ENGIE SA

Reference: page 90

ENGIE describes how its corporate governance addresses sustainability, with full details in Section 4.1. The Board of Directors oversees impacts, risks and opportunities (IROs) through three committees: the Ethics, Environment and Sustainable Development Committee (EESDC), which reviewed IROs and their influence on the business model, strategy, policies and action plans; the Audit Committee, which monitors financial and sustainability performance indicators and the production of sustainability information; and the Appointments, Compensation and Governance Committee, which reviewed compensation incentives linked to ESG performance. Director expertise and skills on sustainability are presented in Section 4.1.1.7 (Individual key areas of expertise of Directors), with training covered in Sections 4.1.1.9 and 4.1.2.3. Most Executive Committee members are experts in matters related to material IROs and validate objectives and action plans before presentation to the EESDC and Board. In 2024, oversight of sustainability information production and quality control was carried out by the CSRD Steering Committee under joint Finance and ESG responsibility, and dedicated CSRD deep-dive sessions were held for Executive Committee members.

Reference: page 91

ENGIE reports that the way its governance bodies were informed about sustainability matters, and how those matters were addressed throughout 2024, is presented in Section 4.1.2.4 in the tables setting out the Main tasks and activities in 2024 for each committee. This covers the disclosure requirements under GOV-2 24, 25 and 26a, b and c. The report indicates that sustainability topics were handled through the Board's specialised committees, in particular the Ethics, Environment and Sustainable Development Committee, the Audit Committee and the Appointments, Compensation and Governance Committee, each preparing the Board's work on the basis of its specific expertise. Material IROs were formally approved by the Executive Committee on April 12, 2024 and by the Board of Directors on September 24, 2024. Main controversies are reported regularly to the Executive Committee and at each EESDC meeting ahead of Board meetings.

Reference: page 91

ENGIE integrates ESG criteria into executive incentive schemes, with the design, approval and updating of mechanisms detailed in Section 4.2. The target proportion of annual variable compensation dependent on non-financial targets is 35% for the Chief Executive Officer, the other Executive Committee members and other senior executives. For long-term incentive compensation, the target proportion dependent on non-financial objectives is 30% for the same population. Non-financial criteria include ESG criteria such as safety, GHG emissions and recruitment of female managers, while individual objectives are not necessarily non-financial. For 2024 annual variable pay, GHG criteria carried a minimum weight of 10%. Long-term incentives for 2024 vesting in 2027 included GHG emissions from energy generation and gas sales, renewable energy capacity and the share of female managers, alongside financial measures such as ROACE, EBIT and TSR. The report also sets out proposed 2025 criteria, including a GHG measure corresponding to the entire carbon footprint.

Reference: page 91

In accordance with French Act no. 2017-399 of March 27, 2017 on the duty of vigilance of parent companies and contractors, ENGIE publishes a Vigilance Plan, set out in Section 3.2. The plan brings together the measures implemented by ENGIE to identify and prevent the risks of negative impacts on people and the environment associated with its activities and those of its controlled companies, as well as the activities of its subcontractors and suppliers with whom it has an established business relationship. The report states that information on the due diligence process provided in the Sustainability Statement is detailed in the cross-reference table in Appendix 3.1.5.4. This statement on due diligence addresses the disclosure requirements under GOV-4 and links the Group's vigilance approach to the wider sustainability reporting.

Reference: page 101

Risks related to sustainability matters are integrated into the Group's overall Enterprise Risk Management Policy, which provides a specific framework for risk governance and control, as described in Section 2.1. Climate and sustainability risks and opportunities are directly related to the Group's commitment to the energy transition and are treated as an integral part of day-to-day operations. For several years the Group has reported on climate-related risks and opportunities as recommended by the Task Force on Climate-related Financial Disclosures (TCFD), and materiality assessments are fully integrated into the risk management system. For this first year of CSRD reporting, ENGIE strengthened the control environment for sustainability reporting processes, notably by deploying information systems for the HR (ESRS S1) and environmental (ESRS E1 to E5) scopes. Roles and responsibilities of contributing functions were formalised, and documentation of certain processes, including the double materiality assessment, was reinforced. A roadmap to increase coverage and maturity was validated by the Board of Directors for implementation from 2025.

Reference: page 79

ENGIE's business model supports the energy transition, with the target of being the best utility in the energy transition by 2030. The model is built around four core businesses (Production, Flexibility, centralized and local Networks, and Supplies) and draws on financial, industrial, intellectual, human and social, and natural capital. The information presented reflects the 2024 organisation of four Global Business Units (Renewables, Networks, Energy Solutions, and FlexGen & Retail) plus Nuclear and GEMS operating entities, while noting the integrated model in place since February 1, 2025. The value chain spans sourcing and purchasing upstream, the Group's own operations, and downstream customers across B2B, B2T and B2C segments. For this first publication the value chain covers rank 1 suppliers and direct customers. 2030 ambitions include 95 GW of renewable production and storage capacity. Revenues from coal and natural gas activities (excluding energy trading and financial activities) amounted to 0.6 billion euros and 16.6 billion euros respectively in 2024.

Reference: page 85

ENGIE treats stakeholder dialogue as a key element of its business conduct, drawing on a structured approach tested in the field. The Group has identified eight categories of stakeholders (customers, suppliers, employees, regions, industrial partners, financial partners, shareholders and civil society) and adapts its dialogue, means of cooperation and purposes to each. Engagement at operational level rests on a Group objective for 100% of activities to be covered by a societal plan by 2030, annual self-assessment by operating entities using a framework based on the AA1000 Stakeholder Engagement Standard, a six-stage toolbox and an in-house ENGIE University training program. At the end of 2023, the double materiality assessment gathered stakeholders' interests and views on environmental, social and governance matters. Meetings across local, regional, national and Group levels feed information to management and governance, with main controversies reported to the Executive Committee and the EESDC. The Stakeholder Committee discussed double materiality results, and the Group explained publicly why it did not agree to certain investors' request for strict adherence to a 1.5 degree pathway.

Reference: page 96

ENGIE presents a detailed description of its 77 material IROs, organised by ESRS topic (E1 to E5, S1 to S4 and G1) and matter. For each IRO the table sets out the impacted part of the value chain (upstream, own operations or downstream), the type of effect (actual or potential, on the environment or people), the level of influence, the link to strategy and activities (direct or indirect), the expected time horizon (short, medium or long term) and the activities concerned. Examples span climate change adaptation and mitigation, industrial pollution, water resources, biodiversity, resource use, working conditions, health and safety, affected communities, consumers, business ethics, sustainable procurement and cybersecurity. The report states that current financial effects of ESG risks and opportunities are taken into account in the financial statements and described in Note 1 of Section 6.2.2. To test resilience, the Group monitors achievement of sustainability objectives and will revise targets or action plans in the event of significant and lasting deviation.

Reference: page 92

Between the end of 2023 and mid-2024, ENGIE carried out its first double materiality assessment under ESRS, covering both impact materiality (impacts on people and the environment) and financial materiality (risks and opportunities affecting financial performance), with the interdependencies between the two taken into account. The work drew on the Group's expertise, an external consulting firm and the mobilisation of internal and external stakeholders. Material IROs were determined in three steps: identifying the main sustainability matters (16 ESG matters covered by topical ESRS plus an added cybersecurity, security and industrial safety matter); identifying potentially material IROs through six thematic workshops involving all GBUs and geographies; and assessing materiality by rating impacts and risks and opportunities on a 0 to 3 scale and setting a materiality threshold. External stakeholder consultations were conducted by an independent firm. The exercise concluded with 77 material IROs, approved by the Executive Committee on April 12, 2024 and the Board of Directors on September 24, 2024.

Reference: page 196

After determining its material impacts, risks and opportunities, ENGIE assessed the materiality and relevance of each disclosure requirement and then each datapoint. A cross-reference table in Section 3.1.5.2 maps each ESRS disclosure requirement to its location in the Sustainability Statement. ESRS 2 general disclosures are covered across Sections 3.1.1.1 to 3.1.1.5, with governance (GOV-1 to GOV-5) in Sections 3.1.1.3 and 3.1.1.5, strategy (SBM-1 to SBM-3) in Sections 3.1.1.2 and 3.1.1.4.2, and IRO-1 and IRO-2 in Sections 3.1.1.4 and 3.1.5. The table also covers the topical standards E1 to E5, S1 to S4 and G1, including their SBM-3 and IRO-1 disclosures and minimum disclosure requirements for policies, actions, metrics and targets. Several anticipated financial effect datapoints (such as E1-9, E2-6, E3-5, E4-6 and E5-6) use the ESRS transitional provision, while some metrics are marked not material or not available, with improvement measures planned for future publications.

Reference: page 107

ENGIE has adopted a transition plan for climate change mitigation, updated in December 2024 and approved by the Board of Directors, to align its strategy and business model with the Paris Agreement and contribute to global carbon neutrality by 2050. The plan rests on three pillars, Reduce, Absorb and Avoid, with a Net Zero 2045 target across the entire value chain (Scopes 1, 2 and 3). Reduction means cutting direct and indirect GHG emissions by at least 90% versus 2017, then neutralizing residual emissions through carbon sinks. ENGIE sold its fossil fuel exploration and production activities in 2017 and stopped selling coal that year. It plans to phase out coal in continental Europe by 2025 and globally by 2027, and to progressively reduce fossil gas by 2045. At end 2024 only 2 GW of residual coal capacity remained. Investments allocated to the action plan reached 6 billion euros in 2024. Growth CAPEX for 2025 to 2027 is planned at 21 to 24 billion euros and is 82% Taxonomy-aligned.

Reference: page 106

ENGIE's climate change mitigation and adaptation policies apply to the same consolidated scope as the financial statements, covering controlled subsidiaries, joint operations and equity-method entities, upstream and downstream of the value chain. The policies are global and cover all geographies in which ENGIE operates, with specific exclusions for trading activities and non-consolidated securities not considered material in environmental terms. The policy covers climate change mitigation, energy efficiency, renewable energy deployment and climate change adaptation. Climate governance involves the Board of Directors, which sets the climate strategy and objectives, supported by the Ethics, Environment and Sustainable Development Committee, the Investment and Technology Committee, and the Audit Committee. The Executive Committee implements the strategy and allocates annual CO2 budgets to the Global Business Units. ENGIE consulted shareholders on its climate strategy at the 2022 Annual Shareholders' Meeting, where it was approved by 97%, and will present its updated strategy for an advisory Say On Climate vote at the 2025 meeting. Executive compensation includes climate-linked criteria.

Reference: page 109

ENGIE sets out a list of mitigation actions whose scope of application is the consolidated scope plus equity-method entities. The main actions are: A1, coal phase-out, ending coal-fired generation by 2025 in continental Europe and 2027 globally in the order closure, conversion, sale, with no coal sales since 2019; A2, reduce and decarbonize gas consumption and sales while producing renewable and decarbonized gas, including biomethane (10 TWh by 2030) and hydrogen (4 GW by 2035); A3, decarbonize electricity and heat production, sales and consumption, with 95 GW of renewable electricity by 2030 (including storage), 20 TWh of renewable, low-carbon or recovered heat by 2030, and 300 TWh of renewable and low-carbon electricity sales by 2030; A4, support energy network transition, including injecting biomethane (50 TWh connected by 2030) and developing 10,000 km of electricity networks; A5, help customers decarbonize their operations. Adaptation actions A6 and A7 address strategic and local site resilience. Investments allocated to the action plan amounted to 6 billion euros in 2024.

Reference: page 110

ENGIE's overall Group target is Net Zero Carbon across Scopes 1, 2 and 3 by 2045, meaning a 90% reduction in emissions versus 2017 plus neutralization of residual emissions. Total GHG emissions (Scopes 1, 2 location-based and 3) fell from 265 Mt CO2 eq. in 2017 to 157 Mt CO2 eq. in 2024, a 41% reduction, with milestones of 120 to 140 Mt by 2030. Targets cover 100% of the Group's GHG emissions assessment and are gross targets excluding offsets and removals. The Group also targets 36 Mt CO2 eq. of avoided customer emissions in 2024 rising to 65 to 85 Mt by 2030, and 58% to 66% renewable capacity share by 2030 (43% in 2024). ENGIE's targets are certified well below 2 degrees by the SBTi since early 2023, and TPI and Moody's (rating NZ-2) assess the Group as broadly 1.5 degree aligned. Adaptation targets include 100% of existing sites assessed for physical risk by 2025 and 100% of material-risk sites with adaptation plans by 2026.

Reference: page 115

ENGIE's total energy consumption (Scope 1 and Scope 2) was 211,710,393 MWh in 2024. Total fossil fuel energy consumption was 110,964,597 MWh, representing 52% of total energy consumption, including natural gas at 91,752,323 MWh, coal and coal products at 4,678,871 MWh, crude oil and petroleum products at 2,409,059 MWh, other fossil sources at 8,608,255 MWh, and purchased fossil electricity, heat, steam and cooling at 3,516,089 MWh. Consumption from nuclear sources was 87,394,100 MWh, or 41% of total consumption. Total renewable energy consumption was 13,351,696 MWh, or 6% of total consumption. On the production side, renewable energy production was 90,697,048 MWh for Scope 1 and 14,929,885 MWh for Scope 3, while non-renewable production was 100,558,973 MWh for Scope 1 and 73,014,628 MWh for Scope 3. Energy intensity on a net revenue basis was 2,868 MWh per million euros, against revenues of 73,812 million euros.

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In 2024 ENGIE's gross GHG emissions were: Scope 1 of 21.9 Mt CO2 eq. (21,947,533 t), down from 80.5 Mt in 2017; Scope 2 location-based of 0.50 Mt (502,325 t) and Scope 2 market-based of 0.81 Mt (808,754 t); and significant Scope 3 of 134.7 Mt (134,715,937 t), down from 183.6 Mt in 2017. Total location-based GHG emissions were 157.2 Mt CO2 eq. (157,165,795 t) in 2024 versus 265.1 Mt in 2017, and total market-based emissions were 157.5 Mt (157,472,224 t). Key Scope 3 categories include 3.3 fuel and energy-related activities of 48.9 Mt, 3.11 use of sold products (fuel sales) of 52.6 Mt, and 3.15 investments in equity-method entities of 28.1 Mt. The percentage of Scope 1 emissions from regulated emission trading schemes was 73% in 2024. Carbon intensity of energy production (Scope 1) was 106.8 kg CO2 eq. per MWh eq. The Group also emitted 3.4 Mt of biogenic CO2. GHG intensity on a revenue basis was 2,129 t CO2 eq. per million euros (location-based).

Reference: page 114

ENGIE committed in May 2021 to being Net Zero across its three scopes by 2045, first by reducing GHG emissions by at least 90% and then by growing carbon sinks within and outside its value chain to neutralize remaining emissions. All emission reduction targets are expressed in gross terms, with induced emissions kept separate from removals, and offsets will not be used to meet reduction targets. In the short term to 2030 the Group will mainly use carbon credits from nature-based sequestration such as afforestation, reforestation, regenerative agriculture and mangroves, using recognized standards (Gold Standard, Verra VCS). In the longer term to 2045 it will rely primarily on negative emission technologies such as bioenergy-based carbon capture and storage. In 2024 the Group generated no carbon sequestration and storage in its operations or value chain (0 kt CO2), but cancelled 1,721 t CO2 of carbon credits for its own account, of which 2.9% were carbon removal credits, 97.1% avoided emissions credits, 100% recognized against quality standards and 0% issued in Europe. Significant removal volumes are expected from 2030.

Reference: page 114

ENGIE operates two carbon pricing mechanisms. First, allowance prices, particularly the EU ETS in Europe, are factored into the modeling of the European energy system to 2050 and directly affect the energy price forecasts that underpin the Group's strategic, budgetary and investment decisions, including impairment testing of assets. The spot carbon price assumption used at December 31, 2024 was 73 euros per tonne. For EU ETS coverage in 2024, the coverage rate of gross Scope 1 GHG emissions was 73%, while coverage of gross Scope 2 and Scope 3 emissions was 0%. Second, a CO2 price is integrated into the financial elements of investment decisions through the Group's CO2 budget management tool, based on changes in carbon prices under internal market decarbonization scenarios. The Group also plans to add an internal carbon contribution to finance future carbon removal in order to reach its Net Zero targets. This contribution will begin from 2030, will involve all consolidated entities in proportion to their Scope 1, 2 and 3 emissions, and will evolve with the amount of carbon to be sequestered and the cost of sequestration.

Reference: page 122

The Group has adopted an anti-pollution policy to reduce and control the risks of air, water and soil pollution from its activities and value chain, aiming to protect people and ecosystems. The policy covers pollution prevention, the control process, and incident and emergency management. To minimise risk, ENGIE applies safety protocols, preventive maintenance and best available techniques, reducing unavoidable emissions through fume filtration, pre-discharge water treatment and ground sealing. Upstream value chain pollution is assessed through life cycle assessments. Detailed emergency response procedures, specialised teams and management plans are in place, with regular training. The policy applies to all Group activities and the upstream chain, covers consolidated financial reporting entities, and is implemented by the Group ESG Department. ENGIE is a founding member of CITEPA's Cross-Border Pollution Forum and complies with the EU Industrial Emissions Directive. The policy is publicly available on the ENGIE website.

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Key actions include inclusion of air, water and soil pollution matters in project development (action taken in 2024, all Group industrial entities, permanent), improvements in the diagnosis and inventory of air, water and soil pollutants linked to industrial processes (forthcoming, target 2026), and remediation of former gas production plants (action taken in 2024, target 2026). The Group adjusts CAPEX or OPEX allocation by project or site type. Main costs include external engineering, installation of filtration systems for air pollutants, pollutant monitoring and measurement, pre-discharge water treatment, soil remediation and damage repair after accidental pollution. In 2024, in France, the Group carried out soil remediation at former gas production plants. For example, at the Coudekerque site, remediation was scheduled from September 2023 to February 2024, where the main pollutants were PAHs, total hydrocarbons, benzene and total cyanides.

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Since 2022, ENGIE has set voluntary targets for reducing atmospheric pollutant emissions by 2030, which have now been achieved or are close to being achieved. Against a 2017 base year, the targets are: nitrogen oxide (NOx) reduction of 75 percent (from 92,209t to 23,223t in 2024, a 75 percent reduction); sulfur dioxide (SO2) reduction of 98 percent (from 159,623t to 2,859t, a 98 percent reduction); and total particulate matter reduction of 60 percent (from 7,353t to 2,636t, a 64 percent reduction). Targets are calculated based on the CO2 medium-term plan pathway and concern thermal power production and gas activities, set with the GBU on the basis of peer exchanges and international standards (TNFD, SBTN). Reviews are underway to set targets for water pollutants and soil pollution.

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Air emissions for 2024 (total / according to E-PRTR thresholds): NOx 23,223t / 18,301t; SO2 2,859t / 1,868t; total particulate matter 2,636t / 1,507t; mercury 107kg / 31kg. Emission intensity ratios for energy production were 0.121 t/GWh (NOx), 0.015 t/GWh (SO2), 0.014 t/GWh (PM) and 0.0006 kg/GWh (mercury). The Group uses continuous emission monitoring (CEM) and Predictive Emissions Monitoring (PEM) systems for combustion plants. For water pollutants, physical-chemical parameters in discharged water are monitored by continuous measurement or spot sampling; discharge water temperature is monitored continuously and heavy metal concentrations on a spot-sampling basis. For soil, with the exception of former gasworks the quantities of pollutants are negligible and chiefly from accidental pollution; in 2024 there was no accidental pollution leading to significant soil pollutant quantities.

Reference: page 124

The Group's water management policy covers assessment of water-related risks and opportunities from the project phase, local actions with stakeholders following the avoid-reduce-compensate sequence, and assessment of the water footprint across the entire value chain. It addresses freshwater resource use, water treatment, pollution prevention and reduction, water stress and regulations, with more stringent requirements in water-stressed areas, and covers the upstream value chain. The policy applies to all Group activities and consolidated reporting entities, and is implemented by the Group ESG Department. ENGIE is a founding member of the CEO Water Mandate, a CDP Water Security respondent, and committed to BAFWAC and the OECD Water Governance Initiative. Water-related risks are assessed annually using the WRI Aqueduct tool. In 2024, 152 sites were in extreme water stress areas and 94 in high water stress areas; seven extreme-stress sites have significant freshwater requirements (over 100,000 m3/year) and have implemented action plans.

Reference: page 125

Key actions include identifying and carrying out actions to reduce freshwater consumption at existing sites (action taken in 2024, target 2030, aiming for a freshwater consumption to energy production ratio of 0.1 m3/MWh, 70 percent down on 2019); analysing water management risks and opportunities for each new project under the avoid-reduce-compensate approach (ongoing); and running action plans at water-stressed sites to reduce pressure at watershed level (forthcoming, target 2028). The Group adjusts CAPEX or OPEX by project or site type. Main costs include external consultancy, installation of rainwater recovery systems, leak detection and repair, and contribution to collective catchment-area actions. ENGIE works with local stakeholders on collective watershed actions; for example, in Mexico it developed a project to preserve fresh water in an extreme water stress watershed. In Chile, a thermal plant in an extreme water stress area resold 30,921,000 m3 of desalinated water to a mine in 2024.

Reference: page 125

ENGIE has set voluntary 2030 targets to reduce pressure on freshwater resources, against a 2019 base year. Reduced freshwater consumption for energy production: 2025 target 0.150 m3/MWh and 2030 target 0.100 m3/MWh, from a baseline of 0.310 m3/MWh, with 2024 reporting at 0.239 m3/MWh (a 23 percent reduction on base year). Reduced freshwater withdrawals for energy production: 2025 target 9.3 m3/MWh and 2030 target 3.6 m3/MWh, from a baseline of 12.95 m3/MWh, with 2024 reporting at 9.44 m3/MWh (a 27 percent reduction). Targets are set with the GBU based on peer exchanges, international standards (TNFD, SBTN) and rating agency questions; the freshwater consumption target is part of the act4nature international commitments. In 2024 the thermal/electrical conversion ratio was brought to 1, updating the 2019 base year values from 0.332 to 0.310 (consumption) and 13.88 to 12.95 (withdrawals).

Reference: page 125

Water performance results for 2024: total water consumption 59,832,379 m3; water consumption in water-stressed areas 33,388,535 m3; water recycled and reused 9,407,124 m3; water intensity to energy production ratio 0.239 m3/MWh; water intensity to revenues ratio 810.6 m3 per million euros; water stored 11,548 Mm3; and variation in stored water quantity 2,471 Mm3. Water volumes are measured on-site using volumetric meters or, failing that, estimated from technical data such as water flow rate; the share of estimated volumes is not available at consolidated level. Water volumes in high and extreme water-stress zones are tracked, and per WRI guidance, volumes for sites in arid zones with low water use are assimilated to those in zones of extreme water stress. Stored water corresponds to the volume in reservoirs at dams and pumped storage sites.

Reference: page 128

Under the Group's commitments, biodiversity and ecosystems are included as factors in its strategic planning and business model. ENGIE is strengthening resilience across all its activities, especially regarding its main dependency, the availability of freshwater, as set out in the Water section. The biodiversity and ecosystem dependencies of the Group and its value chain were analysed using the LEAP method's Evaluate process and the Global Biodiversity Score footprint tool, assessed sector by sector across gas storage and transport, gas distribution and marketing, thermal power production by fuel type, wind, solar, biomass, hydroelectric, geothermal and water services (desalination). Dependencies identified relate to ecosystem services including water availability, climate regulation, raw materials of natural origin and soil quality. The Group used WBCSD findings on energy sector dependencies. Resilience analysis work will be fine-tuned and extended to other dependencies in coming years.

Reference: page 128

The biodiversity policy has four focuses. Focus 1, land footprint and ecological continuities: applying ecological site management (banning phytosanitary products, nature-respecting green space management), locating protected and sensitive zones near industrial sites using employee tools, and applying the avoid-reduce-compensate approach worldwide. Focus 2, biodiversity and climate change: a climate policy to reduce greenhouse gas emissions and identification of Nature-Based Solutions in line with the IUCN standard. Focus 3, value chain: a sustainable procurement policy embedding biodiversity factors and engaging suppliers. Focus 4, awareness-raising and knowledge-sharing through e-learning, the biodiversity fresk, and partnerships with the French Committee of the IUCN and the UNEP World Conservation Monitoring Center. The policy applies to all Group activities and the upstream chain, covers consolidated reporting entities, and is implemented by the Group ESG Department. ENGIE contributes to the Kunming Montreal global framework and is committed to the act4nature approach.

Reference: page 129

Key actions, all taken in 2024, include developing action plans for identified priority material sites (target 2028); applying the avoid-reduce-compensate sequence to development projects submitted to Group and GBU Investment Committees (2025); implementing ecological management for all industrial activities, in particular without chemical phytosanitary products (2030); and implementing Nature-Based Solutions meeting the IUCN standard (2025). The Group adjusts CAPEX or OPEX by project or site type, with main costs related to conservation, restoration and sustainable management of biodiversity and ecosystems, drawing on ecology and landscape consultancies, research laboratories and universities. Compensation measures are determined in the project-stage impact study and are not consolidated Group-wide. Nature-Based Solutions validated by IUCN in 2024 include the Regenera+ regenerative agriculture project at the Passo Fundo hydropower plant in Brazil, reforestation of 14 hectares of mangroves in Bangladesh, and restoration of the Vieux Rhône hydrosystem at Péage-de-Roussillon in France.

Reference: page 130

Targets, all against a 2020 base year and reported as compliant in 2024: develop action plans for identified priority material sites, 100 percent by 2028 (80 percent intermediate by 2025), at 84.5 percent in 2024; apply the avoid-reduce-compensate sequence to development projects, 100 percent of projects by 2025, at 91 percent in 2024; implement ecological management for all industrial activities without chemical phytosanitary products, 100 percent by 2030 (50 percent intermediate by 2025), at 63 percent in 2024; and implement Nature-Based Solutions, 10 by 2025, with 1 in 2023 and 3 in 2024. The targets are not based on ecological thresholds but meet the objectives of the Global Framework on Biological Diversity and are aligned with the Kunming Montreal global framework, the EU strategy and national frameworks, as part of the Group's Nature Positive approach. Targets apply to all countries where the Group operates.

Reference: page 130

In 2024, the 58 priority material sites were located in or near biodiversity-sensitive areas, covering a total surface area of 986.5 hectares. The identification of material impacts related to land-use change, or impacts on the extent and condition of ecosystems, is not yet available. The Group is not yet in possession of metrics on the impact drivers of land-use change, freshwater-use change or sea-use change. Priority material sites are determined as those with four or more very high criticality levels across five criteria: proximity to protected areas (IUCN, KBA, MAB, WDPA including Ramsar and UNESCO areas), the IUCN Red List of Threatened Species, ecosystem integrity levels (Globio model), water stress zones, and sector-based classification of impacts and dependencies. The list of material priority sites and sensitive impacted areas is provided in Section 3.1.5.5; ecological status is not consolidated at Group level.

Reference: page 132

ENGIE's Circular Economy and Natural Resources Policy applies to all Group activities and the upstream chain, covering consolidated financial reporting entities, and is implemented by the Group's ESG Department. The policy is public and available on the ENGIE website. It is built around levers including eco-design, preserve, optimize, reuse, repair, recycle, innovate and empower. Under the climate transition plan, the development of renewable electricity and biomethane reduces demand for fossil fuels and the extraction of natural resources (coal, natural gas), while eco-design and recycling of materials such as solar panels and wind turbines reduce pressure on virgin resource extraction. In the first half of 2024 the Renewables GBU adopted a sustainability strategy addressing three circular economy aspects: transparency (assessing risks in the manufacture of wind turbines and photovoltaic modules), waste reduction, and partnerships. On sustainable procurement, ENGIE applies ESG criteria to all of its purchases, including energy purchases.

Reference: page 133

Key actions taken in 2024 include continuing to implement the Material Risks Passport (with four new technologies in 2025), promoting the circular economy and natural resources dimension in life-cycle assessments (LCAs), and developing energy recovery from industrial and tertiary processes using local resources. With the exception of energy recovery actions requiring CAPEX (shared with climate change action plans), the other actions require OPEX considered as potentially having no significant financial impact. For many years ENGIE has carried out standardized LCA studies covering the majority of products and services (photovoltaic panels, wind turbines, batteries, biomethane, heating networks), conducted on an ongoing basis by a dedicated Group team. The Material Risks Passport identifies risks in the consumption of natural resources in energy production and storage technologies, covering availability/scarcity, criticality, substitutability, geopolitical and societal risks and traceability of materials, and meets the requirements of Article 24 of the European Regulation of April 11, 2024 on critical raw materials. Four case studies have been carried out on photovoltaics, wind power, batteries and electrolyzers. ENGIE also participates in the ZEBRA consortium developing recyclable wind turbine blades.

Reference: page 134

ENGIE does not currently have Group-wide targets for minimizing the use of natural resources or increasing the use of recycled resources; identification work will be carried out with entities over the coming years, and the Material Risks Passport will be applied to identify four new technologies by 2025. Biomethane targets include developing biomethane production capacity in Europe of 10 TWh per year by 2030 (1.2 TWh reported in 2024, 12% of target) and expanding biomethane injection capacity in France of 50 TWh per year by 2030 (13.0 TWh reported in 2024, 26%). For dismantling, ENGIE does not have specific targets on dismantling waste management except for the Renewables GBU, which targets at least 90% recycling of materials from dismantled photovoltaic panels (recovering valuable materials such as silicon, glass and metals) and at least 90% of materials from wind turbine blades to be recycled or reused. A zero landfill principle applies for all dismantled renewable energy assets.

Reference: page 134

With regard to the Group's business model and the IROs identified, the main incoming raw materials are natural gas, biomass, water and metals used in particular in renewable energy technologies. Studies have identified a list of typical materials characteristic of renewable energy installations, though the Group does not yet have a precise and exhaustive view of every material used. The main materials used in wind power plants include steel, copper, aluminum, zinc, lead, polymers, fiberglass, concrete and rare earths. Photovoltaic panels typically include aluminum, concrete, copper, silicon, zinc, rare earths, plastics/polymers and glass. Batteries are made from materials including lithium, graphite, iron, cobalt, aluminum and plastics/polymers. Electrolyzers contain nickel, copper, steel, zirconium and plastics/polymers. Given the nature of the Group's current internal accounting nomenclature and purchasing data, the Group cannot report on the weights of materials purchased or the percentage of recycled materials they contain; work on this aspect will be carried out over the next few years.

Reference: page 135

The repair and reuse of assets is a key aspect of the Group's policy, with actions by the FlexGen & Retail GBU (such as converting power plants from coal to gas) and the Networks GBU (reuse of natural gas networks with biomethane). Dismantling of industrial assets chiefly concerns the FlexGen & Retail (coal and gas-fired power plants), Renewables (wind and solar power) GBU, and Electrabel in the nuclear sector, with operations managed locally. There was no significant non-nuclear dismantling activity in 2024. For Belgian nuclear plants (Doel 3 and Tihange 2 reactors), dismantling is scheduled to begin in 2026 with units dismantled by 2037; some 98% of waste generated by dismantling a nuclear power plant is conventional waste (concrete and metals) that will be recycled and recovered as far as possible. Regarding outflow KPIs, the Group's environmental reporting does not specify waste types, quantities, destinations or the grading of waste treatment methods for dismantling projects; work will be carried out over the coming years.

Reference: page 135

Waste metrics are published with reasonable assurance for continuity with previous Group publications and to meet external stakeholder expectations, though they are not material under the double materiality assessment. For 2024, the total quantity of non-hazardous waste and by-products discharged (including sludge) was 1,024,545 tonnes, including fly ash and refioms (63,231 t), ash and bottom ash (170,959 t), desulfurization by-products (17,409 t), sludge (7,286 t) and driftwood (10,792 t). The total quantity of non-hazardous waste and by-products recovered (including sludge) was 870,972 tonnes. The total quantity of hazardous waste and by-products discharged (including sludge and excluding radioactive waste) was 31,695 tonnes, and the total quantity of hazardous waste and by-products recovered was 7,021 tonnes. The hazardous waste figures were verified by the Statutory Auditors with reasonable assurance for 2024.

Reference: page 150

ENGIE reports several workforce policies, all with Group-wide scope and accountability sitting with the Group Human Resources Department. The Human Rights Vigilance Policy (described in Section 3.1.3.1) explicitly addresses all forms of slavery, human trafficking, forced or compulsory labor and child labor, and prohibits all discrimination and harassment. The One ENGIE Compensation Policy covers fixed and variable pay, social protection and pension plans, and aims to deliver pay that is fair, competitive (benchmarked via Willis Towers Watson, Mercer and Korn Ferry) and performance-based, while avoiding discriminatory pay gaps. The Global Diversity, Equity and Inclusion Policy, validated in September 2022, is built on five pillars: gender equality, origins, LGBTQ+, abilities (disability) and generations. The Training and Development Policy (adopted 2017) and the complementary Talent Development Policy aim to train all employees annually by 2030. The Health and Safety Policy, revised in 2022 alongside the Global Framework Agreement, rests on two prevention streams, No Life at Risk and No Mind at Risk. Policies are made available to all employees via the Group intranet and website.

Reference: page 147

ENGIE describes a culture of social dialogue operating at local, country, European and global levels. At local level, dialogue takes place within entities with trade unions and employee representatives. At country level, two meetings are held each year (in France within the French Group Works Council). At European level, the European Works Council (EWC) meets at least twice a year plus working groups. At global level, the Global Forum, chaired by the CEO, meets annually with international federations. In January 2022 the Group, international federations and French trade unions signed the Global Agreement on fundamental rights and social responsibility, applying worldwide regardless of contract type. Effectiveness is evaluated through quality of exchanges, number of agreements signed, and labor dispute data. Employee views are gathered through the ENGIE&Me survey, run by an external provider for confidentiality. The 2024 survey had an 82% participation rate, showing 88% support for the decarbonization strategy, 85% recommending ENGIE as an employer and 83% job satisfaction. People Managers with teams over 10 respondents receive team-level analysis and must build action plans.

Reference: page 144

All employees are made aware of the ENGIE Whistleblowing System through the Ethics Code of Conduct, intranet, website, training, posters and similar channels. Any Group employee can report acts or behavior that may undermine the integrity or rights of individuals via this system, which is the Group's managerial tool for reporting ethics incidents. Employees can also raise concerns with employee representatives, and specialized helplines are available such as Allodiscrim in France. Under its Human Rights Vigilance Policy, the Group makes every effort to receive and handle reports of potential negative impacts on human rights while protecting the rights of those concerned, and has put in place reporting channels for individuals to communicate concerns and request remediation. The way the Group tracks and monitors issues raised and addressed, and ensures the effectiveness of these channels, is described in Section 3.1.4.1.5 on whistleblowing and reporting of ethics incidents. The Group also requires entities to establish dialogue and grievance mechanisms for potentially affected stakeholders.

Reference: page 148

ENGIE sets out action plans across working conditions, DEI, talent and skills, and health and safety. In 2024 its actions enabled restructuring operations to be carried out constructively, with collective agreements defining support measures; restructuring linked to the just transition concerned about 5% of the Group's employees, mainly in Saudi Arabia, the UAE, Qatar and Chile. In Europe the Group's European Labour Relations Agreement and the EWC operating agreement provide a social diagnosis process before any restructuring with an employment impact, including dialogue with trade unions or the EWC secretariat and psychosocial risk prevention and change management programs. Support measures may include mobility bonuses, pay-gap compensation, relocation expenses and spouse job-search assistance. Planned actions include revising the Global Agreement (H2 2025) and mapping country agreements (2026). Other actions cover performance share awards (about 5,200 employees benefited), pension plan mapping, profit-sharing, the LINK employee share ownership plan and the ENGIE Care social protection program targeting 100% coverage across four pillars by end-2024.

Reference: page 149

ENGIE reports targets across several workforce areas. On gender diversity, the Group targets 40% to 60% of management positions held by women by 2030; the rate in 2024 was 32%. It also targets 10% apprentices among permanent employees (excluding regulated entities GRDF and GRTGaz). On pay equity, the target is a maximum gender pay gap of 2% at Group level over 2022-2030 (base year 2022); the 2024 adjusted gap was 1.85% on a scope of close to 80% of employees, in line with the objective. On training, the target is 100% of employees trained annually by 2030, with intermediate milestones (90% in 2025 rising to 98% in 2029); 94.6% were trained in 2024. On health and safety, 2030 targets include a Lost Time Injury Rate of 1.5, zero fatal accidents and a fatality rate of zero. On social protection, the 2025 ENGIE Care objective is to implement the fifth pillar on employee well-being. Targets related to social dialogue concern the frequency and number of meetings with employees and representatives.

Reference: page 145

At December 31, 2024 ENGIE employed 97,967 people in more than 30 countries, with a strong presence in Europe (77% of employees) and particularly France (47%, or 46,509 employees). Other notable countries were Belgium (8,078), Germany (5,887), Romania (4,546), the United States (3,228) and Italy (3,162). By gender, the Group had 71,709 male employees (73%) and 26,220 female employees (27%), plus 4 recorded as other and 34 unspecified. By contract type, 92% (90,114) were on permanent contracts, 8% (7,806) on fixed-term contracts and 47 on non-guaranteed hours contracts. In 2024, 8,125 employees left the Group, giving a turnover rate of 8.35%; the largest reasons for leaving were resignations (4,417), retirement and early retirement (1,167) and dismissals (1,011). Corresponding personnel costs were 8,623 million euros in 2024. Data are consolidated under headcount, and the reporting scope follows the Group's financial scope of consolidation. The headcount, female, permanent and temporary employee figures were verified by the Statutory Auditors with reasonable assurance.

Reference: page 161

For non-employee workers, ENGIE applies a transitional provision for its 2024 reporting, publishing only data relating to temporary workers within the health and safety section. The Group states that in terms of health and safety at work it aims to provide the same level of protection and risk prevention to all individuals working for the Group regardless of status, whether employees, temporary workers or subcontractors, and that its Health and Safety Policy, rules and processes apply to these different groups. The Group's mandatory e-learning courses (Health and Safety, Ethics and Cybersecurity) delivered through the Learning Management System cover both employees and non-employees. Health and safety metrics reported by ENGIE combine employees and temporary workers and, in several cases, also (sub)contractors. The report does not disclose a full breakdown of non-employee worker characteristics such as headcount by type, given the transitional approach taken for 2024, but commits to reporting health and safety data covering temporary staff alongside employees.

Reference: page 149

The Global Framework Agreement on Fundamental Rights and Social Responsibility applies to all Group employees without exception, and the European Labour Relations Agreement applies to all Group employees based in Europe. The Group reports that it is implementing a process to determine the percentage of employees covered by collective agreements by region outside the European Economic Area, and that local agreements generally establish joint monitoring committees of employee and management representatives. The European Works Council, comprising at least one employee representative for each European country in which the Group operates, is responsible for 100% of the Group's entities and employees in Europe. In addition to institutional social dialogue within each company, ENGIE has set up a social dialogue body for each country that meets twice a year on the initiative of the Country Manager. The EWC operating agreement, revised in July 2023, already incorporates provisions of the draft European directive on consultation, including working groups, country discovery missions and delegation time. The report does not state a single Group-wide collective bargaining coverage percentage.

Reference: page 155

ENGIE reports diversity metrics on its top management and on the age distribution of its workforce. Top Management, defined as the highest level of decision-making and responsibility and evaluated using the Korn Ferry Hay methodology, comprises 294 employees, of whom 92 are women and 202 are men (about 31% women). The percentage of female managers across the Group was 32% in 2024 (31.2% in 2023), against a 2030 target of a 40:60 gender balance. The distribution of employees by age group shows 6,130 employees aged 0-24, 9,669 aged 25-29, 12,845 aged 30-34, 29,704 aged 35-44, 24,225 aged 45-54 and 15,393 aged over 54. Within these groups men consistently outnumber women, for example 21,650 men versus 8,042 women in the 35-44 bracket. Across the total workforce of 97,967, women represent 27% and men 73%. The Group has chosen not to set targets or metrics related to the origin, gender identity or sexual orientation of its employees, citing legal constraints on identifying certain populations.

Reference: page 152

ENGIE states that all its employees receive an adequate wage, in line with applicable benchmarks. The Group complies with minimum social standards on pay in all countries where it operates and ensures that it offers competitive pay to all salaried employees, in particular through compensation surveys conducted with specialized firms such as Willis Towers Watson, Mercer and Korn Ferry. Under the One ENGIE Compensation Policy, pay is designed to be fair, based on clear and documented rules and objective, measurable criteria, ensuring that pay gaps linked to discriminatory factors are avoided and that applicable social minimums are respected. The Group reports that at this stage it has not set any specific targets on adequate wages, but states it will continue to reflect on the issue of the adequate wage in line with best practices and improvement initiatives where applicable, complementing the ENGIE Care objectives already implemented for all employees and their families. The report does not disclose a quantified percentage of employees paid at or above an adequate wage benchmark.

Reference: page 167

Through the ENGIE Care program, launched in 2020 and integrated into the Global Framework Agreement in 2022, ENGIE established a minimum level of social protection for all employees worldwide regardless of status, employer or country. The program guarantees health coverage reimbursing at least 75% of hospitalization costs, a death benefit equal to at least 12 months' salary, a capital payment of at least 12 months' salary for total and permanent disability, full pay for a minimum of 14 weeks' maternity leave and a minimum of four weeks' paternity leave. By the end of 2024 the Group reports 100% of employees covered across the first four pillars. Coverage rates at September 1, 2024 were: fully paid maternity leave 99%, fully paid paternity leave 98%, death benefits 98%, reimbursement of 75% of hospitalization costs 100% and disability allowances 98%, with all reaching 100% by year-end. These represent improvements on 2023 (for example disability allowances rose from 87% in 2023). The 2025 objective is to implement the fifth pillar on employee well-being.

Reference: page 153

Persons with disabilities are addressed under the abilities pillar of ENGIE's Diversity, Equity and Inclusion Policy, which commits the Group to adapt working arrangements and conditions to welcome and include persons with any type of disability. The Group runs specific programs to promote the inclusion and professional development of persons with disabilities, including accessibility of tools, application procedures and premises, and drew on the International Labour Organization's Disability Charter when defining its DEI Policy. To support accessibility, the Group ensures face-to-face training is accessible for persons with disabilities when an employee reports difficulties, and increasingly uses digital training via its Learning Management System available in 11 languages. An awareness campaign to encourage self-declaration of disability is planned for 2025. The report does not disclose a quantified figure for the percentage of employees with disabilities in its own workforce, noting legal constraints related to the identification of certain populations.

Reference: page 160

In 2024 ENGIE trained 94.6% of its employees, with each completing on average at least one face-to-face, digital or hybrid training course across all countries and activities; this is higher than in previous years and forms part of the 2030 target of training 100% of employees annually (interim targets of 90% in 2025, 92% in 2026, 94% in 2027, 96% in 2028 and 98% in 2029). The average number of training hours per employee was 20, comprising 21 hours for men, 16 hours for women, 11 hours for those recorded as other and 24 hours for unspecified. Training is delivered through ENGIE University and Business Academies including the Renewables, Networks, Energy Solutions and FlexGen Academies plus cross-functional HR, Digital and Data, and Procurement Academies. On performance and development reviews, 39,992 employees (53%) received a performance review in 2024, including 21,974 managers and 18,388 non-managers, while 39,555 employees (52%) had a development interview, including 21,566 managers and 17,989 non-managers.

Reference: page 164

ENGIE reports health and safety metrics covering employees, temporary workers and (sub)contractors. The Lost Time Injury Rate (LTIR) for employees, temporary workers and (sub)contractors was 1.7 in 2024, below the maximum annual target of 2.0 and improved from 1.8 in 2023; the LTIR for employees alone was 2.0, against a 2030 target of 1.5. There were 3 fatal accidents in 2024 against a target of zero, comprising one fatality among employees and temporary workers (including one employee) and two among (sub)contractors. The fatality rate for employees, temporary workers and (sub)contractors was 0.009 (0.019 in 2023), against a target of zero. The number of days lost due to lost-time injuries and employee fatalities was 18,116. There were 1,111 accidents with and without lost time for employees and 1,160 for employees and temporary workers. The Total Recordable Injury Rate was 6.7 for employees and 6.7 for employees and temporary workers. The Group recorded 45 new cases of occupational illness among employees, and 72% of employees and temporary workers were covered by a recognized health and safety management system.

Reference: page 152

Work-life balance is addressed mainly through the parenthood pillar of the ENGIE Care social protection program and through workplace well-being initiatives under the No Mind at Risk prevention program. The Group reports that the parenthood pillar helps to strengthen work-life balance and equal opportunities for women and men. Under ENGIE Care all employees are entitled to family-related leave of full pay for a minimum of 14 weeks' maternity leave and a minimum of four weeks' paternity leave. Coverage of these entitlements reached 99% of employees for fully paid maternity leave and 98% for fully paid paternity leave at September 1, 2024, both rising to 100% by the end of 2024. In addition, the Group monitors employees' workplace well-being every two years through the ENGIE&Me survey, which includes questions directly related to well-being and allows each work group to assess its maturity. A monthly No Mind at Risk newsletter covers topics such as mental load, hyperconnectivity and multitasking. The report does not separately disclose the take-up rate of family-related leave by gender.

Reference: page 157

ENGIE reports two compensation metrics under S1-16 for 2024: a calculated gender pay gap of 4.3% and a pay ratio of 71.3. These are calculated from Group Social Reporting aggregate data covering all Group employees, using average Full-Time Equivalent pay (since median pay cannot be calculated across companies with different payroll systems) and excluding the highest-paid individual for the ratio. The compensation data includes fixed and variable short-term compensation, exceptional bonuses and certain benefits in kind such as car and housing, but excludes pension, profit-sharing and long-term incentive data at this stage. Separately, the Group's own adjusted gender pay gap metric (metric 1 of the Gender Equity Index, focusing on equivalent positions and factoring in socio-professional categories and age groups) was 1.85% in 2024 on a scope of close to 80% of employees, against a Group target of a maximum 2% gap over 2022-2030. The adjusted gap is the metric monitored by the EESDC and Board of Directors as part of the Group's 2030 targets.

Reference: page 156

In 2024, 75 allegations of discrimination and harassment affecting company employees were reported via ENGIE's Whistleblowing System. During the same period, 22 allegations related to other social and human rights of employees, covering health and safety and working practices, were filed via the system. To avoid double-counting across the various channels and hotlines available, only incidents submitted through the ENGIE Whistleblowing System were considered. No complaints were submitted to the National Contact Points for the OECD Guidelines for Multinational Enterprises. ENGIE reports that no serious human rights incidents affecting employees occurred in 2024. The Group manages such incidents through its Whistleblowing System, described in Section 3.1.4.1.5, which provides tracking and monitoring of issues raised and addressed, and through its Human Rights Vigilance Policy, which prohibits all forms of discrimination and harassment and addresses slavery, human trafficking, forced or compulsory labor and child labor.

Reference: page 166

ENGIE's main policies on managing material impacts on value chain workers include the Human Rights Vigilance Policy, the Ethics Code of Conduct, and the Code of Conduct in Supplier Relations. The policies explicitly prohibit forced labor, human trafficking and child labor across all activities, including those of suppliers, and expect this to be respected by all third parties. The Procurement Charter commits the Group to sustainability and human rights throughout its supply chains. Commitments are embedded in supplier contracts via an Ethics and Sustainable Development Clause included in all purchasing contracts regardless of amount. ENGIE is committed to the UN Global Compact and ILO standards. In 2024, no instances were reported of non-respect of the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises.

Reference: page 169

Material impacts, risks and opportunities for value chain workers are managed through responsible purchasing and social responsibility policies. All Group entities must annually assess their activities for impact on human rights using a dedicated self-diagnostic scorecard, with findings managed and analyzed by the Ethics, Compliance and Privacy Department. ENGIE seeks to reduce its number of suppliers, focusing on strategic and sustainable partnerships for a more accurate view of value chain workers' perspectives. The company states it is not in a position to publish information on the terms of engagement with workers in the value chain, and it has not directly involved value chain workers, their representatives or other proxies in target setting. For health and safety, ENGIE applies a Group Rule on (sub)contractor health and safety (GR02) covering company qualification, subcontractor selection by questionnaire, specific contractual clauses, and performance assessment during and after work.

Reference: page 167

ENGIE operates a single Group whistleblowing mechanism through which all stakeholders, including value chain workers, can report any infringement of their rights. The system covers the overall approach and procedures for remedying negative impacts on persons, assessment of the effectiveness of solutions provided, and policies to protect whistleblowers from reprisals. Grievances may be of any kind, including social or environmental, and identified negative impacts must be appropriately remedied. The mechanism is managed by a third party that guarantees anonymity. The Code of Conduct in Supplier Relations invites suppliers to report any ethical incident concerning ENGIE through the Whistleblowing System, whose address is notified to them. Procedures for communicating the system to stakeholders are described in the human rights and whistleblowing sections, and stakeholders can use the system to voice concerns or needs and request solutions.

Reference: page 169

ENGIE runs specific actions under its vigilance approach to manage impacts on value chain workers. An in-depth vigilance action plan to identify risks of forced labor in the Group's China supply chains was launched in 2020. Actions taken in 2024 include reinforced due diligence against forced labor in high-risk countries, a mandatory training plan on ethical supplier relations across the Procurement functional line, ethical audits of production sites in high-risk sectors such as solar panels and wind turbines, and specific audits of workers' living quarters in the Middle East, particularly on building sites. Supplier qualification includes a due diligence questionnaire assessing health and safety and human rights, with findings classified as low, medium or high risk determining corrective actions, which may include supplier exclusion. ENGIE allocates internal resources to specialized teams conducting supplier due diligence and auditing at-risk sites. No severe human rights issues or incidents connected to affected communities were reported in 2024.

Reference: page 169

For the health and safety of employees, subcontractors and temporary workers at Group sites, ENGIE targets the prompt eradication of serious and fatal accidents and further reductions in its Lost Time Injury Rate. Two main metrics with maximum annual targets cover accidents of employees, subcontractors and temporary workers: a Lost Time Injury Rate of 1.7 and a fatality rate of 0.009, with a target of zero. ENGIE uses standardized methods to calculate and monitor its indicators, including internal control processes and tools to assess human rights and health and safety risks, with data validated by third-party organizations. For adequate working conditions of value chain workers, the Group reports it is still studying the operational procedures needed to collect the information required to publish metrics. Value chain workers, their representatives or other proxies were not directly involved in the target-setting process.

Reference: page 174

ENGIE is committed to respecting internationally recognized human rights and not undermining the rights of stakeholders potentially affected by its activities. Section 3.1.3.1 describes the Group's general approach to human rights and presents the Human Rights Vigilance Policy, which applies to all communities when managing material impacts and risks. The Group also relies on cross-functional or issue-specific policies such as its Stakeholder Engagement Policy, which includes a specific provision for affected communities, including indigenous peoples and local communities. The policies are based on international standards including the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. ENGIE specifically takes into account the situations of indigenous peoples and is committed to respecting their rights as defined in the UN Declaration on the Rights of Indigenous Peoples and ILO Convention No. 169 on Indigenous and Tribal Peoples. A societal plan is drawn up in accordance with the Stakeholder Engagement Policy to enable remedy for human rights impacts on communities, with the aim of covering all industrial activities by 2030. In April 2023 NGOs lodged a complaint with the OECD's Dutch National Contact Point against ENGIE and others relating to former coal suppliers in Colombia; the plaintiffs withdrew the complaint against ENGIE in 2024.

Reference: page 175

The Group has put in place a Stakeholder Engagement Policy deployed through internal tools for its operating entities, available publicly on the ENGIE website and based on current international standards such as ISO 26000 and AA1000. Engagement of affected communities must be guaranteed throughout project life cycles. On a project-by-project basis and depending on identified risks, a strategy and engagement plan are defined to gather the views of affected communities; the frequency of interaction is specific to each project and discussions take place as close to the area as possible, generally in the form of public meetings. Business developers or site managers are responsible for setting up dialogue, under the responsibility of Country Managers. Each year, each operating activity or site assesses its level of stakeholder engagement based on a Group-wide reference system grounded in the AA1000 standard developed by AccountAbility. Data from operating sites is compiled by the Group's ESG Department, contributing to the metric linked to the target of having 100% of activities covered by stakeholder engagement. An example is ENGIE's consultation in the United Kingdom regarding a planned anaerobic digestion facility on Long Lane in Yorkshire.

Reference: page 175

All information relating to the Group's Whistleblowing System, the processes for providing remedy where it has identified that it has caused a negative impact on affected communities, how the Group assesses that the remedy provided is effective, and the adoption of policies to protect individuals who use these systems against retaliation are set out in Section 3.1.4.1.5. At local level, and depending on the risks identified, the entities also put in place appropriate mechanisms at operational level for affected communities to raise their concerns. The entities have also been asked to inform external stakeholders about the existence of local and Group-level grievance mechanisms, including through engagement with stakeholders. Where the Group's activities lead to air, water or soil pollution incidents, crisis procedures are triggered to remedy the negative impacts, analyze the origin of the incident and implement corrective actions. In cases of negative impacts linked to changes in the business, such as restructuring and plant closures, support measures are put in place to ensure a resilient transition for the area and the affected communities.

Reference: page 176

Actions taken in 2024 include implementation of the Group's Vigilance Plan, implementation of societal plans integrating principles and methodologies in consultation with stakeholders, and implementation of remediation plans by operational teams based on identified risks. The Group adjusts the allocation and level of its resources (CAPEX or OPEX) according to the nature of activities; given the nature of these expenses, they are considered as potentially having no significant financial impact. Examples include the Cuxtal II gas pipeline project in Mexico, where ENGIE Mexico organized 217 meetings attended by around 15,000 people; the social impact assessment identified 38 indigenous localities in Yucatán and Campeche, and after a free, prior and informed consent process 100% of the communities gave their consent, with 129 social benefits decided. Other examples include the Calama wind farm in Chile (engagement with six Atacama indigenous communities) and projects in Brazil. The contribution of Country Sustainability Officers, Local Societal Officers, Business Developers, site managers and ESG Department teams is highlighted, with external human rights experts called on where needed. No severe human rights issues or incidents connected to affected communities were reported in 2024. ENGIE supports over 2.2 million jobs worldwide and has generated over EUR 125 billion in GDP (based on 2022 data).

Reference: page 177

ENGIE has set a target dedicated to stakeholder engagement to be met by 2030 through the gradual rollout of societal plans for all its industrial activities. The target is the proportion of industrial activities with a societal plan for consultation with local stakeholders, with a 2030 target of 100% and 2024 reporting of 54%. This target ensures that the Group's stakeholder engagement approach is deployed throughout the Group, covers all Group activities, and is monitored annually and reviewed annually by the Executive Committee. For the presence in the regions sub-topic, ENGIE carried out a study of the Group's worldwide socio-economic footprint in 2023/2024 (based on 2022 data), following a first edition in 2019, to measure the Group's contribution to local economic and social development.

Reference: page 179

Section 3.1.3.1 describes the Group's overall approach to human rights and its universally applicable Human Rights Vigilance Policy, supplemented by cross-functional Group policies that benefit consumers and end-users, including ESG policies (just transition and stakeholder engagement) and the Personal Data Protection Policy. The Just Transition Policy is premised on the shift to a lower-carbon economy taking place in a way that is fair to all stakeholders, covering the two positive impacts of consuming less and consuming better. The Stakeholder Engagement Policy commits the Group to open, transparent dialogue and sets out the framework for managing both the regulatory risk arising from government intervention in energy supply prices and the opportunity to develop new offerings; it applies to all Group activities and is implemented by the Group's ESG Department. The Personal Data Protection Policy commits ENGIE to protecting the personal data and privacy of its employees, customers, partners, service providers, subcontractors and suppliers, covers the one negative impact identified, applies to all Group activities, and is based on the EU GDPR and national data protection regulations, with the Group Data Privacy Manager and country Data Privacy Managers responsible for implementation. No cases of non-compliance with the UN Guiding Principles, the ILO Declaration or OECD Guidelines involving consumers and end-users were reported in 2024.

Reference: page 180

Interactions relating to the positive impacts of the just transition take place with customers directly, their legitimate representatives (consumer associations, energy ombudsmen) and the authorities in charge of energy programming and regulatory matters. Interaction may take the form of daily telephone calls or digital exchanges, monthly satisfaction surveys, marketing surveys and occasional consumer panels. Interactions with consumers and end-users are the responsibility of the operating units in charge of marketing products and services, while relations with ministries and regulators are entrusted to each country's public relations teams. Tangible results include co-developing the VertVolt green electricity label in France with ADEME and, in Romania, obtaining in November 2024 the country's first license to supply biomethane from the Romanian Energy Regulatory Authority (ANRE). ENGIE's portfolio includes around one million vulnerable customers who benefit from national assistance programs (energy vouchers in France, social tariff in Belgium). For the personal data protection sub-topic, ENGIE interacts with customers who are directly impacted and the external body responsible for ensuring regulatory compliance in each country (e.g., the CNIL in France); customers can report a data breach by telephone or via a dedicated mailbox, and if ENGIE detects an incident likely to result in high risk, customers are notified.

Reference: page 182

The Group's Whistleblowing System, its procedures for taking corrective action when negative impacts on people occur, the way it assesses the effectiveness of actions taken and the policies to protect people who submit reports against retaliation are described in Section 3.1.4.1.5. Grievance mechanisms for consumers and end-users are set up in each country in compliance with local regulations issued by regulators and/or ombudsmen. The operating entities have special channels in place that enable consumers and end-users to report concerns, including customer relations telephone numbers and dedicated email addresses that refer directly to the Data Privacy Officers (DPO) or competent authorities. Users have access to a web portal at the Group level where they can report a potential data breach and/or refer the matter directly to the competent authority. The entities are required to inform stakeholders about the Group's whistleblowing systems and local reporting channels. ENGIE monitors the volume of incident reports processed internally and externally, and a reminder of the channels is posted on country websites.

Reference: page 181

ENGIE is developing a dedicated range of energy offers, services and initiatives to help consumers and end-users manage their energy transition: green electricity/green gas offers; digital tools to monitor consumption (Ma Conso+ in France; Smart App and Energy Monitor in Belgium); challenges to reduce consumption (Ecodefis+ in France, Reduce & Reward in Australia); programs rewarding better and lower consumption (Mon Programme pour Agir); and innovative offers to optimize costs (Drive App in Belgium, Ma recharge intelligente in France). Specific initiatives for customers in difficulty include free consumption-monitoring tools, dedicated telephone lines and flexible payment schedules. Key actions in 2024 cover seven countries (Australia, Belgium, France, Italy, Mexico, the Netherlands, Romania). Government intervention leading to a possible regulatory cap on energy supply prices is identified as a risk factor, mitigated through dialogue with governments and regulators; the Group received no requests to adopt such measures in 2024 except in Romania (removal of the cap on energy prices). For personal data protection, ENGIE uses organizational and technical measures including designation of DPOs and Data Privacy Managers, a Data Privacy Management System (DPMS), annual data protection risk assessments, internal control procedures and audits, privacy by design, data retention policies, employee training, two-factor authentication and a structured data breach handling procedure. No serious human rights issues or incidents involving consumers and end-users were reported in 2024.

Reference: page 181

For the just transition sub-topic, ENGIE has a target to make renewable energy accessible to as many customers as possible through green offerings: the percentage of green electricity contracts in total electricity contracts (average in Europe) has a 2030 target of 90-95%, with 2024 reporting of 89.5%. The target scope covers consumers and end-users in Belgium, France, Italy, the Netherlands and Romania, and corresponds to the IRO of enabling consumers and end-users to consume better. This target meets the objectives of the just transition; the Group relies on a centralized reporting system gathering monitoring data on green electricity contracts supplied by each country. The Group did not directly involve consumers and end-users or their legitimate representatives in the process of drawing up targets. For the personal data protection sub-topic, ENGIE is in the process of drawing up personal data protection targets for consumers and end-users, to be published as and when defined; the effectiveness of implemented actions and policies is measured through internal control.

Reference: page 185

ENGIE's Ethics Code of Conduct establishes the framework for the professional conduct of every employee and manager, with ethics presented as a pillar of the One ENGIE culture. The ethics culture rests on two principles: zero tolerance, under which all ethical misconduct must result in disciplinary action, and speak up / never be left alone, requiring employees facing misconduct to report it. The ethics and compliance framework is structured around three reference systems plus professional codes of conduct: the Integrity reference system (preventing fraud, corruption and influence peddling), the Human Rights Vigilance Policy, and the Ethical Compliance reference system (covering embargoes, sanctions, export controls and competition law). The framework applies to all Group entities, employees, managers and third parties, and the Ethics Code of Conduct is published in 15 languages. A Group Whistleblowing System collects alerts via ethics@engie.com and a dedicated telephone number, both outsourced to an external provider, available 24/7 worldwide, with confidentiality, anonymity and protection from reprisals for good-faith whistleblowers. In 2024, 335 alerts were input through the whistleblowing procedure and 394 managerial reports of ethics incidents were made.

Reference: page 189

ENGIE's Procurement function structures its management system around the Procurement Charter, a Procurement Governance document setting out 12 rules, and the Ethics Code of Conduct. The policy aligns with the UN Convention against Corruption, the US FCPA, the UK Bribery Act, the French Sapin II Act, ILO and OECD anti-bribery conventions, and human rights regulations such as the Uyghur Forced Labor Prevention Act. All procurement operational processes have ESG components. Key suppliers (Strategic, Preferred, Major) must achieve a minimum EcoVadis rating of 45/100, failing which a corrective action plan is drawn up and monitored. Suppliers are classified into four tiers: strategic, preferred, major and transactional. All contracts include an Ethics and Sustainable Development clause requiring suppliers to respect ENGIE's commitments, under which ENGIE can require a third-party ESG assessment within six months of signing. In the largest tenders, ESG performance can account for around 15% of the supplier assessment. ENGIE aims to have all its top 250 preferred suppliers certified and/or aligned with SBTi objectives by 2030 (44% in 2024).

Reference: page 188

Corruption is one of six ethical risks identified in the Group's Enterprise Risk Management process. In 2023, ENGIE implemented a new methodology for mapping corruption and influence peddling risks in line with French Anti-Corruption Agency recommendations. Enhanced preventive due diligence applies to investment project stakeholders, sponsorship beneficiaries, suppliers, business consultants, newly recruited people in exposed positions and B2B customers, supported by the Gifts, Hospitality and Technical Travel Policy and the Conflicts of Interests Policy. A mandatory ethics and compliance training plan covers all employees, with sessions repeated every three years. Employees most exposed to corruption risk, in Project Management, Business Development, General Management, Finance and Procurement, follow specific in-depth e-learning (83.8% completion at end 2024). Global Leaders must attend a fraud and corruption prevention seminar (98.4% completed the e-learning and 87.6% the seminar). ENGIE holds ISO 37001 anti-corruption certification, first obtained in 2018 and renewed through 2024. Internal inquiries follow the Group's Internal Inquiry Guide, which requires investigators to have no conflicts of interest.

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In 2024, the Group did not face any convictions or fines for significant violations of anti-corruption laws. In 2024, the Group also did not face any significant violations of its procedures or of the anti-corruption standards to which it adheres. The Group's ethics and compliance system is designed to prevent and deal with all ethics incidents, including corruption, competition law violations and breaches of international embargoes or sanctions, regardless of significance. All proven incidents result in appropriate disciplinary or commercial action, together with an assessment of the measures needed to prevent recurrence and an obligation to take corrective action where necessary. Alerts and reports are recorded in the My Ethics Incident digital tool and classified into eight areas, including business ethics covering corruption, competition and embargoes.

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ENGIE's payment policy for supplier invoices is to apply regulatory payment terms, which differ from country to country. The Group pays particular attention to SMEs, which are more exposed to cash flow risks. In a 2023 survey by the French organization SME Pact on the payment practices of major accounts with French SMEs, ENGIE was cited as one of the most virtuous companies in this area. The Procurement Charter highlights ENGIE's commitment to comply with suppliers' payment terms in accordance with the laws in force in all countries where the Group operates. To support sustainable payment practices, ENGIE has rolled out digitized billing processes enabling faster and more transparent payment, and finance teams work with procurement to monitor payment terms and identify anomalies. Further information on payment terms is provided in the parent company financial statements (Section 6.1.1.5). ENGIE states it does not currently have the consolidated metrics necessary to meet ESRS requirements and is studying the procedures needed to collect the required information.