EDP - Energias de Portugal SA

Reference: pages 45, 50-51 (Corporate Governance chapter items 17, 21, 29, 55 incorporated by reference).

EDP has a dual governance model: a 5-member Executive Board of Directors (EBD, 3 male/2 female) and a 16-member General and Supervisory Board (GSB, 10 male/6 female). Each material topic has a named responsible EBD member and committee (p.50): Climate/Water/Biodiversity/Circular economy -> Rui Teixeira (CFO) via the Sustainability Committee; Human capital -> Miguel Stilwell de Andrade (CEO) and Ana Paula Marques; Supply chain management -> Rui Teixeira; Business conduct -> Miguel Stilwell de Andrade and Pedro Vasconcelos via the Ethics Commission.

Board's gender diversity ratio: EBD 0.67, GSB 0.60; 56.3% of GSB members are independent (p.51). GSB oversight runs through the Corporate Governance and Sustainability Committee and the Financial Matters Committee.

Reference: page 49.

"EDP's due diligence process is a comprehensive approach to integrating sustainability into all aspects of our operations." The core elements disclosed are: embedding sustainability due diligence in governance/strategy; the double materiality assessment structuring due diligence, "relating to impacts on society and the environment, and financial materiality, relating to sustainability risks and opportunities"; engaging with affected stakeholders; identifying and assessing adverse impacts; taking actions to address them; and tracking effectiveness through metrics and targets.

Oversight of stakeholder engagement is provided by the EBD, management-level committees and the GSB supported by its specialised committees (p.48).

Reference: page 64 (climate-specific), remuneration chapter incorporated by reference.

"Multi-annual executive remuneration includes climate-related KPIs representing approximately 13% of total compensation, namely total Scope 1 and 2 GHG emissions intensity reduction (as reported under E1-4) and the increase of share of renewable energy production."

The Remuneration Committee "is specifically responsible for defining, proposing, and assessing the sustainability and climate-related key performance indicators used in determining variable remuneration." Executive variable remuneration includes both annual and long-term components incorporating explicit ESG and climate indicators.

Reference: page 49.

EDP maps its due diligence process to five core elements: "Embedding sustainability due diligence - This involves incorporating sustainability considerations into governance structures, strategic planning, and business models"; "Double materiality assessment - The double materiality assessment structures the due diligence process"; "Engaging with affected stakeholders"; "Identifying and assessing adverse impacts"; and "Taking actions to address adverse impacts" plus "Tracking effectiveness and communicating."

Unlike a page-mapped table (as used by some peers), EDP's GOV-4 statement is narrative, describing each element rather than cross-referencing to a grid of page numbers.

Reference: page 52.

"Regarding the Internal Control System for Sustainability Reporting specifically, the Group adopts a risk assessment methodology focused on information reliability, distinct from strategic materiality analysis." This characterises misstatement risk on two dimensions: "Magnitude: the potential impact of a reporting deficiency" and "Probability: the likelihood of error materialisation."

"Priority reporting risks managed through this system include data integrity and completeness, accuracy of estimates, and timely availability of information." In 2025 "the control self-certification process... explicitly encompassed sustainability controls."

Reference: pages 46-47.

"EDP's business model focuses on the generation, transmission, distribution, energy management, energy supply and energy solutions across Europe, North America, South America and the Asia-Pacific regions," with more than 26.0 GW of installed capacity. "EDP maintains limited exposure to fossil fuels, with gas and coal-related revenues representing 3.1% of total revenues. In 2025, renewables account for approximately 90% of the Group's electricity generation."

Value chain stages disclosed: upstream (raw materials, processing, transport), own operations (generation across thermal, hydro, onshore/offshore wind, solar and BESS; transmission and distribution; energy supply and solutions), and downstream (energy sales, industry/public supply, EVs, solar DG). Total revenues were EUR 15,607m in 2025 (p.47).

Reference: pages 48-49.

EDP segments stakeholders into four groups - Democracy, Market, Value chain, Social & local communities - each with defined engagement mechanisms, key topics and frequency (p.48). Engagement is guided by "four interaction commitments - comprehend, communicate, trust and collaborate."

"EDP has established a structured approach to stakeholder engagement, supported by the Stakeholder Relationship Policy, a defined methodology and a Local Stakeholder Engagement Policy and its procedures." A prior Environmental and Social Impact Assessment (ESIA) and independent due diligence process precedes development/operation/decommissioning of new sites (p.49, cross-referenced into the local communities chapter).

Reference: pages 56-58, with per-topic material IRO tables through the topical chapters (e.g. pp.63, 92, 101, 108-109, 124-125, 155, 166, 189).

"The topical standard E2 Pollution resulted as not material." All other topical standards assessed - E1, E3, E4, E5, S1, S2, S3, S4 and G1 - are material. "Following the identification of material IROs, EDP determines the specific sustainability information to be disclosed by mapping each material impact, risk and opportunity to the corresponding ESRS disclosure requirements and data points."

For reporting purposes several topics are grouped: "Biodiversity" covers E3 and E4; "Circular economy" covers E5; "Human Capital" covers S1; "Local communities" covers S3; "Resilient Services" covers S4 plus business continuity/cybersecurity; "Business Conduct" (G1) is presented together with S2 under "Supply Chain Management" (p.58).

Reference: pages 54-57.

EDP's second consecutive DMA follows a four-step process - Identification, Assessment, Consolidation & calibration, Validation and approval (p.56) - integrated with the Enterprise Risk Management (ERM) framework. "A materiality threshold of 60/40 was applied to determine which IROs are considered material for reporting purposes" (p.55).

Impact severity is scored on scale, scope and irremediability, "with likelihood considered for potential impacts... For negative impacts related to human rights, severity takes precedence over likelihood" (p.54). Financial materiality is assessed against EBITDA-based magnitude and reputational impact and likelihood (p.55). The DMA is "externally assured by PwC" and revisited annually (p.57).

Reference: page 57; Annex 2.1/2.2 "ESRS Disclosure Requirements (IRO-2)" pages 550-558.

EDP publishes a "Disclosure requirements | Page" index covering every ESRS 2 and topical-standard DR, cross-referenced against SFDR Annex I, the Benchmark Regulation and the EU Climate Law datapoints (Annex 2.2, p.550).

Basis of preparation: "EDP's Sustainability Statement is prepared in accordance with the European Sustainability Reporting Standards (ESRS)... In accordance with the applicable transitional provisions, EDP applied the available quick-fix measures to ESRS E4, S2, S3 and S4 for the reporting period" (p.45). For biodiversity specifically: "EDP applies the phase-in provision in Appendix C of ESRS 1 to omit detailed disclosures under ESRS E4 for the current reporting year" (p.101). "EDP did not omit information related to intellectual property, know-how, innovation, impending developments, or ongoing negotiations" (p.45).

Reference: pages 65-66, 75-80.

"EDP published its first Climate Transition Plan (CTP) in 2023... It builds on EDP's long-standing decarbonisation track record and is embedded in the company's overall business strategy and financial planning." Targets are "validated by SBTi in 2023, consistent with a 1.5C pathway and a Net Zero by 2040 ambition for the power sector."

Decarbonisation levers by emissions share of 2020 baseline (p.78): thermal generation (12%), electricity retail (35%), supply chain (15%), gas retail (12%), networks power losses (3%). Financing: ~EUR 7.5bn CapEx + EUR 0.8bn OpEx (2026-28) for ~5GW renewable additions; ~EUR 3bn for networks. "In 2023, the CTP was submitted to shareholders under a Say on Climate vote"; the updated CTP was submitted for Executive Board approval in 2025 (p.65).

Reference: pages 73-75.

The Environmental policy "was revised and updated in January 2026," setting mitigation commitments (increasing renewable capacity/production; low-carbon energy solutions and electrification; improving energy efficiency; reducing supply-chain emissions) and adaptation commitments (assessing asset exposure to physical risk; promoting resilience) (p.74).

The Climate transition plan policy "sets the baseline of EDP's Group decarbonisation strategy towards a Net Zero goal by 2040." The Supplier code of conduct requires suppliers to "account and either publicly disclose, and/or provide a third-party verification of their GHG emissions" and to "address greenhouse gas emissions reductions... preferably in line with the Paris Agreement's 1.5-degree scenario" (p.75). Standards referenced: TCFD, GHG Protocol, SBTi Net-Zero Standard (p.75).

Reference: pages 75-80.

"EDP's climate transition is operationalised through a defined set of decarbonisation levers and underlying actions, covering own operations and the value chain." Named actions include: near-zero coal-fired generation (achieved: Pecem fully divested, Abono 2 converted coal-to-gas Jul-2025, residual coal at Los Barrios/Soto III awaiting closure approval); >90% renewable generation by 2026-28 (12% YoY growth in wind/solar to 41 TWh); grid-loss reduction (~EUR 3bn networks CapEx); gas-retail volume reduction (-24% vs 2024, Portugal -5%, Spain -41%); and supply-chain emissions databases and RFP climate criteria.

Financing flows through operating cash flow, asset rotation and green bonds; CapEx/OpEx are integrated into the financial statements and linked to EU Taxonomy KPIs (p.66, 77).

Reference: pages 81-82.

SBTi-validated targets from a 2020 base year, 1.5C-aligned: Scope 1+2 intensity -95% by 2030 / -96% by 2040 (157 gCO2e/kWh baseline; 51 gCO2e/kWh in 2025, -67% vs 2020); Scope 3 (S1 stationary combustion + S3 Cat.3 electricity purchased/sold) intensity -80% by 2030 / -95% by 2040 (60 gCO2e/kWh in 2025); S1+S2+S3 Net Zero -90% by 2040 (10,129 ktCO2e in 2025 vs 19,493 ktCO2e base, -48%).

"Due to the divestments from coal... EDP recalculates its baseline emissions, resulting in lower than the ones used to set the decarbonisation targets... the baseline recalculation that took place in 2024 will require that the near- and long-term targets be revisited. This process is yet to be started with SBTi" (p.81).

Reference: pages 82-84.

Total energy consumption 17,829,191 MWh in 2025 (2024: 9,375,061 MWh). Fossil sources 86.8% (15,478,997 MWh: coal 1,377,730; natural gas 12,469,324; purchased fossil electricity/heat 1,583,219); renewable sources 13.1% (2,334,082 MWh); nuclear 0.1% (16,112 MWh).

Energy production: non-renewable 6,796,065 MWh, renewable 57,436,123 MWh. Energy intensity from activities in high climate impact sectors: 1,142 MWh/mEUR net revenue in 2025 (2024: 626 MWh/mEUR), against net revenue of EUR 15,607m.

Reference: pages 82-84.

2025 gross emissions: Scope 1 2,985 ktCO2e; Scope 2 (location-based) 318 ktCO2e; Scope 3 (S1+S2 total 10.1 MtCO2e vs 19.5 MtCO2e in 2020, -48%). Emissions mix in 2025: Scope 3 ~85%, Scope 1 13%, Scope 2 2% (chart p.83).

Drivers: "Both emissions from thermal generation, and from distribution power losses have increased" versus 2024 for Scope 1+2 intensity; Scope 3 fell mainly "due to a significantly lower volume of wind, solar and storage gross additions (2 GW in 2025 vs 3.8 GW in 2024)" in the supply chain category, partly offset by higher gen-retail imbalance in Brazil (p.81-82). EDP uses the financial control consolidation method under the GHG Protocol Corporate Standard and Scope 3 Standard, with no exclusions (p.82).

Reference: page 82 (E1 table); page 65|81 in the ESRS index.

"In the reporting year, EDP did not develop GHG removals and storage projects in its own operations, neither contributed to projects in its upstream and downstream value chain. Additionally, EDP did not acquire new carbon credits outside of its value chain, neither did EDP cancel the credits that remained in its portfolio." Total GHG removals and storage: 0 ktCO2e (2025 and 2024).

On future use: "EDP follows SBTi's current Net Zero commitment, where residual emissions by 2040 will need to be addressed with carbon removals. Therefore carbon credits are not used to meet EDP's GHG reduction targets." Total carbon credits planned to be cancelled by 2040: 255 tCO2e (unchanged 2025/2024).

Reference: page 66.

"EDP applies an internal carbon shadow price to assess the financial impacts of current and future carbon regulation on energy prices, sales volumes and asset valuation, and to support capital investment decisions in electricity generation. The internal carbon price is built by a range of values for different years (2030 to 2050, in 5-year intervals)."

Ranges are set "taking into account the values traded in the short-term CO2 futures market (EU ETS) and the values provided by various external sources (namely the IEA)." EDP also uses "the average price per ton of CO2 in the EU-ETS in 2025 and the volume of licenses acquired," obtainable from Note 25 (Inventories) of the financial statements.

Back-filled from ESRS 2 SBM-3/E1.SBM-3/E1.IRO-1, where this content is disclosed in the FY2025 report (pages 67-71). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risks classified chronic (temperature increase, water availability) and acute (extreme events, wildfire) (p.68). High-emission scenario used: IPCC RCP 8.5 ("the temperature rises by more than 3C... sea level rises by 0.7 metres"), alongside RCP 2.6 and RCP 4.5, aggregated into three named scenarios (BGT/AGG, SMT, and a base case) (pp.69-70). 1.5C-aligned transition scenario: IEA Net Zero Emissions by 2050 (NZE), alongside an IEA Base scenario (p.69-70).

Time horizons: short 0-1yr (2025-26), medium 2-5yr (2027-30), long 6-25yr (2031-2050) (p.70). Scope: electricity generation, networks and client solutions in Iberia, Brazil and North America (EDP Producao, E-Redes, EDP Comercial, EDP Spain, EDPR, EDP Brasil) (p.67). Scenarios were built with external providers Baringa, AFRY, Aurora, IHS and S&P, using Copernicus climate data (p.69-70).

Back-filled from ESRS 2 SBM-3/E1.SBM-3/E1.IRO-1, where this content is disclosed in the FY2025 report (pages 67, 72-73). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"According to the results of the climate risks assessment, the EDP Group demonstrates a resilient portfolio in both the RCP 2.6 + NZE (integrated into the AGG scenario) and the RCP 8.5 + Base scenario (integrated into the SMT scenario)." Resilience is attributed to "diversified geographic and technological exposure," "prioritising regulated and long-term contracted activities, disciplined capital allocation and portfolio optimisation," and capture of opportunities from energy efficiency and renewable expansion (p.73).

On capacity to adjust: "The EDP Group has already contracted a climate analytics tool and are currently updating its climate risk assessment by integrating and reflecting the tool's outputs" (p.72). No explicit statement of significant areas of uncertainty in the assessment is given, and the resilience conclusion is not disaggregated into short/medium/long-term adaptive capacity beyond the scenario-based results described above.

Reference: page 94 (ESRS index); policy content pages 90-91, 97.

Water-related policies and guidelines listed at the head of the Nature and Resource Management chapter: Environmental policy, Climate transition plan, Supplier code of conduct, Nature management approach (p.91), framed around three commitments - "Integrate Water into decision-making," "Assess and mitigate water risks," and "Promote water stewardship" (p.91).

"EDP uses the WRI Aqueduct and the Water Risk Filter tool to conduct a high-level water stress assessment, by mapping all its assets against the Baseline Water Stress (BWS; watershed level), applying the threshold BWS 40%. Wind generation and distribution assets are excluded given their low dependency on water availability" (p.97).

Reference: pages 97-99.

"Water is a critical resource for the EDP Group, particularly for hydropower generation, which represents 28% of the Group's renewable portfolio." The Los Barrios coal plant (Spain) was identified as a water-risk asset via downscaling analysis, but EDP "has requested the closure of this coal-fired plant and is awaiting regulatory feedback." Water-saving measures there include desulphurisation wastewater reuse (a "zero-discharge facility") and rainwater reuse for fire suppression (p.98).

Named actions (p.99): a 700kW Archimedes Screw hydroscrew at Pilotuerto and generating-unit modernisation at La Barca and Castelo do Bode enabling generation under minimum ecological flows (EUR 9m CapEx, "up to +5% additional generation"); the "Water Board" AI-based hydrological forecasting platform (EUR 0.5m initial, EUR 1.0m future upgrades).

Reference: page 100.

"The EDP Group has not set specific quantitative targets under ESRS E3. This risk is largely driven by natural hydrological variability and long-term changes in precipitation patterns... For this reason, no specific deadline has been set for defining quantitative targets."

In place of a numeric target, EDP tracks effectiveness qualitatively: "The Group's level of ambition is defined qualitatively and focuses on strengthening the resilience of hydropower assets... Progress is evaluated through the analysis of hydropower generation performance against historical hydrological baselines, the implementation of climate adaptation measures, and the continued diversification of the generation portfolio towards technologies with lower dependency on water resources" (p.100).

Reference: page 100.

Total water stored: 8,370 (10^6 m3) in 2025 versus 7,901 in 2024. Changes in water storage: +469 (10^6 m3) in 2025 versus +346 in 2024. All figures are obtained "from direct measurement" (100% in both years, 0% from sampling/extrapolation or best estimates).

Water metrics are scoped to hydropower reservoir storage rather than a full withdrawal/discharge/consumption balance; EDP states elsewhere that it "does not rely on marine-resource-related commodities for electricity generation; therefore, marine resources are not considered material" (p.97).

Reference: page 94 per the ESRS index (general biodiversity impacts/dependencies content pages 102-103).

EDP's biodiversity management approach rests on three pillars: the AMAT framework ("Assess, Mitigate/Manage/Act... "), the Environmental Impact Assessment (EIA) process applied "systematically... to its projects," and, since 2025, TNFD LEAP methodology as a "TNFD Adopter" (p.101-102). "EDP has recently published a dedicated document, the Nature Management Approach (NMA)... developed throughout 2025 and formally released in early 2026" (p.101).

Impacts are assessed against the IPBES drivers of nature loss: "land-use change is most significant during the construction phase," while operational-phase impacts from wind, hydro and networks include "collision risks, barrier effects, habitat alteration" (p.102).

Reference: pages 102-105.

Actions follow the mitigation hierarchy: avoidance (a Brazil transmission tower-raising project achieved "a 22% reduction in the area initially expected to require vegetation suppression," p.103); minimisation (the Bright Stalk wind farm's "Optimized Smart Curtailment" bat-protection algorithm, USA, p.104); restoration (the Muniello ash-landfill native reforestation project in Spain, phase completing December 2026, p.104); and compensation (the GREFA red kite recovery programme in Andalusia, Spain - 186 birds released since 2021, 23 in 2025, p.105).

"EDP is also advancing a strategic shift in its asset development model to structurally reduce biodiversity impacts," including repowering, floating solar and agrivoltaics (p.104).

Reference: pages 106-107.

2028 commitment: "All new projects include a biodiversity risk analysis and action plan" (100% target, baseline 2026, Targets 14/15 of the GBF). Following a 2025 review of the business plan cycle, prior formal biodiversity-net-gain and other legacy targets were converted into safeguards or pilot programmes rather than retained as auditable targets: "the conversion of location-based exclusions (e.g., UNESCO World Heritage Sites) into permanent corporate safeguards; the consolidation of Biodiversity Net Gain into a multi-year enablement programme through pilot projects to secure methodological validity and data integrity before setting an auditable target; and the retirement of targets superseded by safeguards or programmes" (methodological note, p.106). "2024 outcomes remain disclosed as historical information; no restatements have been made."

Reference: page 107.

Sites owned/leased/managed in or near protected areas that EDP is negatively affecting: 171 sites in 2025 (2024: 151), covering 34.8 kha (2024: 4.32 kha - "a refinement in the classification approach was implemented, which explains the variation"). Sites in or near key biodiversity areas: 98 sites, 33.0 kha (2024: 32.0 kha).

New construction land-use change: "70% in agricultural or anthropic land; 7% grassland; 15% broad-leaved and coniferous forest." Surface area is standardised per technology: wind (rotor diameter), photovoltaic (plant area), hydropower (reservoir area), networks (management-strip area). "Looking ahead to 2026, EDP will advance financial metrics for nature-related risk assessment."

Reference: pages 108-109.

Key policies: "Environmental policy - establishes EDP's commitment to minimising environmental impacts, making efficient use of resources and promoting waste reduction based on the principles of reduce, reuse and recycle"; a dedicated "Circular economy strategy... reinforces the need to rethink entire product and process life cycles"; and the "Supplier code of conduct" setting mandatory environmental, traceability and due-diligence requirements for suppliers (p.108).

The strategy is built on three pillars - reduction, optimisation, valorisation - implemented through "7 EDP axes of action": efficiency in resource/material use, product longevity, digitalisation, resource valorisation, new business models, circular supplies, and influence and awareness (p.108-109).

Reference: page 109.

"The actions implemented by EDP in 2025 in the field of circular economy were primarily operational, without giving rise to the definition of quantitative targets but subject to annual monitoring." Actions include reuse/recycling of components, wind-farm repowering "enabling the replacement and valorisation of components while extending asset lifetime," and the "Close the Loop" programme recycling solar panels and wind-turbine components with specialised partners (p.109-110).

Named example: planned 2026 decommissioning of the Pena Suar wind farm (Portugal), where "EDP is requiring dismantling suppliers to incorporate measures that maximize the valorization of raw materials," with contractors required to report on material flows and treatment outcomes (p.109).

Reference: page 112.

"EDP has established a voluntary strengthened circular-economy commitment under its 2026-2028 Business Plan, setting a company target of ensuring that more than 85% of total waste is recovered across the assets' life cycle," applying to construction, operation, maintenance and dismantling. Progress: 86% recovered in 2025 versus 72% in 2024 (p.90).

"Regarding resource inflows, EDP does not have a target included in the company's business plan," and EDP "acknowledges that it does not yet have a methodology capable of quantifying the absolute mass or percentage of secondary (reused or recycled) materials" - flagged as a development area for future ESRS alignment.

Reference: pages 112-113.

Overall total weight of products and technical/biological materials: 1,298,389 t (2025). Breakdown includes technical products 1,292,586 t (medium-voltage transformers 14,198 t; tracker aluminium 15,952 t and steel 1,501 t; modules 35 t) and materials 5,803 t (limestone 3,270 t, hydrochloric acid 875 t, sodium hypochlorite 804 t).

Methodology: EDP assesses nine priority "enablement equipment" categories (modules, turbines, inverters, batteries, cables, transformers, poles, racking systems, electric-mobility infrastructure), identifying "ESG Components of Interest" via life-cycle assessments, then multiplying mass shares by 2025 deployment volumes. "Values are only presented for 2025" as the methodology was improved versus 2024 (p.113).

Reference: page 112.

EDP frames its primary circularity contribution as its renewable-generation asset portfolio: "wind turbines rely on materials that are largely recyclable; solar modules allow recovery of valuable elements such as glass, silicon, aluminium and silver; and the use of vegetable-based insulating oils in transformers reduces environmental impacts and supports regenerative material cycles" (p.113).

"EDP also assesses the potential financial impacts associated with circularity-related risks and opportunities," citing material scarcity and tighter regulation as risks and repowering/battery second-life/recycling revenue as opportunities, though these are not quantified (p.113).

Reference: page 112, "Waste materials" table.

Total waste materials: 163,057 t in 2025 (2024: 63,993 t) - "the increase observed from 2024 to 2025 is due to the inclusion of construction-phase and decommissioning-phase waste generated of the asset's portfolio and the inclusion of contractors' waste from distribution networks, in Portugal." Hazardous waste: 13,158 t (2024: 6,423 t); non-hazardous: 149,899 t (2024: 57,570 t).

Recovered waste: 140,514 t (2024: 55,829 t), of which recycled 2,854 t (2024: 2,415 t) and hazardous-waste recovery 8,715 t (2024: 3,946 t). "The materials prepared to send to reuse and the total of waste sent to incineration was zero in 2025."

Reference: pages 129-131.

The DEIB Policy "is critical to managing material impacts, risks, and opportunities related to its workforce," applying to "specific groups with unique needs and challenges (e.g., women, people with disabilities, different generations and nationalities or culturalities)." Key DEIB commitments: 29% female workforce representation and 28% women in leadership by 2028; 2% representation of people with disabilities; >75% of leadership positions reflecting multi-dimensional diversity (p.130).

The Health and Safety at Work Policy, "approved by the Executive Board of Directors in June 2025," is aligned to ISO 45001:2018 and ILO Convention No.155, supporting "zero accidents, no personal injuries" (p.130). 10,148 employees were covered by ISO 45001:2018 certification in 2025 (82% of total; 2024: 81%).

Reference: pages 131-133.

The annual Employee Engagement Survey gathers feedback across 18 dimensions (75 questions total, 1-5 scale), reaching "a rate of 93% in 2025." Results are shared with the Executive Team, team managers and all employees for follow-up action (p.132).

"Approximately 79% of employees are covered by collective labour agreements." Portugal: one agreement covers 99% of employees; Spain: two agreements cover 61%; Brazil: twelve collective agreements plus ten Profit Sharing Agreements cover 99% (p.132). 72% of the internal workforce is covered by OHS representative structures and committees (p.133).

Reference: pages 131-133.

"The Speak Up channel provides a confidential and secure mechanism for employees and other stakeholders to raise concerns, or report potential misconduct, ensuring that matters are handled in a fair, consistent and structured manner" (p.131, further detailed in the Business conduct chapter).

People & Organization (P&O) Business Partners "act as a direct and trusted point of contact for employees, listening to concerns or complaints related to employment conditions and contractual compliance." OHS-specific consultation runs through elected worker representatives on safety committees and subcommittees, which "meet regularly and draw up minutes" (p.133).

Reference: page 133.

Actions span the DEIB Council and ERGs (equal treatment), the Global Compensation Framework and Skill-based Organization project reviewing the Job Family Matrix (wage disparity), and the Safety Review Panel, an "independent" body analysing incident action plans and reporting to the EBD (health and safety) (p.133, 147-148).

"Within the scope of the Safety Review Panel's activities in 2025, 3 fatal accidents (1 in South America and 2 in Iberia) and 3 accidents with serious consequences were analysed. Following a review of the action plans for these incidents, the experts recommended an additional 16 actions to the respective plans" (p.148).

Reference: page 146.

2026-2028 People & Organisation targets: Women 29%, Women in leadership 28%, Leadership Diversity Index >75%, Pay Equity 5%, Pay Transparency 57% favourability, Employees' digital upskilling plan completion 90%, plus qualitative "above high-performing companies" ambitions for empowerment and engagement (p.146).

Occupational Health & Safety KPIs: Fatal accidents target 0 (2025 actual: 3); Frequency rate target 2025 1.55 / 2030 <1.00 (2025 actual: 1.34); Total severity rate target 2025 150 / 2030 <150 (2025 actual: 71); Serious injuries and fatalities target 0 (2025 actual: 12) (p.147).

Reference: page 146.

Total headcount 11,865 in 2025 (2024: 12,596), a 5.8% decrease "primarily driven by a global reorganization initiative." By gender: male 8,396 (-5.37%), female 3,407 (-6.30%), not reported 62 (-29.55%). Countries with >=10% of employees: Portugal 5,245, Brazil 2,918, Spain 1,907 (p.146).

Turnover: 1,470 employees left in 2025 (2024: 1,379); employee turnover rate 12.4% (2024: 10.9%). "EDP's workforce includes employees (all people with a fixed-term or permanent employment contract with EDP or one of its subsidiaries)" (p.122).

Reference: page 132.

"Approximately 79% of employees are covered by collective labour agreements, with strong representation in Portugal, Spain, and Brazil." Portugal: one agreement, 99% coverage; Spain: III Convenio Colectivo EDP Espana and IV Convenio Colectivo Marco Grupo Viesgo, 61% coverage; Brazil: twelve collective agreements plus ten Profit Sharing Agreements (PLR), 99% coverage.

"Labour Relations teams and P&O Business Partners act as focal points for dialogue, ensuring compliance, social peace, and alignment of interests." 72% of the internal workforce is covered by dedicated OHS representative structures and committees (p.133).

Reference: page 133 (linked to DEIB policy metrics, page 130).

Board-level diversity is disclosed under GOV-1 (EBD gender ratio 0.67, GSB 0.60). Workforce diversity targets for 2028: 29% female representation across the workforce, 28% of leadership roles held by women, 2% representation of people with disabilities, and ">75% of leadership positions" reflecting cross-dimensional diversity (gender, nationality, generation/age) via a "Leadership Diversity Index" - "a weighted average of three Simpson Diversity Indexes" (p.130, 147).

"To calculate the ratio 'employees with disabilities' it is used: the number of persons with disabilities / total number of employees" (p.133).

Reference: page 143.

"At EDP all employees are paid adequate wage. EDP has the Global Compensation Framework that considers market factors (compa-ratio) to define its compensation practices and to ensure equity and attractiveness."

EDP discloses the ratio "EDP minimum wage/National minimum wage" by region for 2025: Iberia 1.17, South America 1.8, North America 2.15, Asia Pacific 1.56, Rest of Europe 1.38 - EDP's minimum wage exceeds the national minimum in every region. The national minimum wage benchmark is obtained "from official sources (e.g., Eurostat)." Employees under the Kronos payroll (74 people) are excluded, "as they are managed through an independent payroll process."

Reference: page 143.

"EDP provides robust support to safeguard the income and well-being of its employees at various levels," covering sickness, unemployment, employment injury/acquired disability, parental leave, and retirement. Sickness protection includes "health insurance for employees" Group-wide and, in some countries, financial support during prolonged illness; mental-health support lines have been available "in all EDP countries since 2024."

Injury/disability protection: "in addition to the protection legally granted in each country, EDP has additional support measures in the event of an accident at work, such as insurance in addition to compulsory insurance, as well as life insurance and personal accident insurance." Parental-leave protection: "EDP ensures that all employees can enjoy parental leave, encouraging male and female employees to share the initial parental leave."

Reference: pages 130, 133.

2028 DEIB commitment: "inclusion of people with disabilities: reaching 2% representation of people with disabilities, supported by workplace accommodations and tailored initiatives to promote accessibility and equal opportunities" (p.130).

Calculation methodology: "the ratio 'employees with disabilities' [uses]: the number of persons with disabilities / total number of employees" (p.133). No 2025 actual percentage figure against this target is quoted in the extracted text; the target and its accommodation-focused supporting initiatives are disclosed rather than the year's achieved rate.

Reference: page 146 (target); training-hours table page ~152.

Training-hours per employee are reported by gender and body, e.g. at EBD level: female 30.4 h, male 25.6 h in 2025 (2024: female 27.5 h, male 11.0 h) (p.152). "In 2025, the methodology used to calculate training hours for instructor-led training programs (virtual or [in-person]) [was refined]" (p.152).

The 2026-2028 digital-upskilling target requires 90% completion of the mandatory digital upskilling plan, "defined for the first time during 2025... will be monitored from 2026 onwards" via quarterly dashboards, intended to build "a future-ready workforce capable of operating effectively in an AI-enabled... ecosystem" (p.146).

Reference: page 147.

2025 KPIs versus targets: Fatal accidents (EDP employees and contractors) 3 actual vs 0 target (2025 and 2030); Frequency rate 1.34 actual vs 1.55 (2025 target) / <1.00 (2030 target); Total severity rate 71 actual vs 150 (2025 target) / <150 (2030 target); Serious injuries and fatalities 12 actual vs 0 target.

"Frequency rate measures the number of work-related accidents per one million worked hours... The Total Severity Rate measures the total number of lost workdays due to accidents per one million worked hours." 10,148 employees (82% of the workforce) are covered by ISO 45001:2018-certified management systems (p.131).

Reference: pages 130, 133, 143.

Well-being policies "explicitly address work-life balance, flexible work models, the right to disconnect, psychological safety, and open communication" (p.130). Flexible working arrangements are named among 2028 commitments ("Flexible working setups") as an actual positive impact/opportunity in the S1 material-IRO table (p.125).

Parental-leave provisions support work-life balance: "EDP is dedicated to promote a healthy work-life balance and supporting employees through various life events, including parenthood protection... encouraging male and female employees to share the initial parental leave and promoting gender equality and positive parenting" (p.143).

Reference: page 136.

Gender pay gap [(M-F)/M*100] by job segment, total across all regions, 2025: Senior Management 1.9%, Supervisors 2.8%, Specialists 10.4% (2024 comparatives also tabulated by segment and region: Iberia, South America, North America, Rest of Europe, Asia Pacific) (p.136). "There are no senior management women in the Rest of Europe" (footnote, p.136).

Pay-equity governance: a "Skill-based Organization project" in 2025 created a Global Job Title and skills inventory "for the first time," intended to make "wage disparities visible, explainable, and actionable." A 2026-2028 Pay Equity target of 5% (methodology aligned to the EU Pay Transparency Directive) was newly set for monitoring from 2026 (p.146).

Reference: page 190.

"The EDP Code of Ethics, reviewed in 2025 and available on EDP's website... is approved by the Executive Board of Directors and the General and Supervisory Board." It "addresses critical topics such as respect for human rights, diversity and inclusion, stakeholder relations, environmental responsibility, and the prevention of corruption and bribery," applying "to all employees, members of governing bodies across all Group companies, as well as agents and suppliers acting on behalf of EDP."

"In 2025, EDP maintained its recognition as one of the World's Most Ethical Companies by Ethisphere Institute, with no convictions or fines for corruption violations" (p.187). The Integrity Policy "establishes zero tolerance for corruption and prohibits facilitation payments," operationalised through an ISO 37301-certified Compliance Management System and ISO 37001-certified anti-bribery programme (p.187).

Reference: page 158.

"EDP operates an integrated, multi-stage ESG supply chain due diligence process embedded in the procurement lifecycle and aligned with international responsible business conduct standards." Supplier ESG screening "evaluates corporate-level ESG maturity of the suppliers, using a structured set of indicators" across four criteria: decarbonisation and climate action; circular economy and waste management; human and labour rights including supply chain management; biodiversity and natural resources (p.159).

Contract-level clauses "set obligations on human and labour rights, environmental performance, anti-corruption and transparency, require evidence submission throughout execution and grant EDP audit and inspection rights" (p.159). "70% Purchases with ESG risks covered by ESG Due Diligence" is the 2028 target, tracking at 66% in 2025 (p.154).

Reference: page 190.

Compliance Management System certified to ISO 37301 and anti-bribery programme certified to ISO 37001. "Decision-makers must provide annual compliance declarations. The Speak Up Channel provides accessible, confidential reporting in multiple languages, ensuring independent investigation and protection from retaliation" (p.187).

Governance: "the General and Supervisory Board (GSB), within its oversight role, monitors compliance with these policies through its specialized committees" - the Corporate Governance and Sustainability Committee for internal codes of ethics/conduct, and the Financial Matters Committee for the Compliance Management System's activities and mechanisms (p.189-190). The independent Ethics Commission "assesses matters submitted through Speak Up channels" and "analys[es] breaches of the Code of Ethics and internal regulations" (p.190).

Reference: page 194.

"In 2025, EDP reported no convictions or fines for violations of anti-corruption or anti-bribery laws, reflecting the effectiveness of its compliance framework."

Where breaches of anti-corruption/anti-bribery standards are addressed, EDP may apply: "changes to processes, control methods, or policies; corrections or adjustments to documentation; increased awareness or targeted training on specific topics; termination of contractual relationships; initiation of disciplinary proceedings, including potential removal from governing bodies; notification of competent authorities... [or] initiation of legal proceedings, filing of criminal complaints" (p.194).

Reference: pages 194-195.

"EDP prohibits any contribution or association of the EDP brand to political parties, candidates, political campaigns or candidacies... The company makes no direct political contributions." Lobbying costs 2025: internal/external lobbying expenses EUR 0m; membership fees to lobbying associations EUR 0.967m (2024: EUR 1.092m).

"In 2025, EDP identified 248 Interest Representation entities with total investment of EUR 7,743,473.06, distributed across: Business & Trade Associations (71%); Lobbying Associations (12%); and Others... (17%)" via the "Impact Map" tracking platform. EDP is registered on the EU Transparency Register (no. 676889648373-61). Advocacy topics include the EU 2040 Climate and Energy Framework and the EU Grids Package (p.195).