EDP - Energias de Portugal SA

Reference: page 86

EDP operates a dualist governance model with a five-member Executive Board of Directors (3 male, 2 female) and a 16-member General and Supervisory Board (GSB). The Executive Board manages business affairs and oversight of impacts, risks and opportunities collegially, with CFO Rui Teixeira holding specific responsibility for ESG. The GSB monitors and assesses sustainability through two specialised committees: the Corporate Governance and Sustainability Committee and the Financial Matters Committee. Members are selected under the 2018 Selection Policy, which promotes diversity in age, gender, geographical origin, skills, qualifications and experience. The GSB gender diversity ratio is 0.60 and 56.25% of members are independent; the Executive Board ratio is 0.67. The boards are supported by internal Sustainability and Risk Management Committees of technical specialists. A GSB competence matrix discloses sustainability and risk expertise, and members received CSRD and non-financial reporting training during 2024.

Reference: page 92

The administrative, management and supervisory bodies are informed about material impacts, risks and opportunities, due diligence implementation, and the results and effectiveness of policies, actions, metrics and targets at least quarterly through meetings of the GSB, the Corporate Governance and Sustainability Committee and the Financial Matters Committee. Information is compiled by Business Enablement Functions covering ethics and compliance, people and organization, procurement, digital, investor relations and ESG, and risk and security, which prepare detailed reports for quarterly review meetings. Feedback is used to refine future policies and actions. The Risk Management function meets the Financial Matters Committee quarterly, presenting EDP's Risk Appetite Dashboard and Annual Risk Map; the sustainability reporting challenge was addressed seven times during 2024. The 2023-2026 strategic plan, with decarbonization and ESG goals, was approved with board involvement, and the double materiality assessment result is approved by the Executive Board and presented to both GSB committees.

Reference: page 94

EDP has two remuneration policies, approved at the 2024 annual general meeting: one for the Executive Board of Directors and one for the remaining bodies. The Executive Board policy provides a fixed base remuneration plus annual and multi-annual variable components linked to performance, including ESG indicators. Annual ESG indicators include Dow Jones Sustainability Index results, the employee climate survey, and the customer satisfaction index. Multi-annual ESG indicators include the increase in renewable energy share, emissions reduction, and Bloomberg Gender Index performance. The percentage of variable remuneration dependent on sustainability-related targets and impacts is 20% for the annual variable component and 20% for the multi-annual variable component. The General and Supervisory Board members receive only fixed remuneration. The Executive Board policy is approved by the General Shareholders' Meeting on a Remuneration Committee proposal and updated at least every four years or upon significant change.

Reference: page 95

EDP describes its due diligence process as a comprehensive approach integrating sustainability across operations, with core elements mapped to ESRS disclosures. These include embedding sustainability due diligence into governance, strategy and the business model (GOV-1, GOV-2, GOV-3, SBM-3); the double materiality assessment as the structuring process identifying topics significant to stakeholders and to EDP's business, including financial impacts, risks and opportunities (GOV-2, IRO-1); engaging with affected stakeholders to understand concerns and expectations (SBM-2, MDR-P and the topical engagement DRs); identifying and assessing potential adverse impacts on society and the environment to prioritise actions and allocate resources (IRO-1, SBM-3); taking targeted actions to mitigate or eliminate adverse impacts, integrated into sustainability strategies (MDR-A and topical action DRs); and tracking effectiveness through metrics and targets with regular reporting for transparency and accountability (MDR-M, MDR-T and topical metric DRs).

Reference: page 96

EDP is developing a project to implement an Internal Control System for Sustainability Reporting (ICSSR) under shared management of Ethics & Compliance and Investor Relations & ESG. The project is based on a scope definition model covering the double materiality exercise and mandatory disclosures, a gap analysis of reporting disclosures and processes, identification and gap analysis of controls, and an implementation plan. The risk assessment approach identifies sources of risk and evaluates whether they could cause a material misstatement, characterising risks by Magnitude and Likelihood. As the project is ongoing, EDP is still mapping risks, processes and controls. Main risks relate to data completeness and integrity, accuracy of estimation results, and timely availability of information across the reporting value chain. Mitigation strategies under development include data validation procedures, improved estimation methodologies, clearer roles and timelines, automation, and training. Once complete, findings will be reported quarterly to the Executive Board and the Financial Matters Committee.

Reference: page 97

EDP is an integrated energy group operating across the electricity and gas value chain in regulated and liberalized markets in five regions: Iberia (electricity and gas supply), the rest of Europe (renewables), North America (wind and solar in the US and Canada), South America (renewables) and Asia-Pacific (solar). Products and services include electricity and natural gas supply, distributed solar generation and energy communities, electric mobility and charging, energy efficiency products and services, technical assistance (EDP Funciona), and service packs. The value chain has three phases: upstream (raw material suppliers including coal and gas, contractors, service providers), own operations (generation from wind, hydro, solar, gas and coal with emphasis on renewables, storage, and distribution networks), and downstream (supply to residential, commercial and industrial customers). Total revenue in 2024 was about 14,965,762 thousand euros and headcount was 12,596. EDP has some fossil fuel revenue (coal 41,172,530 euros; gas 266,136,061 euros). Its vision is energy transition leadership across four strategic pillars, with 2026 decarbonization, community, planet, partner and ESG culture goals.

Reference: page 100

EDP has a Stakeholder Management Policy (2013, with a 2015 methodology and a 2023 Local Stakeholder Engagement Policy) overseen by a Stakeholder Team and Centre of Excellence. Its engagement methodology requires internal and external views from independent assessments, generating an action plan with monitoring and reporting criteria. The stakeholder mapping has four areas (Democracy, Market, Value Chain, and Social/local communities) covering 24 groups including employees, suppliers, communities, customers, investors and institutions. Engagement methods include internal climate studies, supplier surveys, customer surveys, focal points for affected communities, and direct evaluations of impacts, risks and opportunities within the double materiality assessment. During 2024 EDP engaged EU institutions and sectoral associations on decarbonization policy and secured European funding (over 187 approved projects and more than 200 million euros since 2021). Engagement aims to identify and understand stakeholders, build trust, integrate expectations into management, and identify emerging risks and opportunities. There were no amendments to EDP's strategy or business model; further steps include the SCOPE 360 project and deeper community assessment.

Reference: page 103

The materiality assessment identified material impacts, risks and opportunities across the ESRS topics, all of which are material except E2 Pollution. Material impacts span E1 Climate change (climate adaptation and mitigation strategies, GHG emissions, low carbon and decentralized generation), E3 Water, E4 Biodiversity, E5 Resource use and circular economy, S1 Own workforce (diversity, wage disparity, health and safety, well-being), S2 Workers in the value chain (labour practices), S3 Affected communities (energy access, inequality risks, indigenous rights), S4 Consumers (energy price volatility, sustainable offer, energy poverty), and G1 Business conduct (ethics, transparent disclosure). Entity-specific topics include fair energy transition, digital transformation, responsible investment, business continuity and resilience, and information privacy and security. Material risks and opportunities include acute and chronic climate physical risks, climate transition risks, carbon pricing, energy efficiency and renewable opportunities, electric mobility, water stress, circular economy opportunities, resource scarcity, workforce diversity opportunities, supplier due diligence risks, infrastructure failure and data breaches, classified by time horizon and value chain position. These IROs are addressed by the bodies and inform strategy.

Reference: page 112

EDP's identification of impacts, risks and opportunities is established by its Enterprise Risk Management framework, structured around four risk categories (Strategic & ESG, Business, Financial, Operational). The double materiality assessment cross-references multiple sources: previous reports and materiality results, desk research and benchmarking, the ESRS topical standards list (ESRS 1 AR 16), international institutions and reporting frameworks, internal meetings with key departments, a consultant IRO library, and stakeholder engagement. Impacts are classified as actual or potential, positive or negative, by time horizon and value chain position. Impact materiality uses severity (scale, scope, irremediability) and likelihood; financial materiality uses magnitude (reputation and economic impact, with euro thresholds) and likelihood. Stakeholder surveys rated impacts on a scale from minus 4 to plus 4, complemented by internal studies and direct evaluation by focal points across all Platforms and Regions. Final scores were averaged, a materiality threshold (e.g. greater than or equal to 2) applied, and results validated by the Executive Board and presented to both GSB committees. E2 Pollution resulted as not material. The DMA will be conducted every two to three years.

Reference: page 125

IRO-2 sets out which ESRS Disclosure Requirements EDP complies with following the outcome of the materiality assessment, together with the page on which each is located. ESRS 2 General Disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) are reported, alongside the topical standards assessed as material: E1 Climate change, E3 Water and marine resources, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users, and G1 Business conduct. E2 Pollution was assessed as not material, so its disclosure requirements (E2-1 through E2-6) are marked Not material, with only the E2 IRO-1 process disclosure provided. EDP also discloses (under IRO-2_01) the list of data points deriving from other EU legislation, including SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, indicating their materiality and location in the statement, such as GOV-1 board gender diversity and independence, GOV-4 due diligence mapping, and SBM-1 fossil fuel revenue disaggregation.

Reference: page 168

EDP's Climate Transition Plan, developed in 2023 by an internal Net-Zero Acceleration Task Force, sets the strategy for reaching Net Zero by 2040. It was approved by the Executive Board of Directors and subjected to a consultative vote of the Annual General Meeting in 2022. The Plan is aligned with TCFD, CDP and the UN High Level Expert Group recommendations. Targets approved by SBTi under the Net-Zero standard are aligned with the 1.5C trajectory, limiting global warming to 1.5C in line with the Paris Agreement. Milestones include coal-free by 2025, all green (100% renewable generation) by 2030 and net-zero by 2040. Near-term and long-term intensity targets for Scope 1+2 are -95% by 2030 and -96% by 2040, with Scope 3 absolute targets of -45% by 2030 and -90% by 2040. By 2024 EDP had reduced total emissions by 42% versus the 2020 base year. Under the 2024-2026 Business Plan EDP will invest 17 billion euros, 80% in renewables, clients and energy management.

Reference: page 189

EDP manages its material climate impacts, risks and opportunities through several policies. Climate change mitigation is addressed by the Environmental Policy, Climate Transition Plan, Risk Management Policy, Sustainable Procurement Policy, Supplier Code of Conduct and Circular Economy Strategy. Climate change adaptation is addressed by the Environmental Policy, Climate Transition Plan and Risk Management Policy. Energy efficiency is addressed by the Environmental Policy, and renewable energy deployment by the Environmental Policy and Climate Transition Plan. The Environmental Policy sets EDP's vision and commitments on environmental and climate management, with commitments to achieve carbon neutrality by increasing the renewable portfolio, reducing direct and indirect GHG emissions, providing low carbon solutions to customers, promoting electrification and energy efficiency, and promoting climate adaptation to maximise asset resilience. The Executive Board of Directors approves the Environmental Policy and its revisions; the Sustainability Committee assesses proposals and the Sustainability Department monitors implementation across the group.

Reference: page 191

EDP's key mitigation actions, part of the Climate Transition Plan, are grouped by decarbonisation lever: 0% thermal generation (exit coal-fired by 2025 and gas-fired by 2030, Scope 1); increase renewable generation (about 23 GW installed capacity and 250 MW of H2 electrolysers by 2026); distribution power losses reduction including 100% smart meters in Iberia by 2025 (Scope 2); reduce generation-retail imbalance through PPAs and EACs (Scope 3); lower supply chain emissions; and minimise natural gas retail emissions (Scope 3, 2030-2040). Achieved emission reductions versus 2020 include 7,840,276 tCO2e from 0% thermal generation (-85%), 363,661 tCO2e from distribution losses (-64%) and 1,567,617 tCO2e from minimise natural gas retail (-65%). The 2024-2026 Business Plan provides 17 billion euros of resources, 80% in renewables, clients and energy management and 20% in networks, financed via asset rotation and sustainable finance including green bonds and sustainability-linked loans.

Reference: page 192

EDP set GHG reduction targets from a 2020 base year, approved by SBTi under the Net Zero Standard and Power Sector guidance, aligned with the 1.5C trajectory and covering all scopes with no exclusions. Near-term (2030) targets: reduce Scope 1+2 emissions 95% per MWh generated; reduce Scope 1+3 from all sold electricity 80% per MWh; reduce absolute Scope 3 from use of sold products 45%; and reduce all other absolute Scope 3 emissions 45%. Long-term (2040) targets: Scope 1+2 -96% per MWh generated; Scope 1+3 all sold electricity -95% per MWh; Scope 3 from sold products -90%; other Scope 3 -90%; and a Net Zero (Scope 1+2+3) -90% target by 2040. The Scope 1+2 intensity fell from 157 gCO2eq/kWh in 2020 to 29 in 2024 (-81.3%). A 2024 re-baselining (due to coal divestment) lowered base-year Scope 1 to 5,576,472 tCO2e; targets will be revisited with SBTi.

Reference: page 196

Total energy consumption related to own operations in 2024 was 9,375,061 MWh. Of this, 7,193,275 MWh came from fossil sources, comprising 1,040,209 MWh coal and coal products, 57,909 MWh crude oil and petroleum products, 5,376,488 MWh natural gas, and 718,669 MWh purchased electricity, heat, steam or cooling from fossil sources. Consumption from nuclear sources was 9,924 MWh and from renewable sources 2,171,862 MWh (including 2,169,993 MWh self-generated non-fuel renewable energy). The energy mix is 76.73% fossil, 0.11% nuclear and 23.17% renewable. On the production side, EDP generated 54,617,797 MWh of renewable energy versus 2,861,564 MWh non-renewable, meaning about 95% of generation is renewable. Energy intensity for high climate impact sectors (all of EDP's activity) was 626 MWh per million euros of net revenue, based on net revenue of 14,966 million euros.

Reference: page 198

Gross GHG emissions for 2024 (GHG Protocol, financial control): Gross Scope 1 was 1,458.32 ktCO2e (1,458,323 tCO2e), with 98.27% covered by regulated emission trading schemes. Gross location-based Scope 2 was 233.48 ktCO2e and market-based Scope 2 was 233.56 ktCO2e. Gross Scope 3 was 9,540.56 ktCO2e, driven by capital goods (3,218.20), fuel and energy-related activities (3,367.21), use of sold products (837.49) and investments (1,451.09). Total GHG emissions were 11,232.36 ktCO2e location-based and 11,232.44 ktCO2e market-based, down from 19,493.23 ktCO2e in 2020 (a reduction of 8,260.86 ktCO2e). GHG emissions intensity per net revenue was 15.60 tCO2e per million euros location-based and 15.61 tCO2e per million euros market-based. About 38.39% of Scope 3 was calculated using primary data. The inventory covers CO2, CH4, SF6 and N2O using IPCC AR5 100-year GWP.

Reference: page 202

In the reporting year EDP did not develop GHG removals and storage projects in its own operations, nor contribute to projects in its upstream or downstream value chain, so total GHG removals and storage, associated emissions and reversals were all 0 tCO2e. EDP did use carbon credits: 211,618 tCO2e of carbon credits were cancelled in 2024, of which 5.6% were from removal projects and 94.4% from reduction projects, all certified to the Verified Carbon Standard. Only 0.7% came from projects within the EU and 0% qualified as corresponding adjustments. A further 255 tCO2e of credits are planned to be cancelled in the future, up to 2040. Credits were acquired by EDP Brasil (Jari Amapa REDD+ project, Verra/VCS) and EDP Renovaveis (Hickory Solar, 210,000 VCUs, 209,745 cancelled in 2024). EDP's SBTi-approved Net Zero commitment does not require offsetting before 2040; residual emissions from 2040 onwards shall not exceed 10% of base-year emissions.

Reference: page 204

EDP applies an internal carbon price of the shadow price type. The CAPEX shadow price is 67 euros per tCO2eq, applied to a volume at stake of 4,316,000 tCO2eq covering thermoelectric power stations under the EU-ETS. EDP uses this internal carbon price to assess the impact of current and future carbon regulation on energy prices and volumes, on existing assets' value, and to evaluate capital investments in new electricity generation assets; it is aligned with the price of allowances under an Emissions Trading Scheme and covers Scope 1 emissions. The scheme covered 98.27% of gross Scope 1 emissions, 0% of gross Scope 2 and 0% of gross Scope 3 in 2024. The carbon pricing scheme is built as a range of values for 2030 to 2050 in 5-year intervals, based on short-term EU-ETS CO2 futures and external sources such as the IEA, consistent with the average EU-ETS price per tonne used in the financial statements.

Reference: page 208

EDP aggregated all former Group environmental policies, including its Water Management Policy, into a single Environmental Policy. It commits to promoting efficient use of natural resources and sustainable management of water across all processes, operations and installations. EDP recognises access to drinking water and sanitation as a universal human right and links its water work to SDG 15 and SDG 7. The policy addresses use and sourcing of water and marine resources, prevention of water pollution via robust environmental management systems, compliance with applicable legislation, stakeholder consultation, and minimising consumption in water-stressed areas. EDP notes its activities have no direct impact on marine resources; impacts are indirect, mitigated through control of oils, spillages and effluent pollutants. To assess exposure, EDP uses the WRI Aqueduct and Water Risk Filter tools, applying a Baseline Water Stress threshold of 40 percent. The water commitment forms part of its circular economy axis.

Reference: page 212

The actions and resources for water and marine resources are reported under E5.MDR-A_01-12, covering only own operations, with annual monitoring and no defined time horizon or associated targets. For areas at water risk, EDP has requested the closure of the Los Barrios coal plant in Spain and is awaiting feedback from the regulator, which will likely depend on availability of back-up energy production sources in the area. Los Barrios, identified as a water-risk asset, is of particular interest in regional water management discussions through the Mesa de la Sequia forum led by Arcgisa, the public water supply company of the Campo de Gibraltar Municipal Association, attended by industries, the Port, farmers, the livestock sector and environmental associations. The plant has adopted good practices to minimise water consumption, including reusing wastewater from the desulphurisation plant to become a zero-discharge facility and reusing clean rainwater for the fire suppression system.

Reference: page 213

EDP's water consumption reduction target is based on its Circular Economy Strategy and is organisation-wide, covering all direct operations and geographic locations without exclusions. EDP aims to achieve a 78 percent reduction in freshwater consumption by 2025 compared to 2015 levels. A structured methodology collects four years of water consumption data for thermal and renewable generation assets and applies factors to estimate future consumption, with networks projected on average consumption, all based on Business Plan net production projections. Progress is reported through the Integrated Annual Report and quarterly ESG reports, assessed against the 2015 baseline. Targets align with the European Green Deal and UN SDGs. The target was achieved due to the Business Plan 2024-2026, which targets 23 GW of renewable capacity by 2026 (wind and solar), becoming coal free by 2025, all green by 2030 and net-zero by 2040. EDP also maintains an organisation-wide goal of no environmental accidents or penalties impacting water; in 2024 it ran 72 environmental simulation exercises. The targets are voluntary.

Reference: page 214

Total water consumption in 2024 was 3,218 thousand m3, down from 5,430 thousand m3 in 2023. By segment: Renewable 8 thousand m3, Generation 3,081 thousand m3, Client solutions N/A, Networks 58 thousand m3, Other 72 thousand m3. Water consumption in areas at water risk (including high-water stress) was 30 thousand m3 in 2024, down from 324 thousand m3 in 2023. Total water withdrawals were 100,925 thousand m3 in 2024 (543,304 in 2023) and total water discharges were 97,371 thousand m3 (538,244 in 2023). Total water stored was 7,900,887 thousand m3 with changes in storage of 345,659 thousand m3. The water intensity ratio was 0.00015 thousand m3 per thousand euros. 100 percent of the measure was obtained from direct measurement. Group freshwater consumption fell 95 percent between 2015 and 2024, driven by a 92 percent reduction in coal-fired generation versus 2023. Facilities exposed to water risk account for 8 percent of the Group, namely Los Barrios in Spain plus hydropower plants in Portugal. Hydroelectric water use (169 million m3 managed, up 29 percent) is non-consumptive.

Reference: page 215

EDP assesses the anticipated financial effects of structural reductions in water availability affecting hydro generation in Portugal. The Changing precipitation patterns risk was evaluated using RCP scenarios 2.6, 4.5 and 8.5 for 2025, 2030 and 2050, with precipitation variations from Copernicus data. A structural reduction in average precipitation of 5 to 10 percent is expected in Portugal, and 20 to 40 percent in the worst case (P95) depending on the scenario, assessed as the accumulated maximum loss at P95 from 2030 to 2050. EDP has material exposure to variation in hydro volumes: assuming a price of 80/MWh, a 20 percent reduction in expected volume impacts EBITDA by 100M to 140M. In the winter of 2021/2022 an extreme drought caused a record hydro shortfall of 2.6 TWh, with average electricity price reaching 229/MWh in 1Q22 (up 407 percent year-on-year), implying a 0.4bn EBITDA loss and a negative net result of -76m. EDP manages this risk through technology and geographic diversification.

Reference: page 228

EDP discloses its biodiversity strategy and resilience approach. EDP does not yet have a Nature Transition Plan; it will be published during 2025, and EDP has committed to report in alignment with TNFD in 2026. Time horizons for scenario analysis will be the same as those used for TCFD: 2025, 2030 and 2050. EDP is aligning its processes with TNFD guidance and has used the LEAP approach to identify nature-related impacts, dependencies, risks and opportunities (physical and transition) at the technology level for its own operations, supporting the double materiality process, with a deeper analysis planned for 2025 to integrate operational specificities and the supply chain. The implementation strategy is based on the AMAT methodology, inspired by SBTN's Step-by-Step Guide to nature-based target setting. EDP maintains an environmental risk management process supporting its corporate environmental management system, with risks classified across physical and transition categories including climate change, biodiversity, use of natural resources, pollution, technologies, supply chain, innovation and regulation.

Reference: page 228

EDP's Environmental Policy recognises the environment as a strategic management element and includes specific biodiversity commitments: contributing to reducing biodiversity loss by promoting the mitigation hierarchy and aiming for a long-term net benefit in biodiversity, and deepening scientific knowledge of biodiversity and ecosystem services through partnerships. The policy relates to E4 AR4 matters including impact drivers (climate change; land-use, freshwater-use and sea-water change; direct exploitation; invasive alien species; pollution), impacts on species and ecosystems, and dependencies on ecosystem services. The policy applies to all sites owned, leased or managed by the Group, whether or not in or near protected areas, with scope per BP-1_03 and no exclusions. Procurement practices use biodiversity as a screening topic to assess supplier maturity, and EDP requires life cycle assessment information from suppliers for key components, though traceability criteria do not yet include biodiversity due to complexity. EDP has no specific deforestation policy, but the mitigation hierarchy contributes to no net deforestation. The policy does not explicitly address sustainable land or agriculture practices.

Reference: page 231

EDP's main biodiversity actions, all in place with a 2026 time horizon and applied to direct operations across all geographies, are: performing environmental feasibility studies at early project stages to ensure proper asset location and avoid biodiversity-sensitive areas; performing environmental impact studies and specific studies to manage impacts across the facility lifecycle; environmental monitoring during construction, operation and decommissioning; and implementation of Environmental Management Systems. These contribute to EDP's biodiversity targets (no sites in World Heritage areas; Biodiversity Net Gain on new projects; internal tracking system; Biodiversity Action Plans at high-risk facilities). EDP follows the mitigation hierarchy but has not yet quantified achievement of No Net Loss or Net Gain, so biodiversity offsets have not been included in the action plan. EDP incorporates local and indigenous knowledge and nature-based solutions; examples include seed cleaning and scarification in the Los Canones project in Mexico (recommended by the local indigenous community via the Autonomous University of Nuevo Leon) and local plant species management in the Los Cuervos project. Expenses are reported in note 49.

Reference: page 232

EDP set environmental targets supporting the Kunming-Montreal Global Biodiversity Framework and its 2030 targets, covering the report scope per BP-1_03 but excluding the supply chain. Targets include: asset area inside UNESCO World Heritage sites of 0 ha (baseline 2015, status 0); achieving Biodiversity Net Gain on 100 percent of new projects (excluding transport) with significant residual impacts by 2030 (baseline 2025); having an internal tracking system in 100 percent of projects to better address BNG by 2026 (baseline 2020, status 0.3 percent in 2024); and being a TNFD adopter by 2026. Ecological thresholds use datasets from the World Database of Key Biodiversity Areas (Birdlife International), the World Database on Protected Areas (UNEP-WCMC, via IBAT), and the IUCN Red List of over 155,000 species; these are not entity-specific. Responsibility for local permitting sits with country managers, while IBAT risk assessment is set at corporate level with action plans decided jointly by corporate and regional levels. Targets align with the EU Biodiversity Strategy for 2030 and can be allocated to all mitigation hierarchy layers.

Reference: page 233

EDP discloses impact metrics for sites in or near protected or key biodiversity areas. In 2024, sites owned, leased or managed in or near protected areas (WDPA) that EDP is negatively affecting numbered 151, occupying 4,299 ha. Sites in or near key biodiversity areas (KBA) numbered 85, occupying 31,975 ha. Site occupation areas may include overlaps; solar distributed generation and distribution networks are excluded from certain figures. EDP has 118 assets in operation located in or near biodiversity-sensitive areas (WDPA and KBA), though many hydropower plants were built before the location was designated. The surface occupied was calculated using wind turbine rotor diameter, solar farm area, hydropower reservoirs and networks management strip area. Relevant metrics being considered include land use in protected/natural habitats (ha), assets located within or near conservation areas, flooded area in protected/natural habitats (ha), assets with biodiversity action plans, wastewater quality parameters at thermal plants, and water abstracted and consumed in water-stressed areas. Figures will change as the biodiversity risk identification process is optimised.

Reference: page 236

EDP manages circular economy and resource use through several policies covering all activities of EDP, its subsidiaries, and entities providing services on its behalf. The Environmental Policy commits to minimizing environmental impacts through efficient resource use and waste reduction, prioritizing reduce, reuse, and recycle principles and the shift from virgin resources to secondary (recycled) materials to maintain resource value across the lifecycle. The Circular Economy Strategy integrates circular principles into the business model through seven axes of action, including efficient resource use, resource valorization, product longevity, circular supplies, and new business models, and includes the Close the Loop program. The Sustainable Procurement Policy and Supplier Code of Conduct require suppliers to meet resource efficiency and circular economy standards, promote responsible sourcing, and encourage recycled and renewable materials. Policies address transitioning away from virgin resources, sustainable sourcing, and the use of renewable resources. Governance is detailed in ESRS 2 MDR-P GOV-1_09 and GOV-1_10.

Reference: page 237

EDP undertook actions across the seven axes of its Circular Economy Strategy during 2024, with annual monitoring and no defined targets due to their operational nature. Efficient resource use actions include rainwater reuse in hydroelectric and wind operations, energy storage batteries at solar farms, the CIRCUMETRIC 2.0 circularity assessment tool expanded to all geographies, and enhanced effluent treatment and water reuse at thermal plants. Product longevity actions include E-REDES reverse logistics for smart meters, where 12,000 faulty meters were checked and 70% reintroduced to the network, and meter reuse in Brazil. Digitalization includes AI-driven asset management at E-REDES and the ECO-D circular dismantling tool achieving 54% avoided environmental impact. Resource valorization includes uniform recycling with Retalhar (1.3 tons into 1,300 tool bags), solar panel donations, wind blade reuse, porcelain isolator recycling, and Close the Loop partnerships with over 20 organizations. Circular supplies include a circular procurement tool and integrating circularity into evaluation of over 10,000 suppliers.

Reference: page 239

EDP reports material resource inflows linked to construction, operation, and maintenance of its assets, comprising equipment, raw materials, and consumables. The overall total weight of products and technical and biological materials used in 2024 was 99,410 tonnes. Of this, Materials totaled 2,541 tonnes, including sodium hydroxide (73 t), hydrochloric acid (258 t), sodium hypochlorite (335 t), ammonia (257 t), limestone (1,503 t), and acquired oils (114 t). Technical Products totaled 96,869 tonnes, including modules (65,524 t), trackers (26,019 t), towers (2,733 t), inverters (1,305 t), turbines (1,038 t), and rotor and blades (250 t). Biological Products were 0 tonnes. Methodologies map main equipment purchased and calculate weight using lifecycle assessment data, with estimates based on Business Plan (BP 23-26) production projections and four years of historical data. EDP does not yet have a methodology to estimate the absolute weight or percentage of secondary reused or recycled components used in its products.

Reference: page 241

EDP describes key products and materials coming out of its production process, focusing on accelerating renewable generation and networks growth across wind, solar, and battery energy storage projects. The principal output is renewable electricity from onshore wind, hydropower, solar PV, and battery storage, which reduces greenhouse gas emissions and supports decarbonization and grid flexibility. EDP does not directly produce the equipment it uses but embeds circularity into procurement. Key materials designed along circular principles include wind turbine components built for 20-25 year lifespans with ongoing recycling of blades and composites (such as fibreglass repurposed in cement), solar PV panels with 25-30 year lifespans that are increasingly recycled to recover silicon, silver, aluminium, and glass, and substations and transformers where mineral oil is replaced with vegetable oil and metal bushings are recycled. Operational by-products like metals, cardboard, and wooden pallets are sorted, recycled, or reused. Circular business models cover battery repurposing and recycling, repowering and refurbishment of older wind farms, and community energy programs.

Reference: page 242

EDP provides qualitative disclosure of anticipated financial effects from circular economy risks and opportunities, noting it is still developing methodologies to quantify them. Material risks include reliance on critical materials such as rare earth elements for wind turbines and silicon for solar panels, where scarcity or supply chain disruption could raise capital and operational expenditures and affect short and medium term cash flows. Stricter regulations on resource extraction, waste management, and circularity may impose additional compliance costs, and extreme weather events could increase maintenance costs and insurance premiums. Market and investor preference for sustainable practices may pressure EDP to reallocate resources toward R&D, raising short-term costs. Material opportunities include lower material costs and reduced dependency on virgin resources through repowering and reuse, second-life battery applications and advanced recycling aligned with emerging energy storage markets, waste minimization supporting cost savings and profitability, and enhanced access to ESG-aligned financing such as green bonds and sustainability-linked loans, improving EDP's long-term financial position.

Reference: page 241

EDP reports group waste figures for 2024 of 63,993 tonnes of total waste materials, down from 266,138 tonnes in 2023. Of the 2024 total, hazardous waste was 6,423 tonnes and non-hazardous waste was 57,570 tonnes. Recovered waste totaled 55,829 tonnes, comprising 3,946 tonnes of recovered hazardous waste and 51,883 tonnes of recovered non-hazardous waste, of which recycled waste was 2,415 tonnes (hazardous) and 47,600 tonnes (non-hazardous). Non-recovered waste was 8,164 tonnes, including 2,477 tonnes hazardous and 5,687 tonnes non-hazardous. The recovered waste materials rate was 87% at group level (83% Iberia, 96% South America). By-products such as gypsum, fly ash, and slag were 0 tonnes in 2024, down from 27,547 tonnes in 2023. Recovered hazardous waste materials reached 61% and recovered non-hazardous waste materials 90%.

Reference: page 247

EDP maintains a comprehensive Diversity, Equity, Inclusion and Belonging (DEIB) Policy covering all workforce, including specific groups (women, people with disabilities, generations, nationalities). The framing policies are the Code of Ethics, the Human and Labour Rights Policy, the DEIB Policy and the Health and Safety at Work Policy. The Human Rights Policy applies to all EDP Group companies and employees in all geographies and commits to internationally recognized human and labour rights, including the Universal Declaration of Human Rights, the two 1966 International Covenants, and the ILO eight Fundamental Principles (including elimination of forced and child labour, Conventions 87, 98, 29, 105, 138, 182, 100, 111). Policies explicitly address trafficking, forced or compulsory labour and child labour, and prohibit discrimination on grounds such as race, sex, sexual orientation, gender identity, disability, age, religion and political opinion. An Occupational Safety and Health policy targets zero accidents, with a Corporate Safety Management System certified by Lloyd's Register and aligned to ISO 45001:2018. In 2024, 10,515 employees were covered by ISO 45001:2018 certification (81% of the group).

Reference: page 253

EDP uses several employee engagement mechanisms including surveys, focus groups and communication channels. The annual Organizational Climate Survey is the main source of comprehensive employee feedback, assessing dimensions of the employee experience and generating action plans at corporate, regional and team levels. Engagement occurs directly with the workforce and with employee representatives and trade unions through plenary meetings (all unions) and bilateral meetings (each union individually). DEIB efforts are driven through Employee Resource Groups (ERGs) and a DEIB Council. Operational responsibility for stakeholder engagement sits with the Policy, Regulation and Stakeholders function led by the Stakeholder and European Affairs Center of Excellence; workforce engagement is managed by the Head of People and Organization, with the most senior role held by the relevant member of the Executive Board of Directors. EDP gathers views of vulnerable or marginalised employees via climate studies, surveys at key journey moments (recruitment, onboarding, mobility, training) and ongoing monitoring of the Speak Up ethics channel. Effectiveness is assessed through the Climate Survey and other listening moments such as exit and ad-hoc surveys.

Reference: page 255

EDP addresses negative impacts on talent through a structured off-boarding process including clear communication, career counselling, job placement support, an alumni network and, in mutual-agreement terminations, outplacement services and health insurance for a limited period. The primary channel for raising concerns is the Speak Up Channel, available to all employees and stakeholders on internal and public websites, allowing reports of perceived violations of the Code of Ethics, internal regulations or legal requirements. Complaints can be submitted via online forms, face-to-face meetings or videoconferences, with confidentiality and an anonymous reporting option. Investigations are managed by the Ethics and Compliance Officer (ECO) and the Ethics Commission. In Brazil there is a separate third-party-managed Ethics Channel. Channels are available 24/7. The whistleblowing process registers each complaint with a non-modifiable sequential number; the channel was internally audited in 2023. Awareness and trust are assessed through a biennial ethics survey and the annual climate survey. Comprehensive policies protect whistleblowers from retaliation, ensuring confidentiality, monitoring and support measures.

Reference: page 257

EDP's talent strategy is built on three pillars: attraction (employer branding, sourcing, diverse talent pool), experience (well-being, flexibility, inclusion, hybrid work, Flex Fridays, compensation and benefits frameworks, retention and succession plans) and development (global collaboration, mobility, leadership growth, reskilling and upskilling). Actions to deliver positive impacts include extending three benefits (Birthday day-off, Magic Season day-off, Psychological Support Line launched globally in 2024), a minimum of three performance and development conversations per year, internal mobility marketplace and process digitization. EDP holds a global Family Responsible Company (EFR) certification. To mitigate risks, EDP uses the Gender Equality Plan, pay equity analysis routines and capacity building (UN Target Gender Equality program), plus a five-dimension well-being strategy (physical, emotional, financial, social, professional) with Mind Your Mind and global psychological support lines. For the green transition (S1-4_19), measures include reskilling, social commuting pass support, bicycle parking, free EV charging, no combustion vehicle purchases since 2023, and outplacement services. Effectiveness is tracked via the Perceptyx platform with two defined actions and three review dates per plan.

Reference: page 261

EDP sets targets collaboratively with input from organizational bodies and employee groups, engaging the workforce and representatives through discussions with the Executive Board of Directors, focus groups, the DEIB Council and the People and Organization community. KPIs and targets are defined by units with technical expertise (FP&A, ESG, P&O, Ethics and Compliance). DEIB and development targets for 2026 include 31% women across the organization and in leadership roles, 2% employees with disabilities, 42% of Generation Y in management positions, and 5% of employees working outside their country of origin. Training targets aspire to 70% of employees receiving ESG training and 45% participating in upskilling and reskilling programs. Occupational Health and Safety targets for 2024 include zero fatal accidents (actual 6), a frequency rate target of 1.60 (actual 1.72) and a severity rate target of 215 (actual 580), with 2030 targets of frequency rate below 1.00 and severity below 150. Workforce representatives are engaged in tracking performance through quarterly safety committee meetings and a Safety Review Panel that reports incident analysis to the EBD.

Reference: page 263

Total employee head count at end-December 2024 was 12,596 (down 3% from 13,041 in 2023). By gender: 8,872 male, 3,636 female, 0 other, 88 not reported. By contract type: 12,487 permanent and 109 temporary; 0 non-guaranteed hours. By working time: 12,591 full-time and 5 part-time. By region: Iberia 7,519, South America 3,050, North America 1,060, Rest of Europe 608, Asia Pacific 359. Largest single-country head counts: Portugal 5,466, Brazil 2,993, Spain 2,053. Employees who left the undertaking totalled 1,379, a turnover rate of 10.95% (versus 13.40% in 2023), covering voluntary departures, dismissal, retirement and death in service. Numbers are reported in head count, at end of December, from the HR Information System, including all consolidated companies. The decrease in head count is attributed to centralization of some functions in 2024 increasing efficiency. The cross-reference to the financial statements is Note 10.

Reference: page 265

At the EDP Group, 77.2% of employees were covered by collective bargaining agreements in 2024 (down from 77.8% in 2023). Around 77.5% of employees are covered overall. By country: Portugal has one agreement in force covering 99.9% of employees; Spain has two agreements (III Convenio Colectivo EDP Espana and IV Convenio Colectivo Marco Grupo Viesgo) covering 57.6%; Brazil has 12 collective labour agreements plus 10 Profit Sharing Agreements (PLR) covering 97.3%. Within the EEA, collective bargaining coverage falls in the 80-100% band for Portugal and the 40-59% band for Spain; outside the EEA, South America is in the 80-100% band. For workplace social dialogue representation (EEA only), Spain falls in the 0-19% band and Portugal in the 20-39% band. Employees have the right to create workers' committees and conduct trade union activities. Regarding European Works Council, SE or SCE Works Council agreements, there is no reference or internal knowledge of involvement (information for non-EEA employees may be omitted in the first year).

Reference: page 266

At top management level (defined as Senior Executive Directors and Executive Directors) there were 97 employees in 2024: 71 male and 26 female, equating to 73% male and 27% female (0 other, 0 not disclosed). Across the total workforce of 12,596, the gender split was 8,872 male and 3,636 female (88 not disclosed). By age band: under 30 years there were 1,628 employees (1,066 male, 527 female, 35 not disclosed), representing 12.9%; between 30 and 50 years there were 8,018 employees (5,579 male, 2,396 female, 43 not disclosed), representing 63.7%; and 50 years or older there were 2,950 employees (2,227 male, 713 female, 10 not disclosed), representing 23.4%. By gender share of the total, women under 30 were 4.2%, women aged 30 to 50 were 19.0%, and women aged 50 or over were 5.7%. EDP uses a Global Compensation Framework to define organizational segments and define top management.

Reference: page 266

EDP states that all employees are paid an adequate wage. The Global Compensation Framework considers market factors (comp ratio) to define compensation practices and ensure equity and attractiveness. EDP discloses the ratio of EDP minimum wage paid to national minimum wage in each region, and in all regions the EDP minimum wage exceeds the national minimum: Iberia 1.26, South America 1.59, North America 2.09, Asia Pacific 1.26, and Rest of Europe 1.4. The ratio is calculated using the minimum wage paid by EDP in each country against the national minimum wage obtained from official sources such as Eurostat. The wage used in the calculation is the contractual wage. Kronos employees (82) are excluded because they have an independent payroll.

Reference: page 266

EDP states all employees are covered by social protection, through public programs or company benefits, against the major life events. Against loss of income due to sickness, EDP offers extensive health insurance to all employees and, in some countries, financial support during prolonged illness, plus mental health support lines available in all EDP countries since 2024, annual flu vaccinations, gym and healthy food initiatives, physiotherapy and other regional initiatives. Against unemployment, mutual-agreement terminations include outplacement services and possibly health insurance for a limited period. Against employment injury and acquired disability, EDP provides insurance beyond compulsory insurance, plus life and personal accident insurance. Against parental leave, EDP ensures all employees can take parental leave, with a new global minimum-days parental leave benefit to be implemented in 2025, a new parents kit in Portugal, 15 consecutive days' leave for pregnant women before childbirth in some countries, and a post-parental-leave reduced-hours transition policy. Against retirement, EDP offers pension supplements or individual pension plans and a retirement preparation training program.

Reference: page 268

In 2024, persons with disabilities represented 1.58% of total employees. By gender, the breakdown as a percentage of the workforce was 0.62% female, 0.96% male, 0.00% other and 0.00% not disclosed. The calculation methodology is the number of persons with disabilities divided by the total number of employees, adapted locally to respect local legislation and the definition of disability and quota compliance in each country. For example, in Portugal the calculation requires a disability of 60% or higher, while in Brazil any degree of disability is considered as long as it is proven through a medical report or biopsychosocial assessment. Data on the number of persons with disabilities is held in the internal people management platform (About.me) and uploaded during the hiring process. EDP is committed to fostering an inclusive environment and ensuring representation of persons with disabilities throughout the employee journey, with a target of 2% representation.

Reference: page 268

In 2024, the average number of training hours per person was 27.96 overall: 20.56 hours for female employees and 30.50 hours for male employees (77.61 for not disclosed). By employee category, average training hours were: Executive Board of Directors 13.75 (female 11.00, male 15.58); Senior Management 22.35 (female 22.57, male 22.35); Supervisors 22.92 (female 29.30, male 20.72); Specialists 22.98 (female 19.18, male 25.57); and Technicians 36.96 (female 21.82, male 38.26). For participation in regular performance and career development reviews, 100% of employees participated across all categories (Executive Board of Directors, Senior Management, Supervisors, Specialists and Technicians) for both female and male employees in 2024.

Reference: page 269

In 2024 there were 0 fatalities in EDP's own workforce as a result of work-related injuries and work-related ill health, and no information regarding fatalities of other workers on EDP's sites came to EDP's knowledge. (Note: the group OHS scorecard reporting EDP employees plus service providers recorded 6 fatal accidents against a target of 0.) Recordable work-related accidents for own workforce totalled 39, with a rate of recordable work-related accidents of 1.66 (number of accidents at work with absence or fatalities per million hours worked). There was 1 case of recordable work-related ill health (versus 0 in 2023). Days lost to work-related injuries and fatalities totalled 1,465, all attributable to work-related injuries (0 days lost to fatalities from accidents, 0 to work-related ill health and 0 to fatalities from ill health). In 2024, 81% of own workforce were covered by a health and safety management system based on legal requirements or recognised standards (up from 78% in 2023). Work-related injuries include accidents at the workplace and commuting accidents with one or more days of absence and fatal accidents.

Reference: page 270

In 2024, 599 employees were entitled to take parental leave (409 male, 190 female), representing 4.8% of the total workforce (4.6% of male and 5.2% of female employees). Of those entitled, 528 took parental leave (342 male, 186 female), meaning 88.1% of entitled employees took parental leave (83.6% of entitled males and 97.9% of entitled females). Across the total workforce, 4.2% took parental leave (3.9% male, 5.1% female). EDP notes that employees entitled to parental leave are those covered by organizational policies, agreements or contracts containing parental leave entitlements, and that currently only information about parental leave within family-related leave is available. EDP supports work-life integration through its Family Responsible Company (EFR) certification by Fundacion Masfamilia, flexible working arrangements (3:2 hybrid model, Flex Fridays), birthday and Magic Season days off, and parenthood support measures including a post-parental-leave reduced-hours transition policy.

Reference: page 271

The gender pay gap, calculated as (M-F)/M x100 on average ordinary basic salary, varied by category and region in 2024. Total gender pay gap by category was: Senior Management 1.1%, Supervisors 6.4%, Specialists 11.1%, and Technicians -19.7%. By region for Iberia: Senior Management 8.6%, Supervisors 3.8%, Specialists 5.9%, Technicians -21.4%. Other regional figures include South America (Senior Management -13.1%), North America (Senior Management -25.7%) and Asia Pacific (Senior Management 10.5%); there are no senior management women in Rest of Europe. Splitting ordinary basic salary versus complementary/variable components, the gaps were: Senior Management 1.1% basic and 3.3% variable; Supervisors 6.4% and 0.4%; Specialists 11.1% and 1.4%; Technicians -19.7% and -23.6%. An adjusted methodology considers global job role, job grade and seniority. The annual total remuneration ratio (CEO pay ratio) is calculated as annual fixed remuneration of the highest-paid individual divided by averaged employee annual fixed remuneration (excluding the highest-paid individual).

Reference: page 271

In 2024, EDP recorded 66 incidents of discrimination (including harassment), up from 64 in 2023, and 355 complaints filed through channels for own workforce to raise concerns, down from 382 in 2023. These figures represent claims presented before the Ethics Commission and are entries registered in the EDP Group ethics complaint channels. There were no complaints filed to National Contact Points for OECD Multinational Enterprises. The complaints relate to issues filed directly to EDP and are consequently not subject to fines. Information is compiled by the area responsible for the whistleblowing management system based on data received through reporting channels and outcomes of the Ethics Commission's analysis and deliberation. There were no severe human rights issues or incidents connected to own workforce, and no fines, penalties or compensation for damages relating to incidents of harassment or discrimination.

Reference: page 276

EDP describes its human rights policy commitments for value chain workers. The Human and Labour Rights Policy aligns with the International Bill of Human Rights, the ILO Eight Fundamental Principles and Rights at Work, the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the OECD Due Diligence Guidance for Responsible Business Conduct. EDP commits to respect freedom of association, eliminate forced labour, abolish child labour, and eradicate discrimination. The policy framework also includes a Sustainable Procurement Policy, a Supplier Code of Conduct (under revision) requiring suppliers to comply with national and international law and uphold standards across their own supply chains, a Health and Safety Policy, a Stakeholder Engagement Policy, and the Code of Ethics. These specifically address trafficking, forced labour and child labour. Through its due diligence processes EDP states it has not identified cases of human rights violations against international standards in its supply chain.

Reference: page 279

EDP engages with value chain workers through their tier 1 suppliers and service providers rather than directly. Engagement is linked to procurement and due diligence phases: registration and qualification, requests for proposals, supplier contracting and awarding, and monitoring and evaluation. For equipment suppliers, considered most exposed to human rights risks, continuous engagement is established, starting before contracting. The EDP Purchasing Director and ESG Director hold operational responsibility, supported by specialized technical teams. EDP currently has no Global Framework Agreement but relies on its Human and Labour Rights Policy. To reach vulnerable workers, EDP uses its materiality process, which in 2024 included a direct questionnaire to critical suppliers and interviews with internal experts. The Speak Up Channel serves as an additional source of information on critical issues raised by value chain workers.

Reference: page 280

EDP describes its remediation approach for value chain workers. The framework combines passive mechanisms (suppliers required to report incidents and violations) and active mechanisms (contractual performance evaluations, on-site and remote audits, inspections, and certified management systems). When needed, action plans are developed and supported. The main channel for raising concerns is the publicly available Speak Up Channel, open to all stakeholders including value chain workers, with anonymity, confidentiality and protection against retaliation. In 2024, no claims regarding human rights were received through this channel. Supplier contracts require dissemination of the Speak Up Channel to their workers. Complaints are screened, investigated, reviewed by the Ethics Committee, and tracked. The Whistleblowing Management Regulation underwent an external audit in 2023. Retaliation protection extends for two years after a good-faith report.

Reference: page 283

EDP describes actions to prevent, mitigate and remediate negative impacts on value chain workers, grounded in its Sustainable Procurement Protocol with focus on critical suppliers. A Sustainability Matrix combines sector risks with specification characteristics. Non-negotiable clauses set minimum qualification standards, and suppliers enter negotiation only after comprehensive ESG due diligence covering integrity, compliance, financial stability, technical capability and social and environmental practices. Go/no-go criteria apply. Effectiveness is tracked through a scoring and rating system across three stages: Registration and Qualification, Requests for Proposals and Contracting, and Monitoring and Evaluation, using third-party platforms and audits. Suppliers are evaluated on five ESG priorities: decarbonization, circular economy, human and labour rights, health and safety, and biodiversity. EDP participates in groups such as Wind Power, Solar Power Europe, Eurelectric and SEIA. EDP recorded no severe human rights incidents during the reporting year.

Reference: page 287

EDP discloses targets for value chain workers. It aims to achieve zero fatal accidents for workers and suppliers by 2025. By 2026, EDP aims for 100% of suppliers to be compliant with ESG Due Diligence and 90% of purchasing volume aligned with the company's ESG goals; this engagement process began in 2022 with strategic suppliers. On human rights compliance, EDP runs a Human and Labour Rights Monitoring Programme and applies a due diligence process on legal compliance, integrity and human and labour rights to counterparties with deals above 25 thousand euros, covering 99% of purchasing volume, excluding those who do not guarantee compliance. Targets are shared and tracked with suppliers through EDPartners Talks, the Stakeholder Relationship Policy, ESG assessments via platforms such as ISNet and GOSupply, the annual SPET Tool review for critical suppliers, and capacity building programs.

Reference: page 294

EDP describes policies for affected communities. It approved its Policy of Local Stakeholder Engagement in 2023, published under Stakeholder Management Approach, supported by a detailed set of Procedures shared with all community and stakeholder teams at group level. The premise is to map and deeply engage with communities before starting a new project and throughout operation, covering all community types including indigenous communities. EDP also has a Social Investment Policy and an Environmental Policy addressing specific impacts on indigenous populations. The Human and Labour Rights Policy, published at www.edp.com, recognizes local communities as stakeholders under its Action Principles and commits to constructive engagement, avoiding adverse impacts, ensuring remediation, and non-retaliation. The policy references the UN and ILO Declarations on the Rights of Indigenous Peoples (2007) and the International Bill of Human Rights. Independent ESIA and HRA results are reported.

Reference: page 298

EDP describes dialogue with affected communities, grounded in the Local Stakeholder Engagement Policy and Procedures. Engagement follows project phases, governance runs from the Executive Board down to local teams, and roles include Project Manager, Stakeholder Manager and Business Unit Stakeholder Management departments. Engagement occurs directly or through credible proxies. In North America a Community Relations Coordinator from the local population acts as EDP's eyes and ears. In Australia, Orange County engaged with several tribes and community leaders to name a wind project, and a co-owned solar and battery park used school voting. In Spain, a public participation process was set up for coal plant shutdowns in Carreno, Ribera, Espiel and Los Barrios. For indigenous peoples, EDP applies indicators on social impact and vulnerability, reports on Impact on Indigenous People via GRI tables, and developed an interaction plan for the Sao Manoel hydroelectric project in Brazil.

Reference: page 302

EDP describes remedy channels for affected communities. Its action principles commit to remediation, non-retaliation, and access to judicial and non-judicial mechanisms, with compensation measures defined during the planning and licensing phase. The primary channel is the publicly available Speak Up Channel, available 24/7, allowing online forms, face-to-face meetings or videoconferences, with confidentiality and anonymous reporting. A general info@edpr.com email is available, and each project must identify project-specific communication channels. Examples include the Ketzin project poster, the Ben Sca Wind Farm landing page, and North American project email and phone contacts publicized through landowner dinners, open houses and community festivals. EDPR South America runs an Ouvidoria Social channel with a red-flag follow-up system. Complaints are registered with sequential numbers in a management tool, screened and investigated by the Ethics and Compliance Officer and Ethics Commission. The Brazil Ethics Channel is operated by a third party.

Reference: page 306

EDP describes actions for affected communities through more than 500 social projects worldwide and more than 30 million euros invested each year in CSR programs, organized under Fair Energy Transition across six pillars. Solar energy projects installed more than 1,700 solar panels impacting more than 6,300 people and avoiding 220 tons of CO2. Energy poverty projects intervened in more than 820 homes impacting more than 3,000 people. The A2E Fund received over 920 applications, selected 47 projects across Mozambique, Malawi, Nigeria, Kenya, Tanzania, Angola and Rwanda, investing 4.5 million euros (2018-2024), impacting more than 8 million people. EDP Solidarity Energy realised 744 projects since 2004 impacting more than 2.4 million people. Just transition upskilling and reskilling supports former coal workers. EDP donated to Vietnam after Typhoon YAGI. There were no complaints from affected communities in 2024 and no severe human rights incidents.

Reference: page 315

EDP discloses targets for affected communities. Following a 2021 social investment strategy review, EDP defined an objective to invest around 30 million euros per year in social impact projects between 2021 and 2030, focused on Fair Energy Transition, representing around 45% of investment. In 2022 EDP made a public commitment to invest more than 300 million euros (30 million per year) by 2030. The A2E Fund budget was doubled to 1 million euros annually from the 4th edition, with awards between 50 thousand and 150 thousand euros per application. Project-specific output and outcome targets (beneficiaries, installed capacity, jobs created, recovered natural area) are set with community involvement. Impact is assessed through a methodology based on the UN SDGs and the B4SI (Business for Societal Impact) framework, with a transversal methodology review underway with an external partner to be implemented by Q1 2025. References include ISO 26000, UN PRI, SDGs, GRI and the Impact Management Project.

Reference: page 321

EDP describes policies managing impacts, risks and opportunities for consumers and end-users. Key instruments include a Personal Data Protection Policy safeguarding privacy and the confidentiality of customer data and IT and OT systems; a Human and Labour Rights Policy; a Safety Policy; an Environmental Policy; the Code of Ethics setting standards for customer interactions; and a Business Continuity Policy approved in 2023. Vulnerable and priority customers (health services, security forces, firefighters, civil protection, maritime and air safety, penitentiary facilities) are protected from supply interruptions and prioritised for restoration. EDP adapts communication systems for customers with disabilities. Policies align with the International Bill of Human Rights, the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and OECD Due Diligence Guidance. There were no reported cases of non-respect of these instruments involving consumers.

Reference: page 321

EDP engages consumers and end-users mainly through the Speak Up Channel, available 24/7 on the company website, alongside the institutional website, mobile app, customer service line and stores. Customer perspectives inform decisions through yearly satisfaction surveys with B2B and B2C customers, which feed the materiality analysis. In 2024 Networks implemented CSAT (Customer Satisfaction) measurement, and Networks Spain uses the NPS (Net Promoter Score) index, monitored in the ESG Masterplan. Satisfaction surveys are run weekly for Networks by external entities and annually for commercial customers after installation. Stakeholder management sits with the Policy, Regulation and Stakeholders function led by the Stakeholder and European Affairs Center of Excellence, chaired by a member of the Executive Board of Directors who holds the most senior role. Effectiveness is assessed through satisfaction questionnaires, digital feedback and interaction data analysis.

Reference: page 323

EDP provides multiple channels for consumers and end-users to raise concerns and obtain remedy. The primary channel is the Speak Up Channel, available 24/7, allowing confidential and anonymous reporting of violations of the Code of Ethics, internal regulations or legal requirements, with whistleblower identity protected unless disclosure is required by law. Complaints can be submitted via online forms, face-to-face meetings or videoconferences. The investigation process is managed by the Ethics and Compliance Officer and the Ethics Commission. Additional channels include 24x7 stores, telephone, website and app, plus an independent Customer Ombudsperson and the Portal da Queixa in Portugal, and in Brazil an externally operated Ethics Channel managed by a third party. Complaints are registered with sequential numbers in a support tool. The Whistleblowing Management Policy prohibits retaliation. In 2024 B2C Portugal electricity customer satisfaction was 8.06 on a 0-10 scale.

Reference: page 326

EDP describes actions to prevent, mitigate and remediate negative impacts on consumers and end-users. To address energy price volatility it uses long-term Power Purchase Agreements and hedging, advanced energy procurement, fixed and indexed price plans, and 30-day notice of price revisions. On energy poverty, Portugal applies a social tariff giving a 33.8% discount on regulated electricity tariffs and 31.2% on natural gas; Brazil's social tariff offers discounts of 10%, 40% or 65% up to 220 kWh/month, with 100% discounts for qualifying indigenous and Quilombola families up to 50 kWh/month. ERSE forecasts 740,912 electricity social-tariff customers for 2025, costing EUR 124m in subsidies. On service quality, 2024 TIEPI was 50.7 minutes in Portugal and 18.75 minutes in Spain; over 99% smart-meter deployment and EUR 3 billion grid investment under the 2024-2026 plan support reliability. Data protection is reinforced through safety protocols and the Customer Ombudsman (42% favourable resolutions).

Reference: page 330

EDP sets targets to manage impacts, risks and opportunities for consumers and end-users, linked to its energy-transition commitments: dropping coal production by 2025, becoming 100% renewable by 2030, and reaching Net Zero by 2040. Defined objectives with associated metrics include reducing avoided CO2 emissions, maintaining a high customer satisfaction index above 75%, increasing the ratio of B2C customers holding electricity plus sustainable services versus electricity only, growing installed distributed generation capacity for B2B and B2C, and installing 100 thousand EV charging points by 2030. Consumers and end-users are engaged in target setting and performance tracking through transactional and relational customer satisfaction surveys, CSAT and NPS monitoring, and stakeholder communication channels. Commercial KPIs aim to grow services across efficient equipment, decentralised solar energy and electric mobility, while EDP Comercial publishes ESG indicators annually.

Reference: page 333

EDP describes its corporate culture and business conduct policies. The EDP Code of Ethics, reviewed in 2024, is foundational, addressing human rights, diversity and inclusion, stakeholder relations, environment, and corruption and bribery; it applies to all employees, agents and suppliers acting on EDP's behalf. The Integrity Policy, approved by the Executive Board of Directors and last revised in 2023, mandates measures against corruption, money laundering and terrorism financing across all group companies. A strong ESG culture features in the Strategic Plan 2023-2026, assessed through organizational climate surveys and psychosocial risk assessments. EDP operates a Whistleblowing Management System via the Speak Up Channel (and the Ethics Channel for EDP Brasil), allowing anonymous, confidential reporting in multiple languages, with protection against retaliation. Concerns undergo preliminary analysis and independent investigation managed by the Ethics and Compliance Officer and Ethics Commission. EDP aligns with the European Whistleblower Protection Directive and local transposing legislation.

Reference: page 335

EDP describes management of supplier relationships and its policy to prevent late payments, especially to SMEs. The EDP Group payment policy establishes rules, procedures and deadlines for executing payments, aligned with the group's General Purchase Conditions (GPC), with the standard payment term set at 60 days; the policy is applied globally. General rules require that the responsibility is created and approved in the ERP system, that legal documents supporting payment and cost recognition are available and registered, and that payment dates are clearly defined and approved. Exceptions are allowed for individual agreements with suppliers adjusted to contract particularities, regulatory requirements in specific sectors or geographies, and specific conditions agreed for critical supplies such as strategic services or emergency situations. These rules aim to ensure proper cash flow forecasting, harmonise payment execution within the group, and create synergies in service execution. Suppliers are also subject to the Supplier Code of Conduct.

Reference: page 336

EDP describes procedures to prevent, detect and address corruption and bribery. The Specific Compliance Program centres on the Integrity Policy (approved by the Executive Board, last reviewed in 2023, mandatory reading with acknowledgement), which reinforces a zero-tolerance stance, prohibits facilitation payments, and addresses conflicts of interest, donations and sponsorships, political contributions, money laundering and terrorism financing, third-party integrity due diligence, relations with politically exposed persons, gifts and event invitations, and international sanctions. Specific procedures cover third-party due diligence, PEP relations, offers and invitations, donations and sponsorships, conflict-of-interest management, due diligence for entering new countries, and whistleblowing. The Ethics Commission managing reports is composed of three independent members of the General and Supervisory Board, separate from executive management. Anti-corruption and anti-bribery training is transversal and mandatory for all employees; in 2024 the How I Met Integrity II program was launched. Functions-at-risk covered by training programmes reached 47.08% in 2024.

Reference: page 337

EDP reports on confirmed incidents of corruption and bribery. For 2024 there were no convictions, nor fines, for violation of anti-corruption or anti-bribery laws. The number of convictions for violation of anti-corruption and anti-bribery laws was zero, and the amount of fines was zero. The report also describes actions that may be taken to address breaches in anti-corruption and anti-bribery procedures and standards, as set out in the Whistleblowing Procedure. These response measures include changes to processes, control methods or policies; corrections or adjustments to documentation; increased awareness or training on specific subjects; termination of contractual relations; initiation of disciplinary proceedings, potentially including loss of membership of a governing body; notification of competent authorities, including European Union institutions, bodies, offices or agencies, for investigation of the offence; and initiation of legal proceedings or filing of a criminal complaint, while preserving the rights and guarantees of the parties involved.

Reference: page 338

EDP describes political influence and lobbying activities. Under its Interest Representation Policy, EDP prohibits any contribution or association of the EDP brand to political parties, candidates, political campaigns or related people or entities; consequently financial and in-kind political contributions were zero. Oversight sits with the General and Supervisory Board (headed by Antonio Lobo Xavier) and the Executive Board of Directors, with Pedro Vasconcelos supervising the Business Conduct area; the Center of Excellence for Stakeholder Management, headed by Ricardo Ferreira, coordinates Interest Representation governance. The amount of internal and external lobbying expenses was EUR 0m, while membership of lobbying associations cost EUR 1.092m. In 2024 lobbying expenditures amounted to EUR 1.092m, representing 13% of total Interest Representation expenditures. EDP is registered in the EU Transparency Register (number 676889648373-61, last updated 20/05/2024). Main lobbying topics covered energy transition, climate change and promotion of renewable energy.

Reference: page 339

EDP describes supplier payment practices. The general payment policy is aligned with the General Purchase Conditions (GPC), with the standard payment term set at 60 days. Exceptions may alter this term for individual agreements with suppliers, regulatory requirements in specific sectors or geographies, and specific conditions for critical supplies such as strategic services or emergency situations. Payments are primarily processed through the ERP system (SAP), where rules are parameterised to ensure payment in accordance with contractual conditions. Regarding the average payment term in days, EDP states the global average term has not been consolidated for all geographies due to data complexity and regional differences, and the standard 60-day policy is followed except for noted exceptions. For Portugal, the percentage of late payments was identified as 0.70%. There are no court cases related to non-payment or payment delays by EDP. Payment practices are mostly global and standardised, with some locally managed regional particularities.