center for Balancing and Emission Management (KOBIZE), the Polish Agency for Enterprise Development and the Intergovernmental Panel on Climate Change (IPCC).

Scope 2: Emissions are predominantly related to purchased electricity. In the case of the location-based method, they were calculated using the latest available (for 2023) emission factor for electricity end-users published by KOBIZE, which was adjusted for transmission losses and balancing differences (the emissions associated with this item are included in Scope 3, Category 3). The emission factor converted in this manner was 560 tCO2/GWh. Scope 2 emissions in the market-based method were estimated based on the emission factor published by the Association of Issuing Bodies for the residual mix (source: aib-net.org; the residual mix excludes from the emission factor that portion of electricity from RES that is fed into the national energy system using guarantees of origin; the latest available factor for Poland for 2023 and was 788 tCO2/GWh).

Scope 3: Emissions mainly include emissions related to the manufacture of goods sold in Dino stores, capital goods, transportation and distribution of goods, downstream transportation, and processing of products sold. Scope 3 emissions were estimated using the following assumptions and indicators:

• Category 1: an estimate based on the value of purchased commercial goods and the value of purchased repair and other services and emission factors for various categories of products and services as shown in the Climatiq database (climatiq.io)
• Category 2: estimated based on the value of purchased equipment and capital expenditures and emission factors from the Climatiq database
• Category 3: mainly takes into account energy and fuel-related emissions not included in Scope 1 and 2: WTT emissions for fuels and energy (transmission losses are included) and emissions related to the production of fuels used for energy generation (estimated using an indicator from the Defra database: WTT- overseas electricity (generation) + WTT- overseas electricity (T&D))
• Category 4: mainly takes into account emissions related to transportation between the Company's warehouses and stores, estimated based on ton-miles traveled and emission factors from a study prepared by the Fraunhofer-Institute for Systems and Innovation Research ISI for the European Environment Agency, "Methodology for GHG Efficiency of Transport Modes."
• Category 5: estimated based on the weight of waste generated and emission factors for various waste categories from the Defra database
• Categories 6 and 7: estimation based on estimated distance and emission factors for different modes of transportation
• Category 9: takes into account emissions from customers' commute to Dino stores (estimated based on estimated distance and emission factors for passenger cars)
• Category 11: mainly takes into account emissions from the use of the charcoal, brickettes and kindling fuel sold as well as from the use of appliances that consume electricity, estimated based on the estimated weight of the products and appliances sold and the factors produced by KOBiZE
• Category 12: estimated based on the weight of products sold and assuming that 20% of this weight ultimately becomes waste

Scope: Scope 1 and 2 issues include only issues from Dino Group operations subject to consolidation for accounting purposes. The Group does not have associates, joint ventures or unconsolidated subsidiaries, nor does it exercise operational control over other operations or assets through contractual arrangements.

Revenue basis: Revenues used in the calculation of GHG intensity represent total sales revenues referred to in the consolidated financial statements in the income statement.

Assurance: The measurement of the metrics presented in the tables above were not validated by an assurance provider.

Biogenic emissions

Not separately disclosed.

Regulated emissions (EU ETS)

Not applicable. Percentage of Scope 1 GHG emissions from regulated emission trading schemes: 0%.

Internal carbon pricing

The Dino Group does not apply internal systems of carbon pricing.

GHG removals and carbon credits

The Dino Group does not implement GHG removals or GHG mitigation projects financed through carbon credits.

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

Phase-in exemption applied

In the first year of preparation of its sustainability statement, Dino Polska is not reporting all data points included in this disclosure requirement, based on the exemption specified in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Policies related to water and marine resources

Dino Polska does not have a separate policy dedicated to water and marine resource issues.

The Company's environmental policy (outlined in ESRS E1 (E1-2)) addresses water through the following elements:

• Rational management of materials and utilities and reduction of utility consumption, especially electricity and water
• Commitment of own workforce (in the Code of Conduct) and suppliers (in the Supplier Code) to the economical and efficient use of natural resources

Company's rationale for no dedicated water policy

The Company views the water impacts of its value chain as a difficult issue to avoid, stating that:

• Food production by definition involves the use of natural resources, including water
• Food production is not optional, and some processes (e.g., growing crops, raising animals) are inherently resource-intensive
• Reducing water consumption in this sector should be done in a sustainable manner so that it does not come at the expense of food availability and quality
• Without adequate irrigation, yields would be lower and production would be less efficient, leading to higher prices and potential shortages

The Dino Group applauds the initiatives of its own value chain players to optimize consumption, such as implementing water-saving technologies and recycling.

Water risk assessment

Due to the nature of Agro-Rydzyna's operations, the Company analyzed the locations of its meat processing plants for operations in areas exposed to water risks. The results showed that these plants are not located in areas of significant water scarcity (defined according to ESRS standards as regions where the percentage of total water withdrawn is high or extremely high in the Aqueduct Water Risk tool of the World Resources Institute (WRI)).

Regulatory context

The vast majority of value chain operations are located in Poland, where water withdrawal is regulated by the Act of 20 July 2017 - Water Law, which establishes the management of water in accordance with the principle of sustainability.

Actions and resources related to water

The Group's activities related to water and marine resources relate to:

Water efficiency and monitoring of water consumption

• Scope: Own operations
• Description: The Company is promoting a similar approach among supply chain players
• Materiality assessment: In the context of the ESRS, the Company does not regard these activities as crucial
• Resources allocated: Not disclosed
• Time horizon: Not specified
• Expected outcomes/KPIs: Not specified

Water risk assessment at meat processing plants

• Scope: Own operations (Agro-Rydzyna meat processing plants)
• Description: Analysis of locations of meat processing plants for operations in areas exposed to water risks using the Aqueduct Water Risk tool of the World Resources Institute (WRI)
• Outcome: Plants are not located in areas of significant water scarcity (defined as regions where the percentage of total water withdrawn is high or extremely high)
• Resources allocated: Not disclosed

Value chain activities

The vast majority of value chain operations are located in Poland, where water withdrawal is regulated by the Act of 20 July 2017 - Water Law. Due to the regulatory framework and the nature and area of supply chain operations, the Company has not established specific water-related activities in the value chain.

Linked policy: Environmental Protection Department and Management Controlling Department procedures, Management Board oversight process of strategy implementation.

Targets related to water

The Group's long-term development strategy sets out the main directions of Dino Group's development, but does not define precise goals. The Company's ambitions in the key impact areas are pursued in a similar manner: the Company's Management Board defines the directions for action, particularly in terms of issues such as water efficiency, but does not set any specific numerical targets.

The Company monitors the effectiveness of its policies and actions taken on a continuous basis, as part of the general procedures in place in the Environmental Protection Department and the Management Controlling Department, and as part of the Management Board's oversight process of strategy implementation.

Specific factors are not taken into account in the process of monitoring the supply chain's impact on water.

No quantified targets related to water and marine resources have been disclosed.

Water consumption

Total water withdrawal and consumption

Water withdrawal in Dino Group's own operations, per employee, was 1.2 m³ per month in 2024.

The corresponding ratio for water consumption was 0.2 m³ per employee per month in 2024.

Context and scope

Water withdrawal is mainly for utility purposes of employees and for food production at the Agro-Rydzyna meat processing plant.

The Company has two water sources at its meat processing plant:

• Main source: city's water supply system (intake is metered and monitored by the water utility)
• Secondary source: own water intake (regulated by water permit, metered, with periodic reporting to relevant authorities)

Water withdrawal and consumption by Agro-Rydzyna are mainly for food production purposes.

Water stress areas

The Company analyzed the locations of its meat processing plants for operations in areas exposed to water risks. The results showed that these plants are not located in areas of significant water scarcity (defined according to ESRS standards as regions where the percentage of total water withdrawn is high or extremely high in the Aqueduct Water Risk tool of the World Resources Institute).

Value chain context

Intensive use of water in agricultural activities and food production processes in the upstream value chain was identified as an actual negative environmental impact (short, medium and long term horizon).

Taking into account the dispersed nature of its operations, the Company considers its water withdrawal to be below the accepted standards for these operations and does not consider its environmental impact to be material in this context.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

In the first year of preparation of its sustainability statement, Dino Polska is not reporting all data points included in this disclosure requirement, based on the exemption specified in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Policies related to resource use and circular economy

Dino Group has identified reducing waste generation and preventing food waste as the main areas for managing negative impacts related to resource utilization and circular economy. Both issues impact environmental and social outcomes as well as financial performance through waste management costs and commodity losses.

Environmental Policy

The Dino Group's approach to resource use and circular economy is reflected in the Environmental Policy (described in detail in ESRS E1 (E1-2) Policies related to climate change mitigation and adaptation).

Key content and principles:

The policy is implemented through:

• Identification of applicable legal and other environmental requirements and consistent compliance with them
• Rational management of materials and utilities and reduction of utility consumption, especially water
• Proper waste management and minimization of the mass of waste generated
• The use of reusable packaging and the optimization of packaging
• Minimizing commodity and production losses
• Commitment by employees (in the Code of Conduct) to minimize waste production through proper recycling and composting, and to use natural resources sparingly and efficiently
• Commitment by suppliers (in the Supplier Code) to manage natural resources sparingly and take initiatives to reduce the weight of waste produced or better manage it through proper segregation and recycling

Waste management hierarchy:

The company's waste management policy prioritizes activities in the following order:

1. Prevention
2. Reuse
3. Recycling (including organic recycling)
4. Disposal (as last step)

Implementation mechanisms:

• Internal procedures define principles of segregation, selective waste collection and management, and assortment management to reduce losses due to expiration or loss of shelf-life characteristics
• Separate organizational units are responsible for implementing specified procedures and monitoring results
• Directors of each unit oversee effectiveness and report directly to Management Board Members
• Weekly meetings (for fresh goods) and quarterly meetings (for other goods) of a dedicated committee monitor and analyze commodity losses
• The committee's work is supervised by the Management Board Member responsible for sales

Collaboration:

The Group seeks opportunities to work with suppliers to reduce the amount of packaging materials used and to manage these materials effectively.

Actions and resources related to resource use and circular economy

The Dino Group has disclosed actions related to circular economy across two main areas: food waste prevention and waste management/recycling.

Food Waste Prevention Actions

The Group pays attention to ensuring products (particularly fresh ones) delivered to Dino stores are of the highest quality for longer storage after purchase. Key actions employed include:

• Daily product review procedures – Internal procedures define rules for daily review of product assortment in stores and order of products put out for sale based on FIFO principle (products produced first or with shorter expiration date sold first)

  • Scope: Own operations (stores)

• Efficient logistics network for fresh products – Daily delivery of fresh products to Dino stores, reducing need to store them in stores

  • Scope: Own operations (distribution/stores)

• Dedicated commodity loss analysis teams – Teams analyze commodity losses and take initiatives to reduce them

  • Scope: Own operations
  • Resources: Dedicated employee teams; oversight by Management Board Member responsible for sales
  • Monitoring: Weekly meetings for fresh goods, quarterly meetings for other goods via dedicated committee

Additional ongoing actions (not designated as key):

• At least three times daily fruit and vegetable stand servicing in every store
• Store order system designed to facilitate requisitioning based on historical sales levels
• In-store incentive bonus system with product spoilage level as criterion
• Regular discounting of products with short best-by or shelf-life dates
• Vertical integration with meat processing plant for efficient production and logistics management
• "Buy, Eat, Don't Waste" consumer campaign in 2024 using in-store communication channels

Waste Management and Recycling Actions

Key activities for proper waste management, recycling and minimizing waste mass:

• Reusable return packaging for fruit and vegetables – Using reusable packaging together with suppliers (process starts at supplier packing stage) to limit disposable bulk packaging waste

  • Scope: Upstream value chain (suppliers) and own operations

• Partnership with IFCO SYSTEMS – Using reusable plastic containers (PPWU) for food transport in Dino network; containers use less natural resources over lifetime than disposable packaging, meet highest food safety standards, limit product damage

  • Scope: Own operations (supply chain)
  • Resources: Partnership with IFCO SYSTEMS

• Waste segregation and selective collection – Observing and promoting waste segregation procedures across all operational areas (head office, stores, warehouses, meat processing plant)

  • Scope: Own operations (all areas)

Additional ongoing actions (not designated as key):

• Raising employee awareness of waste segregation
• Recycling all return packaging made of plastic foil, waste paper and glass
• Baling waste at store level to compress volume for transport; pressing waste in warehouses for recycling preparation
• Promoting minimization of printed matter and automatic double-sided printing; encouraging reuse of materials (plastic sleeves, folders)
• Installing tap water filters in head office social rooms
• Promotional newsletter printed on FSC and Ecolabel certified paper
• Battery disposal facilities in each store and head office

Resources Allocated

No quantified financial resources (capex/opex amounts) are disclosed for these actions. Non-financial resources mentioned include:

• Dedicated employee teams for commodity loss analysis
• Dedicated committee with weekly/quarterly monitoring (supervised by Management Board Member)
• Partnership with IFCO SYSTEMS

Targets related to circular economy

Dino Polska does not set specific quantified targets related to resource use and circular economy.

According to the disclosure:

The Company's long-term development strategy sets out the main directions of Dino Group's development, but does not define precise goals. The Company's ambitions in the key impact areas are pursued in a similar manner: the Company's Management Board defines the directions for action, particularly in terms of issues such as reducing the amount of waste generated, proper segregation of waste, or minimizing commodity losses, but does not set specific numerical targets.

Monitoring approach

The Company monitors the effectiveness of its policies and actions taken on a continuous basis, as part of the general procedures in place in the Environmental Protection Department and the Management Controlling Department, and as part of the Management Board's oversight process of strategy implementation.

The indicators used for monitoring include those presented in ESRS E5 (E5-5) Resource outflow – Waste.

2024 waste performance (for context)

• Total waste generated: 118,828 tons
• Waste for which disposal was avoided: 65,260 tons
• Non-recycled waste: 53,569 tons (45.1% of total)

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

In the first year of preparation of its Sustainability Statement, Dino Polska is not reporting all data points included in this disclosure requirement, based on the exemption specified in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Financial risk from circular economy - waste

As described in the material impacts and risks section, Dino Polska identifies significant financial risks concentrated in the Group's own operations that may materialize in the medium and long term. This risk is associated with potential regulations that, in connection with the European Union's climate obligations, may obligate various businesses to implement specific capital-intensive solutions or solutions requiring the incurrence of major operating expenditures.

As at the publication date of this Statement, an example of such regulations is Directive 2019/904 of the European Parliament and of the Council of the European Union on the reduction of the impact of certain plastic products on the environment, which forms grounds for introducing the "deposit system" in Poland. The deposit system obliges stores with an area of more than 200 square meters to organize the collection of plastic packaging, glass bottles and metal cans. Accordingly, each Dino store will have to be equipped with an appropriate device serving this purpose.

The Group believes that its strategy and business model are highly resilient to the material impacts and risks arising from waste-related issues, but it recognizes that the mitigating measures may result in significant additional capital expenditures, depending on the rate of implementation. Current and expected impacts on the business model and value chain include, in particular, the need for consistent implementation of the principles of a circular economy, which may generate additional operating expenses and capital expenditures in the short to medium term, but will ensure regulatory compliance in the long term and should result in reduced costs of waste disposal.

Waste

Dino Polska omits reporting data points on product- and material-related resource outflow included in this disclosure requirement due to their insignificant nature.

Waste Generated and Management

The waste generated by the Dino Group mainly consists of communal waste, waste paper, plastics, food waste and side products of animal origin (in the Agro-Rydzyna meat processing plant). The waste is collected by dedicated and specialized companies based holding the appropriate collection documents.

The total amount of waste generated by the Dino Group in 2024 was 118,828 tons.

The total amount of waste generated by the Dino Group in 2024, for which disposal was avoided, was 65,260 tons, of which:

• 931 tons were prepared for reuse,
• 61,685 tons were recycled,
• 2,644 tons were sent to other recovery processes.

The total amount of waste generated by the Dino Group in 2024 that was sent for disposal was 53,568 tons, of which:

• 35 tons were sent for incineration,
• 22,641 tons were sent to storage,
• 30,893 tons were transferred to other disposal processes.

The total amount of non-recycled waste was 53,569 tons, accounting for 45.1% of all waste generated. The amount of hazardous waste generated by the Dino Group was 352 kg.

Methodology Note

The measurement of the metrics presented in the tables above were not validated by an assurance provider. The above metrics were calculated by adding up the weight of waste, the source of which is the record-keeping systems, particularly the so-called waste transfer cards prepared at each business location and invoices received for municipal waste disposal (segregated and mixed). In the case of municipal waste, the weight was estimated, based on the number of municipal containers submitted for collection during 2024 and the assumed weight of waste per container (respectively: 0.136 kg per liter of container capacity for mixed waste; 0.130 kg/l for biowaste; 0.080 kg/l for waste paper; 0.150 kg/l for glass; 0.025 kg/l for plastics).

Waste Management Approach

The company's waste management policy is to prioritize activities accordingly. In the first step, efforts are made to prevent waste, in the next step, a reusable solution is implemented, followed by recycling (including organic recycling), and in the last step, disposal is considered. Dino Group's internal documentation has dedicated procedures in place to define the principles of segregation, selective waste collection and management, and assortment management in order to reduce losses due to expiration or loss of shelf-life characteristics of the product.

Key activities include:

• Using reusable return packaging for fruit and vegetables
• Observing and promoting waste segregation procedures and selective waste collection in all areas of operation (head office, stores, warehouses, meat processing plant)
• Recycling all the return packaging made of plastic foil, waste paper and glass
• Baling waste at the store level to compress its volume for transport and pressing waste in warehouses and preparing it to be recycled
• Installing tap water filters in social rooms to reduce bottled water use
• Using FSC and Ecolabel certified paper for promotional materials
• Collecting spent batteries in stores and head office for specialized disposal via the BDO system
• Implementing more ecological packaging in private label products using thinner film or recycled materials
• Donating food that meets food law requirements for social purposes

Policies related to own workforce

Dino Polska has disclosed several policies and internal documents that collectively constitute its policy framework for managing impacts on its own workforce. These documents apply to all workforce, although they may contain specific provisions for particular areas of activity. The interest of the workforce in establishing these documents was ensured primarily by compliance with applicable laws. Implementation of the policies is the responsibility of the directors of relevant departments in the Company.

Code of Conduct

Policy name: Code of Ethics of Dino Polska S.A. and subsidiaries (Code of Conduct)

• Scope: All employees, associates and managers of Dino Polska and its Subsidiaries
• Key content:
  • Excludes the possibility of violating the human rights set forth in the Universal Declaration of Human Rights
  • Does not tolerate any form of discrimination based on gender, religion, mental and sexual orientation, disability, political views, nationality, education, professional experience, social background, assets, birth, age, marital status or other differences
  • Prohibits stalking, mobbing and sexual harassment
  • Only within applicable laws and in specified situations permits employment of juveniles who have reached the age of 15
  • Does not accept work or employment of children under the age of 15 anywhere in the supply chain
  • Does not tolerate forced labor or any forms of slavery
  • Provides equal access to career advancement for women and men
  • Requires people managing teams to respect human dignity and respond to manifestations of infringing upon it
  • Guarantees confidentiality to whistleblowers and excludes retaliation
• Public availability: Available via the intranet and posted in places accessible to employees (e.g., in social rooms in stores, distribution centers), or handed over when concluding employment contracts; also publicly available at grupadino.pl/lad-korporacyjny/
• Link to international standards: Inspired by the Universal Declaration of Human Rights and the Ten Principles of the United Nations Global Compact; in accordance with the UN Guiding Principles on Business and Human Rights
• Monitoring: Violations should be reported through specified channels; the Company has a human rights due diligence process in place to identify, prevent and mitigate possible negative human rights impacts

Work Rules and Regulations

Policy name: Work Rules and Regulations

• Scope: All employees
• Key content:
  • Ensures respect for employee rights
  • Defines basic obligations of employees and the employer
  • Regulates working time, absences and vacations
  • Covers organizational responsibility, rewards and distinctions
  • Defines timing and method of payment of salaries
  • Protects the work of women, people with disabilities and minors
• Public availability: Made available to employees via the intranet and posted in places accessible to employees

Personal Data Protection Policy

Policy name: Personal Data Protection Policy

• Scope: All areas of the Dino Polska Group's activity and all employees who process personal data within their scope of duties
• Key content:
  • Defines methods used to secure and handle personal data
  • Identifies individuals responsible for personal data processing and protection
  • Establishes principles of personal data processing
  • Provides for audits to check compliance with regulations and procedures
  • Includes procedures and rules to enable persons to exercise their rights (data access, revision and deletion)
• Public availability: Available to all employees
• Oversight: Subject to review by the Personal Data Inspector for adequacy, carried out no less frequently than once a year
• Monitoring: Dino Polska regularly monitors the purposes of processing, the legal grounds and the scope of personal data

Anti-mobbing Policy

Policy name: Anti-mobbing Policy

• Scope: All employees
• Key content:
  • Set of rules to counteract mobbing in the Company
  • Procedures for dealing with cases of mobbing occurrence
  • Key objective is to support activities that foster positive relations among employees
• Oversight: Position of a Management Board Representative on preventing mobbing reporting directly to the Company's Management Board has been established
• Monitoring: Anti-mobbing survey is conducted among Dino employees to provide support for the internal anti-mobbing procedure in preventing the occurrence of mobbing incidents
• Public availability: Made available to employees via the intranet and posted in places accessible to employees

Internal Whistleblowing and Whistleblower Protection Procedure

Policy name: Internal Procedure for Whistleblowing and Protecting Whistleblowers (also referred to as Internal Whistleblowing and Whistleblower Protection Procedure of Dino Polska S.A.)

• Scope: All employees and stakeholders
• Key content:
  • Establishes a framework for the protection of whistleblowers
  • Ensures compliance with statutory and organizational requirements for procedures to protect the identity of notifiers
  • Regulates the follow-up of received reports
  • Sets detailed rules for reporting and processing of whistleblower reports
  • Lays down rules for providing feedback
• Link to international standards: Adopted in accordance with the Whistleblower Protection Act, which implements into Polish law Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law
• Public availability: Made available to employees via the intranet and posted in places accessible to employees

Compensation Rules and Regulations

Policy name: Compensation Rules and Regulations

• Scope: All employees (applies to secure employment and adequate wages)
• Key content:
  • Clarifies the company's remuneration rules
  • Indicates work-related cash benefits
• Oversight: Company holds monthly meetings of the Compensation Committee attended by Management Board members where decisions are made regarding changes in compensation for each position
• Public availability: Made available to employees via the intranet and posted in places accessible to employees

Internal health and safety procedures

Policy name: Internal health and safety procedures

• Scope: All employees; separate procedures for stores, offices and distribution centers
• Key content:
  • Regulates occupational safety and health (OSH) issues
  • Preventing accidents and providing conditions ensuring occupational safety and health is the employer's top priority
• Oversight: Dino Polska has a dedicated department responsible for OSH
• Monitoring: 100% of Dino Group employees are covered by the health and safety management system
• Link to international standards: Agro-Rydzyna, Dino's meat processing plant subsidiary, implemented an ISO 14001 environmental management system in 2022, certified accordingly (though this relates to environmental management)
• Public availability: Made available to employees via the intranet and posted in places accessible to employees

Environmental Policy (workforce-related aspects)

The Company has an environmental policy (outlined in ESRS E1 (E1-2)) that includes workforce commitments:

• Key content (relevant to workforce):
  • Commitment of own workforce (in the Code of Conduct) to economical and efficient use of natural resources
  • Commitment to minimize waste production through proper recycling and composting
• Approval and oversight: Adopted by Dino Polska in the form of an official document in 2025 (pursued in 2024 and previous years); implementation is the responsibility of the head of the Environmental Protection Department; Management Board of Dino Polska and Subsidiaries provide necessary resources

Recruitment and staff policy

Dino Polska's recruitment and staff policy is based on four pillars (store format and location, employment flexibility and employee satisfaction, professional development and promotions, competitive salary), though this is described as a policy framework rather than a single named document.

Human rights due diligence

• Link to international standards: In accordance with the UN Guiding Principles on Business and Human Rights, the Group is committed to respecting human rights and has a human rights due diligence process in place to identify, prevent and mitigate possible negative human rights impacts
• Scope: Entire operations conducted in Poland; Poland is a signatory to international agreements including the European Convention on Human Rights and the Universal Declaration of Human Rights; compliance ensured through Labor Code
• Link to ILO conventions: The Code of Conduct excludes employment of children under 15, prohibits forced labor, and ensures equal access to career advancement for women and men, aligning with fundamental ILO principles

Additional policy elements

The Company notes that it does not identify the need for dedicated policies specifically aimed at eliminating discrimination (including harassment), promoting equal opportunities and other ways to enhance diversity and inclusion, as these are addressed in the current Code of Conduct which states that no discrimination is tolerated in the Dino Group.

The Company also states it has no formal diversity policy, as decisions on promotion and employment are based solely on competences, experience and familiarity with the Company, notwithstanding age, gender, education and other attributes.

Taking action on material impacts on own workforce

Overview of material impacts and approach

The Dino Group's material impacts on its own workforce focus on:

• Safety of employees
• General working conditions

Due to rapid growth, the Group significantly and consistently increases headcount (by 8,000 people in 2024, up 19.1% year-on-year), creating opportunities for professional development and promotion. The hiring of workforce under employment contracts guarantees employees the same rights and security as defined by the Group's policy, at a level not lower than required by law.

Responsible departments: HR Department, Personnel and Payroll Department, Recruitment Department, Health and Safety Department, and Sales Organization Training Department.

Actions and initiatives

1. Employment policy and labor law compliance monitoring

• Scope: Own operations
• Description: Continuous monitoring of compliance with employment policy, applicable labor laws and ethical standards
• Mechanism: Regular internal audits and inspections of working conditions to identify irregularities and take corrective action
• Tools: HR and reporting systems to monitor indicators such as headcount and employee turnover
• Time horizon: Continuous/ongoing

2. "First Job" program

• Scope: Own operations
• Description: 6-month program for employees interested in professional growth, providing support to people at the outset of their career to gain practical skills and check professional plans
• Outcomes: After completing the program, the Group plans and aligns the trainee's subsequent career path within Dino Group
• Opportunity: Employees can change departments to obtain professional experience relevant to their education and interests
• Time horizon: Ongoing

3. Occupational safety and health training

• Scope: Own operations
• Description: Regular training courses to minimize negative impact on workforce and associated risks
• Coverage: Training in occupational safety and health, prevention of discrimination and mobbing
• Time horizon: Continuous/ongoing

4. Anti-mobbing procedure and surveys

• Scope: Own operations
• Description: Application of anti-mobbing procedure supported by anti-mobbing surveys conducted among employees every year
• Linkage: Based on Code of Conduct (highest-ranking document governing discrimination issues)
• Time horizon: Annual surveys, ongoing procedure

5. Onboarding surveys and interviews

• Scope: Own operations (head office)
• Description: Surveys and interviews with new employees to collect feedback on initial experience in the organization
• Process: Outcomes reviewed and conclusions used to improve onboarding processes and uplift work standards
• Target group: New hires, especially at head office
• Time horizon: Ongoing

6. Stable employment conditions

• Scope: Own operations
• Description: Policy requiring full-time employment contracts as primary form of employment, providing stable and predictable employment conditions
• Impact: Guarantees employees same rights and security at level not lower than required by law
• Time horizon: Ongoing policy

7. Local employment creation

• Scope: Own operations
• Description: Opening stores in smaller towns creates employment opportunities near employees' place of residence (every store gives jobs to roughly a dozen people)
• Impact: Positive contribution to local labor markets, often in places with limited stable employment opportunities based on employment contracts
• Linkage: Supports Company's mission statement "Dino – Closest to You"
• Time horizon: Ongoing as part of growth strategy

Resource allocation

Non-financial resources:

• Multiple dedicated departments: HR Department, Personnel and Payroll Department, Recruitment Department, Health and Safety Department, Sales Organization Training Department
• HR and reporting systems for monitoring
• Internal audit function

Financial resources: Not disclosed/quantified

Future plans

The Group intends to continue rapid growth both in terms of network and headcount.

Targets related to own workforce

The Group's long-term growth strategy sets out the main directions of the Dino Group's growth, but does not define any specific goals. The Company's ambitions in the key impact areas are pursued in a similar manner: the Company's Management Board defines the directions for action, particularly in terms of issues such as:

• Reducing employee turnover
• Minimizing the number of incidents related to occupational safety and health
• Creating a friendly workplace

However, the Company does not set any specific numerical targets.

Monitoring approach

The Dino Group monitors the effectiveness of its policies and activities in the areas of employment, occupational safety and diversity. This effectiveness is evaluated through:

• Internal audits
• Reviews of indicators published in the Group's disclosures
• Dialogue with employees

The indicators are compared frequently with the aim of improving them steadily.

Context data (2024)

• Unadjusted employee turnover rate: 21.7%
• Adjusted employee turnover rate: 13.1% (excludes people who left within 3 months of starting work)

Characteristics of the undertaking's employees

Total headcount

At yearend 2024, the Dino Group had 49,887 employees. At yearend 2023, the Dino Group had 41,883 employees (calculated based on the stated increase of 8,000 employees). In 2024, the workforce increased by 8,000 people (19.1% year-on-year).

All Dino Group staff are employed in Poland.

Headcount by contract type and gender

The table below presents a breakdown of Dino Group employees by contract type and gender at the end of 2024:

Employee turnover

The following table presents the number of employees who left their jobs in 2024:

In 2024, the unadjusted employee turnover rate was 21.7%. The adjusted employee turnover rate in 2024 was 13.1% (this rate excludes from the numerator people who left their job within 3 months of starting work). The unadjusted rate is calculated as the ratio of the total number of people who left their job (this number includes people who left voluntarily or as a result of dismissal, retirement or death at work – there were no such cases – and does not include any cases of termination of employment due to the expiry of the term for the employment contract) and the total number of employees at the end of the reporting period.

Age structure

The following table presents the age structure of the Dino Group's employees at yearend 2024:

Methodology notes

Employee data are obtained from internal HR and payroll systems. The data are subject to ongoing verification by the HR Department. At the end of the reporting period, the data are used to calculate the indicators. The headcount includes all staff employed in the respective period, regardless of their FTE status.

The headcount data are consistent with the corresponding information presented in note 35 to the Consolidated Financial Statements of Dino Polska for 2024.

The employee data presented in this note have been obtained from the Dino Group's internal HR and payroll systems (but have not been verified by an external assurance provider).

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

In the first year of preparation of its sustainability statement, Dino Polska is not reporting all data points included in this disclosure requirement, based on the exemption specified in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Contextual information

The Company notes that its value chain includes upstream entities such as independent transport companies that manage distribution between the Group's distribution centers and stores. However, no quantitative metrics regarding the number, type, or characteristics of non-employee workers are disclosed for 2024.

Collective bargaining coverage and social dialogue

Collective bargaining agreements

There are no collective labor agreements in the Dino Group, nor are there any other agreements with employees regarding representation by the European Works Council.

Trade union membership

At yearend 2024, there were 4 trade unions operating in Dino Polska, which combined accounted for:

• Less than 1% of all Company employees
• Less than 1% of all Dino Group employees

Diversity metrics

No formal diversity policy is in operation in the Company. Decisions on the promotion of employees and extension of their employment contracts are based solely on their competences, experience and familiarity with the Company, notwithstanding their age, gender, education and other attributes. The Company does not accept any forms of employee discrimination. By having a diverse team in terms of age, education, competences, gender and experience, among other aspects, Dino Polska secures diversity, creativity and dynamism while the combination of these factors makes it possible to execute its growth strategy effectively.

Gender structure of senior management (yearend 2024)

Age structure of the Dino Group's employees (yearend 2024)

Methodology: The Dino Group applies a consistent methodology to calculate the gender breakdown of its workforce, in particular with regard to senior management. The group of top management includes persons holding the highest managerial positions within the organization, including Management Board Members, Directors of key departments and individuals making strategic decisions. Employee data have been obtained from the Dino Group's internal HR and payroll systems (but have not been verified by an external assurance provider).

Adequate wages

Policy statement

All Dino Group employees receive their compensation at a level commensurate with their professional experience, the work they perform and their level of responsibility. The amount of employee compensation and the method and date of payment are always in compliance with the applicable laws.

The compensation level of all Dino Polska employees is reviewed by the Management Board at least annually and is generally adjusted (upward) at the beginning of each year in accordance with changing conditions in Poland's economy and labor market. The Company holds monthly meetings of the Compensation Committee attended by Management Board members where decisions are made regarding changes in compensation for each position.

Benchmark used

Dino Group employees receive at least adequate wages, as construed by ESRS as a wage that provides for the satisfaction of the needs of the worker and their family in the light of national economic and social conditions.

No specific external or internal living wage benchmark methodology is disclosed (e.g., Fair Wage Network, WageIndicator, Anker Methodology, MIT Living Wage Calculator, Global Living Wage Coalition).

Remuneration system

The remuneration system offers:

• Fixed salary paid at monthly intervals, set at a decent level enabling employees to have at least a safe living standard while ensuring that the Company is competitive on the labor market
• Variable compensation in the form of bonuses:
  • Store employees earn financial bonuses derived from fulfillment of sales targets achieved by a specific store and the level of product spoilage
  • Bonuses and awards are paid according to completed tasks and may vary among employees

Equal pay principles

The Company takes care that all employees have equal access to professional development opportunities and receive equal pay for equal work. There is a standard base salary scale that is identical for women and men in the Company's various business areas.

All Dino Group employees are offered the same non-financial benefits regardless of the type of employment contract or working time.

Coverage

The disclosure states that "all Dino Group employees" receive at least adequate wages but does not provide:

• Specific percentage of workforce assessed against a living wage benchmark
• Percentage found to earn at or above a living wage threshold
• Geographic scope or exclusions (though operations are solely in Poland)

External factors affecting wages

The company references minimum wage increases as an external factor affecting business:

• "Macroeconomic situation in Poland, also accompanied by the minimum wage hike and the operation of social programs augmenting consumers' disposable income"
• "Low unemployment, which coupled with higher salaries in Poland will translate into the Group's operating expenses continuing to rise"

No targets or value chain commitments disclosed

No forward-looking targets or commitments to extend adequate/living wage assessment to the value chain are disclosed.

Social protection

All Dino Group employees are covered by social protection in accordance with the laws adopted by Poland. Such protection covers such life events as illness, unemployment, accidents at work, acquired disabilities, parental leave and retirement.

Coverage

• Percentage covered: 100% of employees
• Type of scheme: Public scheme (Polish national legislation)
• Geography: Poland
• Life events covered:
  • Illness (sickness)
  • Unemployment
  • Accidents at work (employment injury)
  • Acquired disabilities (disability)
  • Parental leave
  • Retirement

Persons with disabilities

The Group creates conditions for employing people with disabilities. At the end of 2024, employees with a disability certificate issued in accordance with national regulations accounted for 6.75% of all staff (this indicator has not been verified by an external assurance provider).

Methodology / Definition

In the context of the applicable Polish laws, a person may be considered disabled if they have an impaired body function and, due to their limitations:

• are unable to perform remunerated work or need to have their workplace adapted to their medical condition,
• require care or assistance from others,
• have problems with daily activities and need devices that assist them in functioning properly.

The Dino Group, in accordance with the applicable laws, collects disability data in its employees only to the extent necessary to fulfill an employer's obligations arising from national legislation and in full compliance with data protection regulations. Disability-related data are collected on a voluntary basis only. The processing of such data is carried out in a manner consistent with the principles of equal treatment and non-discrimination. Accordingly, the employer may not require the disclosure of such information unless it is necessary for the exercise of employee rights.

Training and skills development metrics

In the first year of preparation of its sustainability statement, Dino Polska, due to limited data availability, is not reporting some of the data points included in this disclosure requirement, based on the exemption specified in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Health and safety training (disclosed under S1-14)

OSH training hours (2024):

• Dino Polska total: 53,703 hours
• Entire Dino Group total: 61,601 hours

Forklift operator training (2024):

• Total hours: 10,190 hours

Note: The company has not disclosed average training hours per employee, breakdowns by gender or employee category, performance review coverage, or total training investment for S1-13. The only training-related quantitative data disclosed relates to occupational safety and health training hours reported under S1-14.

Health and safety metrics

Coverage of health and safety management system

100% of Dino Group employees are covered by the health and safety management system.

Work-related accidents and injury rate

The accidents recorded in 2024 were mainly light accidents, especially cuts.

Methodology

In computing the rate of work-related injuries, the Company divides the respective number of cases (accidents in accordance with the data stated in ZUS IWA forms) by the total number of nominal hours (in accordance with the payroll lists) worked by employees who are own employees and multiplied by 1,000,000.

The data are derived from internal safety and health records (not verified by an external assurance provider).

Omitted disclosures

In the first year of preparation of its Sustainability Statement, Dino Polska omits the information on:

• Cases of work-related ill health
• Number of days lost to injuries

This is based on the exemption included in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Work-life balance metrics

Entitlement to family-related leave

All employees of the Dino Group are entitled to a leave of absence for family reasons in accordance with the applicable Polish laws.

Data disclosure limitation

In the first year of preparation of its sustainability statement, Dino Polska is not reporting all data points included in this disclosure requirement, based on the exemption specified in Appendix C to ESRS 1 – List of phased-in Disclosure Requirements.

Available metrics

No quantitative metrics are disclosed for:

• % of employees entitled to family-related leave by type (maternity/paternity/parental/family care)
• % of entitled employees who took family-related leave (split by gender)
• Return-to-work rate after parental leave (split by gender)

Qualitative information

The Company provides support to parents returning from maternity leave and flexible solutions for people with disabilities as part of aligning working conditions with the needs of individual employees.

Compensation metrics

Pay gap

Dino Polska takes care that all employees have equal access to professional development opportunities and receive equal pay for equal work. There is a standard base salary scale that is identical for women and men to eliminate the pay gap problem in the Company's various business areas. Bonuses and awards are paid according to the completed tasks and therefore may vary between employees.

In 2024, the unadjusted gender pay gap (construed as the difference between the average gross hourly wage of all male employees and the average gross hourly wage of all female employees divided by the average gross hourly wage of all male employees) was 22.6%.

The adjusted gender pay gap was 0.4%. This metric is calculated as the average, weighted by the number of employees, of pay gaps in the following 4 areas: (i) stores, (ii) warehouses, (iii) meat processing plant, (iv) head office, which differ substantially in terms of the nature and scope of work performed, the level of employee responsibility and the required qualifications.

In the group of store employees, which accounts for 80.3% of all staff, the wage gap is -2.03%.

Remuneration ratio

In 2024, the annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual) was 45.2.

Methodology

The Company notes that the unadjusted metric is unsuitable for a proper assessment of possible disparities between the salaries of women and men in the Dino Group. The average compensation of female and male employees in the Group are strongly affected by the employment structure – the largest group of employees carries out their duties in the retail sales area. These jobs are mostly filled by women, which is a factor of decisive impact on the average employee compensation of all women. The small percentage of men working in stores has the opposite effect on the average employee compensation of all men, which is to a greater degree affected by specialized positions in the head office that require higher qualifications.

The use of the adjusted pay gap takes into account the different qualifications and professional experience of staff associated with different roles in the Company, different levels of responsibility and different impacts on the organization's operations. The adjusted pay gap better reflects the complexity of the organizational structure and the differences in employee compensation resulting from these factors.

The above metrics were not validated by an external assurance provider.

Incidents, complaints and severe human rights impacts

In 2024, there were no incidents of discrimination, harassment or human rights violations (in particular in terms of forced labor, human trafficking and/or child labor) in the Dino Group. No fines, penalties or damages have been imposed on the Dino Group as a result of complaints and/or incidents related to discrimination, harassment or human rights violations.

Incidents of discrimination and harassment

Number of incidents: 0

Human rights violations

Number of severe human rights impacts (forced labor, human trafficking, child labor): 0

Complaints and grievances

Number of complaints: Not disclosed

Status of complaints: Not applicable (no incidents reported)

Fines, penalties and compensation

Total amount of fines, penalties or damages: 0

Policies related to consumers and end-users

The Dino Group's policy pertaining to consumers and end-users is aligned with human rights in areas such as health protection, the right to choose and the right to information. In 2024, neither within its own operations nor in the value chain did the Group identify any cases of human rights violation affecting consumers.

The main areas of the Dino Group's impact on consumers are related to: (i) ensuring the quality and safety of goods and products offered in Dino stores, (ii) Dino store network roll-out, including in less urbanized areas (small towns and rural areas).

Food quality and safety policy

Objective and scope: The objective of the food quality and safety policy in the Dino Group is to provide all customers of the network with safe and high-quality food that meets their expectations. The policy covers all process areas – from purchasing (audits at suppliers) to storage in distribution centers, to distribution across the store network.

Key systems and content: This goal is pursued through the development, deployment, maintenance and continuous improvement of the following systems:

• GHP/GMP (good hygiene practices/good manufacturing practices)
• HACCP (Hazard Analysis and Critical Control Points)

Governance: Responsibility for the pursuit of the quality and food safety policy rests with the Product Quality Development Manager, who reports directly to the Company's Management Board.

Communication: The policy and related procedures are conveyed to employees who exert an impact on their application (staff working in stores, distribution centers and the Product Quality Development Department).

Remediation mechanisms: Consumers have the right to react to any cases of departure from expected food quality and safety standards by submitting their concerns to the Customer Service Office. Dino Polska has appropriate procedures in place for the withdrawal from sale of products that do not meet the applicable standards of food law as well as procedures for handling consumer concerns and complaints.

Quality and safety policy at Agro-Rydzyna meat processing plant

Scope: The operations of the Agro-Rydzyna meat processing plant owned by the Dino Group include the separation of semicarcasses (the "production" of fresh meat), the production of cold cuts and the distribution of merchandise that is sold in its entirety in the Dino store network.

Key content: Product safety is ensured by compliance with current legal regulations and the HACCP food safety management system in force at Agro-Rydzyna. Staff of the meat processing plant participate in training sessions and are aware of the importance of adhering to the rules applicable to the health safety of consumers.

Governance: Responsibility for the pursuit of the quality and food safety policy at Agro-Rydzyna rests with the Quality and Investment Director, who oversees the work of the Quality Department and reports directly to the Agro-Rydzyna Management Board.

Dino store network roll-out policy

Objective: Dino stores are located close to customers' place of residence to ensure that customers are able to shop for their first-need articles quickly and conveniently.

Key content: The Company's policy in terms of the Dino store network roll-out calls for opening new stores in areas with a high population density and in sparsely urbanized areas with a low population density and a limited range of other stores. This strategy creates opportunities for rapid growth and exerts a material positive impact on people and the environment by shortening the distance between consumers and a modern, organized grocery retail network enabling them to save time and save on the costs associated with traveling to more distant stores.

Governance: The Directors of the Expansion and Investment Departments are responsible for overseeing the pursuit of the Company's policy in this respect. They are in charge of the selection of locations for new stores and the process.

Stakeholder engagement: Dino Polska cooperates with local administration units in order to obtain pertinent approvals and permits for the construction process and subsequent operation of the store.

Alignment with international standards

The statement notes that in accordance with the UN Guiding Principles on Business and Human Rights, the Group is committed to respecting human rights and has a human rights due diligence process in place to identify, prevent and mitigate possible negative human rights impacts.

The disclosure confirms that ESRS S4-1 addresses "Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines" but does not provide detailed information on how the policies specifically align with these frameworks beyond the general commitment stated above.

Taking action on material impacts on consumers

Product Quality and Safety Management

Scope: Own operations and upstream value chain (suppliers)

Key organizational units and responsibilities:

• Product Quality Development Department – responsible for ensuring safety standards and quality of products; enforces preparation and observance of internal quality management system procedures and provisions of food law; oversees the Hazard Analysis and Critical Control Point (HACCP) System

• Inspection Department – includes specialized Fruit and Vegetables Quality Control Team responsible for reducing the risk of accepting merchandise that fails to meet required parameters

• Warehouse Acceptance Quality Control units – conduct inspections of merchandise upon acceptance in distribution centers

• Fruit and Vegetables Quality Control units – conduct quality inspections

Detailed quality management procedures:

• GHP/GMP Books (good health practices / good manufacturing practices) – dedicated to Dino stores and distribution centers; describe in detail rules for receipt, storage, transport and sale of foodstuffs

• Fruit and vegetables catalogue – detailed catalogue of features and quality requirements for every product from the fruit and vegetables offering; used for ordering products, accepting them from suppliers, training staff and ensuring quality on stands in stores

Quality testing process includes:

• New supplier inspection and selection and regular inspections of current suppliers
• Inspection of merchandise by quality control team upon acceptance in distribution center
• Inspection of merchandise in requisition completion process
• Inspection by store employees after merchandise is accepted in store
• Regular quality checks in store

Medical certification:

• Every Dino Group employee who comes into contact with food must possess a valid medical certificate for sanitary and health compliance

Employee Training Programme

Scope: Own operations

Action:

• Training sessions for employees who have contact with food at every stage (warehousing, transporting, storage, sales)
• Training provides required knowledge pertaining to rules for checking products
• 2024 specific action: Additional training on HACCP documentation conducted for team of Trainers directly involved in teaching store employees
• Time horizon: Training to be held regularly (ongoing)

Expected outcomes:

• Employees properly respond to any detected irregularities in terms of product safety and quality

Internal Audit Programme

Scope: Own operations

Action:

• Internal audits conducted on HACCP and GMP in every Dino store at least once a year

Supplier Audit and Qualification Programme

Scope: Upstream value chain

Action:

The Product Quality Development Department carries out inspections and audits of suppliers with respect to safety and quality of products. The Company is consistently working on developing audit procedures among suppliers:

• Audits to approve all new suppliers of private label products – preceded by consumer assessment of products
• Audits to approve suppliers of branded products – including audits of regional bakeries
• Partial audits – pertaining to selected aspects of supplier functioning
• Periodic evaluation audits – conducted as part of regular supplier evaluation
• Preventive audits – conducted in event of irregularities to identify causes and formulate remedial program

Supplier requirements:

• Suppliers required to submit detailed specifications of quality requirements for each type of merchandise
• Up-to-date certificates required, including those confirming implementation of Global Food Safety Initiative (GFSI) standards

Product Recall and Remediation Procedures

Scope: Own operations and downstream (consumers)

Action:

When any product stocked on Dino's shelves is found to be out of compliance with food law requirements (based on own inspection or notification in Early Warning System for Hazardous Food and Feed kept by Chief Sanitary Inspectorate):

• Dino Polska recalls product from market
• Warns customers against consuming product
• Offers customers possibility of returning product to Dino

Key enablers:

• High degree of standardization of Dino stores
• Same product range in each store
• Centralized network management process

These factors enable the Company to efficiently take any remedial actions that may be necessary.

Pertinent procedures:

• Procedure for emergency recall of product that endangers health or life of consumer
• Procedure for non-compliant product recall

Commitment:

In event of material negative impact on consumers or contribution to such impact, Dino Polska undertakes to take appropriate corrective measures in line with at least recommendations issued by inspection authorities and carry out suitable assessment of corrective measure taken.

Agro-Rydzyna Complaint Handling Process

Scope: Own operations (subsidiary)

Action:

• Complaints regarding Agro-Rydzyna products handled by plant's technologists and specialists from quality department
• Tests conducted when necessary to verify proper operation of whole production and distribution process
• Record of instances of non-compliance kept as part of corrective measure taken
• Based on non-compliance sheets, Agro-Rydzyna determines causes of non-compliance and decides on corrective actions
• For supplier-related complaints, supplier required to cooperate in providing support to examine problem and take measures to prevent recurrence

Link to policies

All actions are implemented in accordance with:

• Quality Policy – goal to provide customers with safe and high-quality food that meets their expectations through development, deployment, maintenance and continuous improvement of GHP and HACCP systems
• Code of Conduct – includes product and service responsibility principles
• Code of Conduct for Suppliers – expected to be adhered to by every supplier

Resources allocated

Non-financial resources:

• Product Quality Development Department (dedicated organizational unit)
• Inspection Department with specialized Fruit and Vegetables Quality Control Team
• Warehouse Acceptance Quality Control units
• Quality control teams
• Team of Trainers
• Multiple specialized units within Product Quality Development Department specializing in managing quality of private label products, grocery products, and non-food products

Financial resources: Not quantified

Effectiveness monitoring

The effectiveness of the Company's policies is monitored through:

• Regular quality audits in own operations
• Regular quality audits in suppliers' businesses
• Objective: consistently increase number of such audits as store network grows

Targets related to consumers

The Company explicitly states that it does not set specific numerical targets related to consumers and end-users.

Disclosed approach

According to the ESRS S4-5 disclosure:

"The Company's long-term growth strategy sets out the main directions of the Dino Group's growth, but does not define any specific goals. The Company's ambitions in the key impact areas are pursued in a similar manner: the Company's Management Board defines the directions for action, particularly in terms of issues such as minimizing the number of customer complaints and cases of product recall due to non-compliance with food standards, or opening new Dino stores, but does not set any specific numerical targets."

Monitoring approach

The effectiveness of the Company's policies is monitored through:

• Regular quality audits in own operations and in the suppliers' businesses
• Objective to consistently increase the number of such audits as the store network grows (qualitative ambition, not quantified)

Key impact areas mentioned (without quantified targets)

• Minimizing the number of customer complaints
• Minimizing cases of product recall due to non-compliance with food standards
• Opening new Dino stores

Business conduct policies and corporate culture

Dino Polska's organizational culture supports the pursuit of the Company's mission "Dino – Closest to You". The Company has implemented comprehensive policies and procedures governing business conduct across five key areas: employee workplace, business relations, environmental impact, product quality, and community proximity.

Code of Conduct of Dino Polska S.A. and its subsidiaries

Scope: All employees, associates and managers of Dino Polska and its subsidiaries.

Governance: Not explicitly stated for approval; implementation monitored through various organizational units and mechanisms including Internal Audit Department, Management Controlling Department, Legal Department and Management Board Office.

Key content: The Code defines ethical values and conduct standards inspired by the Universal Declaration of Human Rights and the Ten Principles of the United Nations Global Compact. Key principles include:

• Creating a friendly and safe workplace
• Respecting human rights (excludes violation of human rights per Universal Declaration of Human Rights)
• Prohibits discrimination based on gender, religion, sexual orientation, disability, political views, nationality, education, age, marital status or other differences
• Prohibits stalking, mobbing and sexual harassment
• Prohibits child labor (under age 15); only permits employment of juveniles aged 15+ in accordance with applicable laws
• Prohibits forced labor or any forms of slavery
• Ensures equal access to career advancement for women and men
• Commitment to economical and efficient use of natural resources
• Commitment to minimize waste production through proper recycling and composting
• Counteracting conflicts of interest, corruption and bribery
• Ensuring product and service responsibility
• Respecting social surroundings and natural environment

Public availability: Publicly available at grupadino.pl/lad-korporacyjny/

Link to international standards: Inspired by the Universal Declaration of Human Rights and the Ten Principles of the United Nations Global Compact. The Company is committed to respecting human rights in accordance with the UN Guiding Principles on Business and Human Rights.

Monitoring: Violations should be reported through specified channels. All employees and associates, particularly team managers, are responsible for adhering to principles of respecting human dignity and responding to any manifestations of infringing upon them. The Company guarantees confidentiality to whistleblowers and excludes retaliation.

Dino Polska S.A. Code of Conduct for Suppliers

Scope: All suppliers with whom Dino Polska signs commercial contracts. The Code is an attachment to commercial contracts.

Governance: Not explicitly stated.

Key content: Defines principles of human rights, labor rights, environmental impact and business conduct that the Company expects suppliers to follow. Values include:

• Human rights: respecting human rights, ensuring decent and lawful working conditions, eliminating child labor practices
• Working conditions: occupational safety and health in accordance with applicable regulations and standards
• Business ethics: honesty, mutual trust and respect; no corruption or bribery
• Sustainable resource management: economical and efficient use of natural resources, initiatives to reduce consumption, responsible waste and emissions management
• Product quality and safety: manufacturing in accordance with applicable standards and regulations
• Responsible agriculture and animal husbandry: using plant protection products per regulations, respecting animal welfare

Public availability: Publicly available at grupadino.pl/lad-korporacyjny/

Link to international standards: Not explicitly stated.

Monitoring: The Code forms an integral part of commercial contracts signed with suppliers. The Company conducts audits at contractors' plants to assure quality of products and compliance with food law regulations. Contractual clauses reserve the right to terminate contracts for breaches.

Anti-corruption and Gift Policy of the Dino Polska Group

Scope: Dino Polska S.A., other Dino Group companies and their employees and associates, covering relationships between employees, managers, associates, counterparties and business partners.

Governance: Not explicitly stated for approval.

Key content: Defines responsibilities in preventing corruption. Prohibits:

• Accepting financial or personal benefits beyond framework in "Principles for accepting and offering gifts"
• Making performance of official duty contingent on receipt of benefit
• Granting benefits to persons holding public office
• Inducing public officials to violate law or promising benefits for such violations
• Granting or promising benefits for mediation in state institutions
• Accepting benefits in exchange for abusing powers or failing duties that may damage the Company
• Actions constituting unfair competition
• Thwarting or obstructing public tender procedures for financial advantage

Contractual clauses with anti-corruption provisions apply to all forms of cooperation. The Company reserves right to terminate contracts for breaches.

Public availability: Not stated.

Link to international standards: The policy is not fully compliant with the United Nations Convention against Corruption. As at the date of publication, no decision has been made on adoption of a policy fully consistent with the Convention.

Monitoring: Breaches can be reported through established whistleblowing channels. Contractual mechanisms allow for contract termination.

Principles for accepting and offering gifts in the Dino Polska Group

Scope: Dino Polska Group employees.

Governance: Not stated.

Key content: Clarifies the rules from the Anti-corruption and Gift Policy regarding conditions for offering or accepting gifts. Prohibits employees from offering gifts with intention of influencing anyone's decision-making or objectivity or making recipient feel obligated.

Public availability: Information about the rules is published annually on the intranet.

Link to international standards: Not stated.

Monitoring: Not stated.

Procedure for reporting breaches of the law, procedures and ethical standards in the Dino Polska Group

Scope: Applicable to the Dino Polska Group.

Governance: Not stated.

Key content: Governs scope of complaints as provided for in Act on Public Offerings and the Conditions for Introducing Financial Instruments onto an Organized Trading System and on Public Companies. Defines internal tool to increase effectiveness of monitoring, detecting and resolving situations related to irregularities and reporting breaches of law, procedures, good practices, ethical standards or reasonably justified suspicions.

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Reports recorded in Register of Reports. Investigations conducted by person or unit designated by Management Board, free from conflict of interest. Reports concerning Management Board Members examined by Supervisory Board Member or Supervisory Board. External entity may be commissioned in special cases.

Internal Whistleblowing and Whistleblower Protection Procedure of Dino Polska S.A.

Scope: All Group stakeholders, particularly employees and associates, partners, counterparties, subcontractors and customers.

Governance: Management Board appoints members of teams responsible for accepting and processing reports.

Key content: Sets detailed rules for reporting and processing whistleblower reports, specifies manner of meeting statutory and organizational requirements for protecting whistleblower identity, and lays down rules for follow-up actions and providing feedback. Protection measures include:

• Detailed procedure for handling reports
• Exclusion from investigation of employees with conflict of interest
• Confidentiality of data in reports; identity not disclosed without express consent
• Prohibition of retaliation
• Data encryption requirement
• Limited access to information to necessary minimum
• Consequences for persons who disclose confidential information

Reporting channels:

• Email to naruszenia@marketdino.pl
• Letter to Company's address
• In person to Legal Department, Management Board Member or Supervisory Board Member

Anonymous or confidential reporting permitted.

Public availability: Published on intranet. In 2024, the Company decided to deploy a dedicated IT tool (EY Virtual Compliance Officer) for Q1 2025.

Link to international standards: Adopted in accordance with the Whistleblower Protection Act, which implements Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons reporting breaches of Union law.

Monitoring: Reports recorded in Register of Reports and investigated. Investigation verifies report, evaluates risk, proposes countermeasures and monitors deployment. EY Virtual Compliance Officer fulfills requirements of Whistleblower Protection Act and Directive 2019/1937.

Anti-mobbing Policy

Scope: Dino Polska employees.

Governance: Management Board Representative on preventing mobbing reports directly to Company's Management Board.

Key content: Set of rules to counteract mobbing in the Company and deal with cases of occurrence. Key objective is to support activities fostering positive relations among employees. An anti-mobbing survey is conducted among employees.

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Internal anti-mobbing procedure in place. Anti-mobbing survey conducted among Dino employees to support prevention.

Tax Strategy

Scope: Not stated (presumably Dino Polska Group).

Governance: Not stated.

Key content: Objective is to ensure actions are in compliance with tax law regulations.

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Not stated.

Personal Data Protection Policy

Scope: All Company employees who process personal data as part of job responsibilities and other persons authorized by the Company to access personal data. Applies to all areas of Dino Polska Group's activity.

Governance: Personal Data Inspector reviews policy for adequacy no less frequently than once a year.

Key content: Developed to ensure compliance of personal data processing with requirements of Polish and European legislation. Defines methods to secure and handle personal data, identifies individuals responsible for processing and protection, and principles of processing. Provides for audits to check compliance. Includes procedures and rules for data subjects to exercise rights (access, revision, deletion).

Public availability: Available to all employees; training materials available.

Link to international standards: Ensures compliance with Polish and European legislation (implicitly GDPR).

Monitoring: Subject to review by Personal Data Inspector for adequacy no less than once a year. Dino Polska regularly monitors purposes of processing, legal grounds and scope of personal data. Supervision by internal GDPR Department.

Procedure for evaluating transactions with related parties

Scope: Not stated (presumably Dino Polska).

Governance: Not stated.

Key content: Fulfills requirements of Article 90j(2) of the Act on Public Offerings and the Conditions for Introducing Financial Instruments onto an Organized Trading System and on Public Companies.

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Not stated.

Compliance Policy

Scope: The Company and its employees.

Governance: Not stated.

Key content: Purpose is to deploy a Compliance System aimed at achieving and maintaining organizational level ensuring maximum degree of mitigation of potential risks. Activities include:

• Identifying amendments to legislation and market standards
• Informing Management Board and employees about requirements arising from laws and internal regulations
• Assessing risk of non-compliance to cover material business areas, especially those most exposed
• Determining method of ensuring compliance and monitoring
• Determining division of tasks within compliance system with emphasis on supervision

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Oversight by designated parties over compliance system.

Risk management procedure

Scope: Dino Polska.

Governance: Not stated.

Key content: Defines principles of risk management, outlines organizational structure of risk management, establishes roles and responsibilities of Company's management and employees. Defines objectives and principles of risk management process and methods of dealing with and monitoring identified risks.

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Central risk matrix established as tool for monitoring and prioritizing internal audit process.

Quality policy

Scope: Dino Group.

Governance: Not stated.

Key content: Purpose is to provide all network customers with safe and high-quality food meeting expectations. Pursued through development, deployment, maintenance and continuous improvement of Good Hygienic Practice (GHP) and Hazard Analysis and Critical Control Point (HACCP) systems in all stores and distribution centers. Staff have necessary knowledge and capability to apply it in practice. Involvement of all staff in pursuing objectives helps prevent food safety risks.

Public availability: Not stated.

Link to international standards: GHP and HACCP systems.

Monitoring: Regular quality checks and inspections throughout value chain. Internal audits conducted on HACCP and GMP in every Dino store at least once a year.

Environmental Policy

Scope: Generally applies to Dino Group for own operations.

Governance: Implementation is responsibility of head of Environmental Protection Department. Management Board of Dino Polska and Subsidiaries provide necessary financial, technical and organizational resources.

Key content: Covers climate change mitigation with specific focus on:

• Identification of applicable legal and environmental requirements and consistent compliance
• Rational management of materials and utilities and reduction of utility consumption, especially water
• Proper waste management and minimization of waste mass
• Use of reusable packaging and optimization of packaging
• Minimizing commodity and production losses
• Commitment by employees (in Code of Conduct) to minimize waste production and use natural resources sparingly
• Commitment by suppliers (in Supplier Code) to manage natural resources sparingly and reduce waste

Policy was pursued in 2024 and previous years and adopted in form of official document in 2025.

Public availability: Not stated.

Link to international standards: Not stated.

Monitoring: Implementation monitored by Environmental Protection Department. In 2022, Agro-Rydzyna implemented ISO 14001 environmental management system, certified accordingly.

Work Rules and Regulations

Scope: Employees.

Governance: Not stated.

Key content: Ensures respect for employee rights. Defines basic obligations of employees and employer, issues related to working time, absences and vacations. Regulates areas of organizational responsibility, rewards and distinctions, timing and method of salary payment. Defines in detail protection of work of women, people with disabilities and minors.

Public availability: Made available to employees via intranet and posted in places accessible to employees (social rooms in stores, distribution centers) or handed over when concluding employment contract.

Link to international standards: Not stated.

Monitoring: Not stated.

Compensation Rules and Regulations

Scope: Employees.

Governance: Not stated.

Key content: Clarifies company's remuneration rules and indicates work-related cash benefits.

Public availability: Made available to employees via intranet and posted in accessible places or handed over when concluding employment contract.

Link to international standards: Not stated.

Monitoring: Not stated.

Internal health and safety procedures

Scope: Employees and associates.

Governance: Not stated.

Key content: Regulate OSH issues separately for stores, offices and distribution centers. Preventing accidents and providing conditions ensuring occupational safety and health is top priority.

Public availability: Made available to employees via intranet and posted in accessible places or handed over when concluding employment contract.

Link to international standards: Not stated.

Monitoring: Not stated.

Due diligence process

The Company has a due diligence process with regard to sustainability matters as part of overall management system, in accordance with UN Guiding Principles on Business and Human Rights. The process covers identifying and assessing adverse impacts, taking actions to address them, and tracking effectiveness.

Training on business conduct

As part of onboarding, all newly hired employees undergo training covering business conduct policy and corporate culture. Additional training information, including on rules for offering and receiving gifts, is published annually on the intranet. Regular training provided on personal data protection, legal regulations and other topics. Training targeted at office staff, store and warehouse employees, with scope tailored to specific duties and identified risks. The Group does not keep statistics on business training. No training on whistleblower protection system was provided in 2024.

Policies not in place

The Company does not have:

• Dedicated policies specifically aimed at eliminating discrimination (including harassment), promoting equal opportunities and other ways to enhance diversity and inclusion (given general corporate culture and current Code of Conduct which prohibits discrimination)
• Separate policy on climate change adaptation and physical and transition risk management (based on past assessments that climate-related risks are not expected to have significant impact)
• Formal diversity policy (decisions on promotion and employment based solely on competences, experience and familiarity with Company)
• Separate policy dedicated to water and marine resource issues (beyond general environmental policy references)
• Separate policy defining framework for cooperation with SMEs (terms negotiated in same manner as with any other entity, subject to applicable legal provisions)

Prevention and detection of corruption and bribery

Anti-corruption and Gift Policy of the Dino Polska Group

Purpose and scope: The Policy defines the obligations of Dino Polska S.A., other Dino Group companies and their employees and associates in the prevention of corruption in relations between employees, managers, associates, counterparties and business partners.

Key prohibitions:

• Accepting any financial or personal benefits or promises thereof in connection with the performance of official duties that extend beyond the framework set forth in the "Principles for accepting and offering gifts in the Dino Polska Group"
• Making the performance of any official duty contingent on the receipt of a financial or personal benefit
• Granting a financial or personal benefit to any person holding a public office
• Inducing a person holding a public office to violate the law or granting or promising to grant such a person a financial or personal benefit for violating the law
• Granting or promising to grant a financial or personal gain in exchange for mediation in settling a matter in state institutions
• Accepting financial or personal benefits in exchange for abusing the powers granted or failing to fulfill the duties incumbent on the employee that may cause damage to the Company or any Dino Group member
• Taking actions constituting an act of unfair competition within the meaning of the Act of 16 April 1993 on Combating Unfair Competition
• Thwarting or obstructing a public tender procedure in order to gain a financial advantage

Contractual implementation: The Company has developed contractual clauses applicable to all forms of cooperation and civil law relationships with the Company and containing anti-corruption provisions. In the event that a counterparty breaches any of the provisions of the contractual clauses, the Company reserves the right to terminate any contract, agreement or other civil-law relationship.

Enforcement: Failure to comply with the rules results in disciplinary action against the employees involved.

Communication: The Policy is communicated to employees via the intranet.

Training: In 2024, the Company did not conduct any training programs on anti-corruption or anti-bribery.

Monitoring and updates: The Policy is subject to regular review and is updated on an as-needed basis. The Company has a team in place to conduct internal investigations in the event of breaches of the Policy.

Alignment with international standards: The Anti-corruption and Gift Policy is not fully compliant with the United Nations Convention against Corruption. As at the date of publication of this Statement, no decision has been made on the adoption of a policy fully consistent with the Convention.

Oversight: The Management Board is supported by the Internal Audit Department, the Management Controlling Department, the Legal Department and the Management Board Office, which monitor the company's management practices and policies, in particular the implementation of the anti-corruption policy.

Principles for accepting and offering gifts in the Dino Polska Group

Purpose: Clarify the rules laid down in the "Anti-corruption and Gift Policy of the Dino Polska Group" regarding the conditions for offering or accepting gifts.

Key prohibition: The procedure prohibits employees from offering gifts with the intention of exerting an impact on anyone's decision-making or objectivity or making the recipient feel obligated in any manner whatsoever.

Specific preventive and control mechanisms

For merchandise purchasing (vulnerable positions):

• Multi-stage process of accepting commercial terms
• Analysis of commercial terms for alternative products
• Changing the buyers responsible for particular categories of goods
• Analysis of product sales performance

For real estate purchases (vulnerable positions):

• Multi-stage real estate purchase approval process (for the most expensive real estate, decisions are made by the Company's Supervisory Board)
• Standardized selection process for new real estate
• Verification of sellers and intermediaries
• Verification of previous transactions involving the property
• Evaluation of the property and the purchase conditions based on information obtained from various sources
• Price analysis of other similar properties
• Price analysis of neighboring properties
• Monitoring the practices of own employees and associates by obtaining feedback from the sellers of the real estate

Limitations in current framework

Apart from the Anti-corruption and Gift Policy and the related Rules for Accepting and Offering Gifts, the Company has no separate procedures in place to prevent, detect or respond to allegations or incidents of corruption and/or bribery.

Due to the absence of corruption incidents, no investigating persons or investigating committees have been appointed to date. The Company does not have a procedure in place for reporting the outcomes of investigations to the administrative, management and/or supervisory bodies. No plan has been made to adopt such a procedure.

Incidents of corruption or bribery

Confirmed incidents

In 2024, there were no incidents of corruption or bribery in the Dino Group.

Convictions and fines

In 2024, there were no convictions or fines for violations of anti-corruption or anti-bribery laws by Dino Group companies or their employees.

Investigation and speak-up mechanisms

The Company has established multiple confidential channels for reporting breaches of the law, procedures and ethical standards, including violations related to corruption and bribery. These channels are available to all Group stakeholders, including employees, associates, partners, counterparties, subcontractors and customers.

Violations may be reported:

• By e-mail to naruszenia@marketdino.pl
• By letter to the Company's address
• In person to the Legal Department, any Management Board Member or any Supervisory Board Member

The Company permits anonymous or confidential reporting of violations, ensuring that the whistleblower's data and any other information enabling their identification is not accessible to unauthorized persons. All reports are recorded in the Register of Reports. Investigations are conducted by a person or unit designated by the Management Board, free from any conflict of interest and guaranteeing impartiality and independence. Reports concerning Management Board Members are examined by a Supervisory Board Member or the Supervisory Board.

In 2024, the Company decided to deploy a dedicated IT tool ("EY Virtual Compliance Officer" from EY) enabling the reporting of violations and their comprehensive handling. The solution will replace the previously existing reporting channels, and its deployment is scheduled for Q1 2025.

The Company guarantees confidentiality to whistleblowers and excludes any retaliation against them. The Internal Whistleblower Protection and Whistleblower Reporting Procedure adopted by the Group ensures protection of every person making a report in accordance with the Whistleblower Protection Act, which implements Directive (EU) 2019/1937.

Due to the absence of corruption incidents, no investigating persons or investigating committees have been appointed to date.

Political influence and lobbying activities

Political engagement approach

Neither Dino Polska nor any of its Subsidiaries were involved in any lobbying activities or made any political financial or in-kind contributions in 2024.

Political contributions

In 2024, the Company made no political financial or in-kind contributions.

Lobbying expenditure

In 2024, the Company was not involved in any lobbying activities and incurred no lobbying expenditure.

Appointments from public administration

In 2024, the Company did not appoint to administrative, management or supervisory bodies any persons who had held comparable positions in public administration in the previous two years.

Payment practices

Payment terms and practices

The Dino Group makes every effort to settle its financial liabilities in a timely manner and to support the financial stability of its business partners. The Company's payment practices comply with the applicable regulations, contracts and market standards. Payment terms for suppliers are negotiated and recorded in the respective contracts.

Maximum payment terms applied

The maximum payment terms applied by the Dino Group do not exceed the terms permitted by law (in particular by the Act of 8 March 2013 on Counteracting Excessive Delays in Commercial Transactions and the Act of 17 November 2021, on Counteracting Unfair Use of Contractual Advantage in Trade in Agricultural and Food Products), specifically:

• In respect of a supplier against whom the Company has a contractual advantage – 30 days for perishable agricultural or food products
• In respect of a supplier against whom the Company has a contractual advantage – 60 days for agricultural or food products
• In respect of a micro/small/medium-sized enterprise – 60 days
• In respect of a large enterprise – 60 days, with the possibility of extension to 120 days if the parties expressly agree to such an extension in the contract, provided that the arrangement is not grossly unfair

On-time payment performance (2024)

99.95% of all payments (in terms of their value) were made by the Group within the contractual deadlines in 2024.

Average time to pay invoices (2024)

The average period it took the Dino Group to settle an invoice from the start date of the contractual or statutory time limit for payment until the actual date of payment was 35 days.

Calculation basis: Nearly 2.3 million payments made by Dino Polska to suppliers of merchandise.

Assurance: The above metrics were not validated by an external assurance provider.

Legal proceedings for late payment

As at the date of this report, the Company is a party to 5 pending court cases concerning late payments. The reasons for these cases stem from delays in the performance of contracts by the service provider, including defective service provision, which resulted in discrepancies in the final financial settlement of the service. The cases concern mutual claims arising, without limitation, from contractual penalties charged to the service provider by the Company or the costs of substitute performance, including deductions made from collateral. The amounts in question are disputed.

The Company emphasizes that all undisputed payments to its suppliers for work performed and accepted in accordance with the pertinent reports were settled by the Company in a timely manner.

Payment process mechanisms

The primary mechanism preventing the Company from delays in payments to SMEs and all other suppliers is long-term cooperation, which involves regular deliveries to the Company's distribution centers. The Company has mechanisms in place to streamline the payment process, such as an electronic invoice circulation system and procedures for the control and approval of accounting documents.