ENGIE SA

The role of the administrative, management and supervisory bodies

Reference: pages 89-90.

ENGIE's Board of Directors oversees sustainability through the Ethics, Environment and Sustainable Development Committee (EESDC), which "reviews the impacts, risks and opportunities (IROs), their influence on the business model and strategy, and the policies, action plans and associated objectives" (p.90). The Audit Committee "monitors all key financial and sustainability performance indicators and, more generally, the process of producing sustainability information," and the Appointments, Compensation and Governance Committee (ACGC) "reviews the definition and monitoring of management compensation incentives linked to the Group's ESG performance" (p.90).

Most Executive Committee members are experts in one or more matters related to material IROs; they "validate the objectives and monitor the progress of the action plans associated with these material IROs before any presentation to the EESDC and subsequently to the Board of Directors" (p.90). In 2025, oversight of sustainability-information quality control sat with the CSRD Audit Steering Committee under the joint responsibility of the Finance and ESG Departments (p.90). Director expertise on sustainability matters is presented in a table entitled "Individual key areas of expertise of Directors" (Section 4.1.1.7, referenced p.90).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 92.

"The way in which governance bodies are informed about sustainability matters and how said matters were addressed throughout 2025 is presented in Section 4.1.2.4 in the tables setting out the 'Main tasks and activities in 2025' for each Committee" (p.92, GOV-2 24, 25, 26a-c). ENGIE cross-references this disclosure into its governance chapter rather than repeating the committee-by-committee detail inside the Sustainability Statement itself. Dedicated sustainability sessions for Executive Committee members were organized in 2024; the report states "no further sessions were held in 2025" (p.90).

Integration of sustainability-related performance in incentive schemes

Reference: pages 90-91.

"The presentation of incentive mechanisms, their approval and updating procedures are detailed in Section 4.2" (p.91). Non-financial criteria, including ESG criteria, form part of the proportion of criteria selected as targets for Executive Committee members for 2025 and proposed for 2026; individual objectives are "defined according to the prerogatives of each Executive Committee member or other senior executive" (p.91). Elsewhere the report quantifies this link for climate specifically: sustainability-related targets accounted for a share of Executive Management incentive remuneration tied to internal annual CO2 reduction targets focused on energy efficiency and fossil-fuel-reduction projects, reviewed quarterly (Section 3.1.2.1.2, p.107 area).

Statement on due diligence

Reference: page 92.

Under French Act no. 2017-399 of March 27, 2017 on the duty of vigilance of parent companies and contractors, "ENGIE publishes a Vigilance Plan (see Section 3.2). This plan brings together all 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 or suppliers with whom it has an established business relationship" (p.92). Information on the due diligence process is cross-referenced in the "Core elements of due diligence" table in Appendix 3.1.5.4.

Risk management and internal controls over sustainability reporting

Reference: pages 102-103 (interpolated from the surrounding page markers; not independently confirmed against a printed folio).

Sustainability risk is "integrated into the Group's overall Enterprise Risk Management Policy, which provides a specific framework for risk governance and control" (Section 2.1). ENGIE states it "has been reporting on climate-related risks and opportunities, as recommended by the Task Force on Climate-related Financial Disclosures (TCFD)" for several years, and that "materiality assessments are fully integrated into the risk management system."

On internal control specifically: "In 2025, ENGIE continued to strengthen the control environment for the processes leading to the disclosure of sustainability statement information. A risk-based approach has strengthened the control frameworks governing the processes for producing sustainability statements, particularly for environmental, societal and human resources information. At present, the control environment will be developed as part of a continuous improvement approach in line with the Group's Internal Control Policy." No material weaknesses are described.

Strategy, business model and value chain

Reference: pages 79-83.

ENGIE's stated target is to "Be the best energy transition utility by 2030," with 2030 ambitions including 95 GW of renewable production and storage capacity, 300 TWh of electricity sales (B2B and B2C), 50 TWh of biomethane injection capacity, 10,000 km of electricity transmission networks, and 4 GW of hydrogen production by 2035 (p.79-80).

The value chain description covers upstream sourcing (products/services purchasing, energy purchasing), own operations (production, networks, sales across centralized assets - renewable, nuclear, gas - and decentralized assets - solar panels, on-site heating/cooling), and downstream sales, mapped against ESG issues at each stage: sourcing carries "biodiversity and ecosystems," "natural resources," "circular economy" and "human rights" issues; operations carry "climate change," "water," "pollution," "biodiversity," "human rights and stakeholders" and "health & safety" issues (p.81-82).

Interests and views of stakeholders

Reference: page 85.

"ENGIE has made stakeholder dialogue a key element of its business conduct... The Group has identified eight categories of stakeholders and adapts its dialogue to their specific requirements" (p.85, SBM-2 43, 45a). For customers, engagement runs through "Marketing studies, consumer panel," "Responses to customer consultations," "Satisfaction surveys" and a mediation space with ENGIE and energy mediators, aimed at "Understanding customer needs," "Co-constructing offerings" and "Resolving as many complaints as possible." For suppliers, engagement runs through "Consultations via calls for tender," ESG discussions via EcoVadis ratings and supplier audits, and a "Procurement Forum (Supplier Days)," aimed at selecting and encouraging the most sustainable suppliers and preventing risks such as shortages, monopolies, economic fragility and forced labor (p.85).

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

Reference: pages 93-102 (the full IRO table, Section 3.1.1.4.2).

ENGIE's double materiality assessment concluded with "a list of 77 material IROs," approved by the Executive Committee on April 12, 2024 and the Board of Directors on September 24, 2024 (p.96). Ten of ENGIE's topical standards are covered (E1-E5, S1-S4, G1); water (E3) and affected communities (S3) are both material for ENGIE, unlike many peers.

The material IROs are grouped by ESRS topic in a full characterization table spanning pages 96-102, each row tagged as an actual or potential impact (positive/negative), a risk, or an opportunity, together with its position in the value chain (own operations/upstream/downstream) and time horizon. Group subsidiaries also flagged IROs "specific to them due to their own activities, but which have not been identified as material at Group level" (p.96), including Electrabel's nuclear waste responsibilities in Belgium and methane emissions from the energy networks businesses (GRDF, GRTgaz, Storengy, Elengy, Distrigaz Sud).

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

Reference: pages 93-96.

ENGIE's double materiality process ran in three steps: Step 1 identified 16 ESG matters across the ten topical standards via workshops covering "General information on the methodology chosen," "Climate and circular economy," "Biodiversity, pollution and water," "Social and personal labor," "Value chain" and "Governance" (p.94). Step 2 identified the IROs associated with those matters with the help of an external consulting firm and all Group business units. Step 3 rated impact materiality (scale, scope, irremediability/likelihood) and financial materiality (current/future effects) on a 0-3 scale, with Risks and Opportunities assessed by the Finance and Risk and Insurance Departments using the Group's Enterprise Risk Management methodology over a three-year Medium-Term Business Plan horizon (p.94-95).

Input values combined stakeholder consultation with three data sources: "financial thresholds for assessing risks and opportunities in the Group's annual analysis of residual risks (ERM)," the 2020 NFRD-era materiality assessment, and a September 2023 peer benchmark on double materiality approaches (p.96).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 96, 204-207 (Section 3.1.5.2 Appendices).

"After determining material impacts, risks and opportunities, the Group assessed the materiality and relevance of each disclosure requirement, then each datapoint" (p.204/96). "The cross-reference table between the ESRS and the Group's double materiality assessment, as well as the list of data points for cross-functional and thematic standards deriving from other EU legislation can be found in Section 3.1.5 Appendices" (p.96).

That table (Section 3.1.5.2) lists, ESRS-by-ESRS, which disclosure requirements are covered and where, and marks specific items either "Not material" (E2-5, G1-5) or "Transitional provision" (E1-9, E2-6, E3-5, E4-6, E5-6, S1-7, S1-12, and a sub-datapoint of E4-3 on biodiversity-offset financing effects). It groups G1's covered requirements as "G1-1, G1-4, G1-6" without listing G1-2 or G1-3, even though both appear extensively, tagged, elsewhere in the Section 3.1.4 business-conduct chapter.

Transition plan for climate change mitigation

Reference: pages 108-110.

ENGIE's climate strategy rests on three pillars - "Reduce," "Absorb" and "Avoid" - "with Net Zero 2045 as a target across its entire value chain (Scopes 1, 2 and 3)" (p.108). The plan "is updated every three years through the Climate Resolution, which is presented to shareholders at the Group's Shareholders' Meeting. ENGIE's Board of Directors last updated the transition plan in December 2024" (p.108). ENGIE sold its E&P activities in 2017, ended coal sales the same year, had "phased out coal usage in continental Europe" by end-2025 with global phase-out targeted for 2027, and "plans to phase out fossil fuels entirely by 2045" (p.108).

Investments allocated to the action plan under EU Taxonomy alignment criteria were "€4 billion in 2025" (p.109), with growth CAPEX of €25-28 billion planned for 2026-2028, "84% Taxonomy-aligned" (p.109). At end-2025 residual coal-fired capacity was "just 0.7GW" (p.109). ENGIE states its targets "are on a pathway compatible with the Paris Agreement, as confirmed by the assessments of the Science Based Targets initiative (SBTi), the Transition Pathway Initiative and Moody's" (p.109).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, disclosed in the FY2025 report (pages 104-107). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

For physical risk, ENGIE uses "Representative Concentration Pathways (RCPs)... developed by the Intergovernmental Panel on Climate Change (IPCC) for its Fifth Assessment Report," focusing on "a central scenario... (RCP 4.5)," projecting 2.4-3°C by 2100, and "a pessimistic scenario in which GHG emissions increase at the current rate (RCP 8.5)," projecting "global warming of 4°C or more by 2100" (p.104) - a high-emission scenario. Analyses use CMIP5/CMIP6 or CORDEX models and warming levels of "+1.5°C for assets ending between 2026 and 2040; +2°C for... 2041 and 2060; +3°C for... after 2060," with +4.0°C for sensitivity analyses (p.104).

For transition risk, ENGIE "annually updates various energy scenarios including an Energy Transition scenario for Europe (15 countries) to 2050" (p.105), and its "Net Zero 2024 scenario consistent with a +1.5°C pathway was presented publicly on November 12, 2024" (p.106) - a 1.5°C-aligned scenario. Assumptions include forward market prices, macroeconomic and supply/demand modeling, and comparison against external scenarios (ENTSO-e, RTE, IEA, ADEME) (p.106). The same process is also applied, on a narrower basis, in South America and parts of the United States (p.106).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, disclosed in the FY2025 report (pages 103, 49-50). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The results of the resilience analysis for physical risks are cross-referenced to Section 2.2.2, and for transition risks to Section 2.2.3 (p.103). In Section 2.2.2, ENGIE identifies hydropower as its most exposed technology, since "hydropower generation is the most exposed technology, due to the strong fluctuations in annual and infra-annual production expected between now and 2050" (p.49). Risk-management measures cited include "the inclusion of climate risk in the Group's geographic and technological portfolio selection criteria," "climate risk analysis and the implementation of adaptation plans... for all new projects," "identification of existing sites at risk from climate change and monitoring of the implementation of adaptation measures (Enterprise Risk Management (ERM) adaptation process)," and "annual monitoring of material damage occurring at ENGIE sites" (p.50).

Analysis of resilience "covers the Group's entire portfolio, in terms of both technologies and geographical footprint" and "is carried out as part of the Enterprise Risk Management (ERM) process, which is an iterative process conducted annually" (p.103).

Policies related to climate change mitigation and adaptation

Reference: page 107 (Section 3.1.2.1.2, cross-referenced from the E1-1 transition plan and E1-4 targets sections, pages 108-115).

Climate governance and policy are addressed jointly under the heading "Governance and policies [GOV-3, E1-2]." The Group's climate policy operationalizes the three-pillar Reduce/Absorb/Avoid strategy through defined GHG-emission-reduction milestones (2030, 2035, 2040) assigned to each Global Business Unit, CO2 budgets integrated into the Medium-Term Financial Plan since 2021, and a CO2 price embedded in investment appraisals (see E1-1 and E1-8 content). Climate governance itself is presented in Section 3.1.2.1.2 per the report's own cross-reference (p.110, "[E1-1 16i] Climate governance is presented in Section 3.1.2.1.2").

Actions and resources in relation to climate change policies

Reference: page 111.

ENGIE's climate action plan is organized into five named actions (A1-A5), each with expected results, scope and time horizon (p.111): "A1. Coal phase-out" (reduce GHG emissions, target 2027 - "No coal sales since 2019... Exit from coal-fired power generation by 2027 globally, in the following order of priority: closure, conversion and sale"); "A2. Reduce and decarbonize gas consumption and sales, while producing renewable and decarbonized gas" (produce 10 TWh biomethane and 4 GW hydrogen by 2035, targets 2030/2045); "A3. Decarbonize electricity and heat production, sales and consumption" (95 GW renewable production by 2030, including storage, 300 TWh of electricity sales by 2030); "A4. Support energy network transition" (50 TWh of biomethane injection by 2030, 10,000 km of new transmission networks by 2030); and "A5. Help customers decarbonize their operations" (energy efficiency, sobriety and demand flexibility support, 2030/2045).

Targets related to climate change mitigation and adaptation

Reference: pages 111-113.

ENGIE's overarching target is "Group Net Zero Carbon, Scopes 1, 2 and 3," from 265 Mt CO2eq (2017 baseline) to 157 Mt CO2eq (2024) to 145 Mt CO2eq (2025), with a 2045 goal of "90% reduction in emissions and neutralization of residual emissions" (p.112). The share of renewable energy capacity in the electricity production mix rose from 43% (2024) to 50% (2025), against a 2030 target of "58%/66%" (p.112).

ENGIE's targets "have been certified as 'well below 2°C' by the SBTi since early 2023, following an initial 2°C certification in 2020," with 2017-2030 commitments of a 66% cut in carbon intensity for energy production (Scopes 1-2; 2025 result -59%), a 56% cut for purchases/production for resale (Scopes 1, 3.3.D, 3.15; 2025 result -39%), and a 32.5% cut in other Scope 3 (2025 result -35%) (p.113). Targets exclude carbon offsets or removals and cover 100% of Scopes 1, 2 and 3 and all Kyoto-basket GHGs (p.112).

Energy consumption and mix

Reference: pages 118-119.

Total energy consumption (consolidated scope) was 172,257 GWh in 2025, down from 211,710 GWh in 2024 - a 19% fall the report attributes to "the drop in production from the Group's nuclear assets in Belgium in 2025 with the shutdown of three reactors: Doel 1, Doel 2 and Tihange 1" (p.119). The share of fossil sources in total energy consumption was 64% (consolidated scope) in 2025 versus 52% in 2024; nuclear made up 30% (vs. 41% in 2024); renewable sources made up 6% (unchanged) (p.118). The report separately notes 2025 coal consumption rose versus 2024, "linked to rising electricity demand in Chile, where Engie owns coal-fired power generation assets" (p.119).

Energy intensity on a net revenue basis fell from 2,868 MWh/€million (2024) to 2,394 MWh/€million (2025) (p.119).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 119-121.

Total location-based GHG emissions were 145.2 Mt CO2eq in 2025 (157.2 in 2024; 265.1 in the 2017 base year); total market-based emissions were 145.3 Mt CO2eq (157.5 in 2024) (p.120). Significant Scope 3 emissions totaled 122.6 Mt CO2eq in 2025 (183.6 in 2017), with the largest single lines being "3.11 Use of sold products (fuel sales)" at 47.7 Mt CO2eq and "3.3 Fuel- and energy-related activities" at 44.1 Mt CO2eq (p.120). The carbon intensity of energy production (Scope 1) was "121kg CO2 eq./MWh eq. in 2025, compared with 107kg CO2 eq./MWh eq. in 2024" (p.120).

Methodology follows "the GHG Protocol Corporate Standards (2004 version) and ISO 14064 (supplemented by ISO 14069)" (p.121), covering CO2, CH4, N2O and fluorinated gases at 100-year GWP. ENGIE excludes steel-gas-recovery-service emissions from Scope 1 for three facilities (DK6 in France, Knippegroen and Rodenhuize in Belgium) under ISO 14404:2024, on the basis that responsibility for those emissions sits with the steelmaking customer (p.121).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: pages 116-117.

"In May 2021, ENGIE committed to being Net Zero in its three scopes by 2045, first by reducing its GHG emissions by at least 90% and then by contributing to the growth of carbon sinks within and outside its value chain to neutralize its remaining emissions" (p.116). In the short term (to 2030) the Group "will mainly use carbon credits from nature-based carbon sequestration solutions (e.g., afforestation, reforestation, regenerative agriculture or mangroves)," certified to standards such as Label Bas Carbone and Verra VCS (p.116).

"In 2025, the Group did not generate any carbon sequestration and storage in its operations or value chain. It did, however, retire 76,252t CO2 in carbon credits for its own account," of which 34% were carbon removal/similar credits, 66% avoided-emissions credits, 100% recognized-standard credits, and 22% issued in Europe (p.116-117). ENGIE states "significant volumes will start from 2030, to deliver on the Net Zero target on working practices" (p.117), and that longer term it expects to rely also on negative-emission technologies such as biogenic carbon capture and storage.

Internal carbon pricing

Reference: page 117.

ENGIE operates two carbon-pricing mechanisms. First, EU ETS and comparable allowance prices are "taken into account when modeling the evolution of the European energy system to 2050" and feed directly into energy-price forecasts used for annual asset impairment testing, using "a central assumption (spot value at December 31, 2025 of €87/t)" (p.117). EU ETS quotas covered 76% of gross Scope 1 GHG emissions in 2025 (vs. 73% in 2024), and 0% of Scope 2 and Scope 3 emissions (p.117).

Second, ENGIE states it will add "an internal carbon contribution to finance future carbon removal... needed to reach the Group's Net Zero targets (from 2030)," to "involve all the Group's consolidated entities, contributing financing in proportion to their Scope 1, 2 and 3 emissions," beginning in 2030 (p.117).

Policies related to pollution

Reference: pages 124-125.

"The Group has adopted a policy that aims to reduce and control the risks of pollution (air, water, soil) associated with its activities and value chain, and help protect people and ecosystems," covering "pollution prevention," "the control process" and "incident and emergency management" (p.124). To minimize risk, ENGIE "applies safety protocols and risk management strategies, including preventive maintenance and the use of best available techniques," with emissions reduced where unavoidable "by means of fume filtration systems, pre-discharge water treatment or ground sealing systems" (p.124).

The Anti-Pollution Policy applies "to all Group activities, and to the upstream chain," is approved by the Executive Committee and implemented by the ESG Department; ENGIE is "a founding member of CITEPA's Cross-Border Pollution Forum" and complies with the EU Industrial Emissions Directive (p.125). The policy is public at engie.com.

Actions and resources related to pollution

Reference: pages 125-126.

Three listed actions: inclusion of air/water/soil pollution matters in project development (all Group industrial entities, permanent, aiming to reduce NOx/SO2/particulate emissions); improved diagnosis/inventory of industrial pollutants (all Group industrial entities, by 2026); and "Remediation of former gas production plants" (former gas plants in the portfolio, target 2026) (p.125). Main cost categories are "external engineering expenses, the installation of filtration systems for air pollutants, pollutant monitoring and measurement, pre-discharge water treatment, soil remediation and damage repair" (p.126).

"In 2025, in France, the Group carried out soil remediation work at former gas production plants... Projects include the Vichy Cusset site (work completed in 2025) and the Brionne site (work started in 2025, completion in early 2026). The main pollutants are hydrocarbons, in particular PAHs and THCs" (p.126).

Targets related to pollution

Reference: page 126.

Since 2022 ENGIE has set voluntary 2030 targets for atmospheric pollutants versus a 2017 baseline: NOx from 92,209 t (2017) to 22,656 t (2025 reporting), a -75% reduction versus a -75% 2030 target; SO2 from 159,623 t to 4,387 t, -98% versus a -97% 2030 target; total particulate matter from 7,353 t to 3,411 t, -60% versus a -54% 2030 target (p.126).

The report explains the 2025 movements: "NOx emissions reduced due to lower thermal generation in the Group's portfolio," while "the increase in SO2, particulate matter and mercury emissions relates to the rise in output from coal-fired power plants in Chile to meet demand from the country's electricity system," plus greater biomass use in Brazil and France (p.126). Targets are calculated on the CO2 medium-term plan pathway and set with the GBUs against regulatory, TNFD/SBTN and rating-agency benchmarks (p.126).

Pollution of air, water and soil

Reference: page 127.

2025 air-emission results (consolidated scope, E-PRTR-threshold basis in parentheses): nitrogen dioxide (NOx) 22,656 t (16,880 t), intensity 0.121 t/GWh; sulfur dioxide (SO2) 4,387 t (2,082 t), intensity 0.025 t/GWh; total particulate matter 3,411 t (1,507 t), intensity 0.019 t/GWh; mercury 102 kg (31 kg), intensity 0.0006 t/GWh (p.127). NOx, SOx and particulate matter are "calculated locally by taking measurements," and where measurements are discontinuous, "an average of the measurements over the last five years is taken where possible to avoid inconsistencies related to one-off measurements" (p.126).

Policies related to water and marine resources

Reference: pages 127-128.

Material water IROs include "significant use of fresh water to cool thermal and nuclear power plants and operate methane terminals" (negative impact) and "high water consumption for raw materials extraction, including fuels" (negative impact) (p.127). ENGIE's water management policy covers "assessment of water-related risks and opportunities right from the project phase," "local actions with the stakeholders involved to mitigate the impact on freshwater resources," and "assessment of water footprint of activities across the entire value chain" (p.127), extending to the upstream value chain for raw-materials extraction and fuel production.

The policy applies to all Group activities and the upstream chain, is led by the ESG Department, and aligns with the CEO Water Mandate, CDP Water Security, BAFWAC and the OECD Water Governance Initiative (p.128).

Actions and resources related to water and marine resources

Reference: pages 128-129.

Three actions: reducing freshwater consumption at existing sites (target: freshwater-to-energy-production ratio of 0.1 m3/MWh, down 70% on 2019, by 2030); water-risk analysis for every new project under the avoid-reduce-compensate approach (ongoing); and site-level action plans in water-stressed watersheds (2028) (p.128). "In 2025, 175 sites were located in extreme water stress areas and 114 in high water stress areas. Six of the sites in extreme water stress areas have significant freshwater requirements (freshwater consumption in excess of 100,000 m3/year) and have implemented action plans" (p.128).

In Chile, a thermal plant in an extreme-water-stress area resells desalinated water to a nearby mine: "In 2025, 30,472,871 m3 of water were sold to this third party" (p.128).

Targets related to water and marine resources

Reference: page 129.

Voluntary target: "Reduction in freshwater consumption for energy production," from a 2019 baseline of 0.310 m3/MWh to 0.185 m3/MWh in 2025 (-40% on baseline), against a 2025 target of 0.150 m3/MWh and a 2030 target of 0.100 m3/MWh (p.129). The report states plainly that the target was missed: "The rate of freshwater consumption for energy production is higher than the 2025 target due to the extension of the nuclear business in 2025" (p.129). The target is included in ENGIE's act4nature international commitments and was reviewed by the act4nature review committee (p.129).

Water consumption

Reference: page 129.

Total water consumption fell from 59,832,379 m3 (2024) to 45,890,955 m3 (2025); water consumption in water-stressed areas fell from 33,388,535 m3 to 19,698,451 m3; water recycled and reused rose slightly from 9,407,124 m3 to 9,503,250 m3 (p.129). The report attributes the year-on-year decline to "lower thermal generation in the Group's portfolio (gas and nuclear)" (p.129). Two of the underlying KPIs on stored water "were recalculated for 2024 due to an error in the application of the consolidation rate to one of the entities, which should be integrated at 35% and not 100%" (p.129).

Transition plan on biodiversity and ecosystems

Reference: page 132.

"Under the Group's commitments, biodiversity and ecosystems are included as factors in its strategic planning and business model. ENGIE is strengthening such resilience in all its activities, especially as regards their main dependency, namely the availability of freshwater" (p.132). ENGIE states: "The Group is developing a methodology to evaluate the resilience of its activities to nature-related physical and transition risks. This methodology will be based on ENGIE's strategic and operational data, coupled with the results of its footprint analyses and the LEAP methodology" (p.132) - i.e., the methodology is under development rather than complete. The description of biodiversity IROs and their interaction with strategy is cross-referenced to Section 3.1.1.4.2.

Policies related to biodiversity and ecosystems

Reference: pages 132-133.

ENGIE's biodiversity policy has four focuses: (1) "Land footprint and ecological continuities," via ecological site management eliminating chemical phytosanitary products and identification of protected/sensitive zones near industrial sites; (2) "Biodiversity and climate change," reducing GHG emissions as a lever to ease pressure on biodiversity; (3) "Biodiversity and ecosystem matters in the value chain," via the Sustainable Procurement Policy engaging key suppliers on nature-related challenges; (4) "Awareness-raising and knowledge-sharing," via e-learning, the "biodiversity fresk," and partnerships with the French Committee of the IUCN and UNEP-WCMC (p.132-133).

The policy applies to all Group activities and the upstream chain, is led by the ESG Department, and commits ENGIE to the Kunming-Montreal Global Biodiversity Framework, the French National Strategy for Biodiversity, the Cancun pledge (2016), Business for Nature's "Make it Mandatory"/"Now for Nature" campaigns, and act4nature International (p.133).

Actions and resources related to biodiversity and ecosystems

Reference: pages 133-134.

Four actions: site-level biodiversity action plans for priority sites (2028); applying the "avoid-reduce-compensate" mitigation hierarchy to development projects (all 2025 Group/GBU Investment Committee submissions); ecological site management without chemical phytosanitary products (2030); and implementing Nature-Based Solutions (NBS) meeting the IUCN standard (2025) (p.133). Examples validated by the IUCN French Committee in 2025 include the Araucaria Project in Brazil (restoring degraded ecosystems within Legal Reserves using native araucaria) and a marine protected area on Sainte-Marie Island, Madagascar, with the ENGIE Foundation, Goodplanet Foundation and GRET (p.134).

On compensation-measure financing specifically, ENGIE discloses a data gap rather than a figure: "The financial impacts (direct and indirect costs) and the measures to compensate for biodiversity loss are not available at Group level for 2025" - a sub-datapoint (paragraph 28bii) the company's own ESRS index separately marks under the transitional provisions (p.134, p.206).

Targets related to biodiversity and ecosystems

Reference: pages 134-135.

Four targets, each versus a 2020 baseline: priority material sites with an action plan, 84.5% (2024) to 100% (2025), on track for the 2028 target; development projects applying the avoid-reduce-compensate sequence, 91% (2024) to 100% (2025), on track for the 2024 milestone; active sites with an ecological management plan (notably no chemical phytosanitary products), 63% (2024) to 68% (2025), against a 50%-by-2025 milestone; and Nature-Based Solutions implemented, 4 cumulative (2024) to 6 (2025), against a 2025 target of 10 - "non-compliant" (p.134). ENGIE states plainly: "The 2025 target for Nature-based Solutions implementation was not met. Only six solutions were validated by the IUCN. The demanding nature of the standard makes the preparation and validation of dossiers more complex" (p.135).

Impact metrics related to biodiversity and ecosystems change

Reference: page 135.

"In 2025, the 25 priority material sites were located in or near biodiversity-sensitive areas. These sites cover a total surface area of 1134.44 hectares. This surface area increased compared with 2024, mainly due to the identification of eight new material sites, most of which are wind farms" (p.135). Sites are identified against five criteria (proximity to protected areas, IUCN Red List proximity, ecosystem integrity via the Globio model, water stress zones, and sector-based impact/dependency classification), with a site rated "material priority" once it reaches four or more "very high" criticality levels (p.132).

ENGIE discloses a specific gap rather than filling it with an estimate: "The Group is not yet in possession of metrics on the impact drivers of land-use change, freshwater-use change or sea-use change" (p.135).

Policies related to resource use and circular economy

Reference: pages 135-138.

ENGIE's circular economy and natural resources policy, updated in 2024, addresses three sub-topics: pressure on natural resources/critical materials (mainly affecting Renewables & Flex Power), reuse of industrial assets (Networks and Renewables & Flex Power), and dismantling of industrial assets (Electrabel, Renewables & Flex Power, Local Energy Infrastructures) (p.136). The policy is built around eight levers: "eco-design," "preserve," "optimize," "reuse," "repair," "recycle," "innovate" and "empower" (p.137).

"Under the climate transition plan outlined in Section 3.1.2.1.3, the development of renewable electrical energies and biomethane will reduce demand for fossil fuels and thus reduce the extraction of natural resources (coal, natural gas)" (p.138). The policy applies to all Group activities and the upstream chain, led by the ESG Department, and is informed by membership of OREE, RECORD and Circul'R (p.138).

Actions and resources related to resource use and circular economy

Reference: pages 138-140.

On natural resources: developing biomethane in Europe (Networks GBU, recurring annual action) and repairing assets to extend lifespan, funded through OPEX considered to have "no significant financial impact" given its nature (p.139). Biomethane injection reached "802 sites in France injecting into gas networks at the end of 2025, including 73 sites that began injecting during this period" (p.139).

On dismantling: nuclear decommissioning at Doel 3 and Tihange 2 (not yet begun, target 2037) and maximizing recovery/recycling value from hazardous and non-hazardous waste at dismantled sites (recurring annual activity) (p.139). ENGIE states "there was no significant dismantling activity in 2025" for non-nuclear sites (p.140); for renewable-asset end-of-life it applies principles of "zero landfill," "environmentally-sound dismantling," "extended service life" and "stakeholder engagement" (p.140).

Targets related to resource use and circular economy

Reference: page 139.

Two biomethane targets versus a 10 TWh/year-by-2035 and 50 TWh/year-by-2030 ambition: biomethane production capacity in Europe held at 1.2 TWh in both 2024 and 2025 reporting (12% of the 2035 target), while biomethane injection capacity in France rose from 13.0 TWh (2024) to 14.5 TWh (2025 reporting), 29% of the 2030 target (p.139). For dismantling waste specifically, "ENGIE does not have specific targets on the management of dismantling waste, except for the Renewable & Flex Power GBU, which targets at least 90% recycling for materials from dismantled photovoltaic panels... and at least 90% of materials from wind turbine blades. Work with other GBU on this matter will be carried out over the next few years" (p.140).

Resource inflows

Reference: pages 138-139.

ENGIE describes its incoming raw materials qualitatively rather than by weight: "the main incoming raw materials are natural gas, biomass, water and metals used in particular in renewable energy technologies," with wind plants typically using "steel, copper, aluminum, zinc, lead, polymers, fiberglass, concrete and rare earths," photovoltaic panels "aluminum, concrete, copper, silicon, zinc, rare earths, plastics/polymers and glass," batteries "lithium, graphite, iron, cobalt, aluminum," and electrolyzers "nickel, copper, steel, zirconium and plastics/polymers" (p.138-139). ENGIE states it "does not, however, have a precise and exhaustive view of every material used in renewable energy technologies," and that the underlying studies "do not cover all the technologies used by the Group" (p.138).

On the quantitative datapoints: "Given the nature of the Group's current internal accounting nomenclature and purchasing data, the Group cannot report on the weights of materials purchased and the percentage of recycled materials they contain. Work on this aspect will be carried out over the next few years" (p.139).

Resource outflows

Reference: pages 140-141.

Dismantling-related outflows are covered qualitatively: nuclear dismantling waste in Belgium is monitored by Electrabel and by the Belgian National Agency for Radioactive Waste and Enriched Fissile Material (ONDRAF); "some 98% of the waste generated by dismantling a nuclear power plant is conventional waste (concrete and metals) that will be recycled and recovered as far as possible" (p.139-140). For non-nuclear/dismantling waste generally, ENGIE states a gap: "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 next few years to meet any standards applicable here" (p.140).

The Group does publish a general non-hazardous/hazardous waste tonnage table (see the separate Waste disclosure), but flags it explicitly: "Indicators relating to waste are published, although they are not material in the sense of the double materiality analysis, in order to ensure continuity with the Group's previous publications and to meet the expectations of external stakeholders" (p.141) - a caveat worth checking against the index, which lists E5-5 itself (unlike E5-4's narrower datapoints) as reported without a "Not material" qualifier.

Policies related to own workforce

Reference: pages 156, 167 (Sections 3.1.3.1, 3.1.3.2.3, 3.1.3.2.6).

Own-workforce policy is anchored in the Human Rights Vigilance Policy, described in the report's general human-rights chapter (Section 3.1.3.1) and applied to employees throughout Section 3.1.3.2. The Health & Safety Policy is built on two axes: "'No Life At Risk', which deals with accident prevention" and "'No Mind At Risk', which focuses on improving quality of life at work and preventing psychosocial risks" (p.167), based on "eight fundamental principles" and the subject of "a global agreement with employee representatives." Both the Health & Safety Policy and the Human Rights Vigilance Policy apply to all Group employees, temporary workers and, for health & safety, subcontractors (p.167).

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

Reference: pages 153-154.

Social dialogue runs at four levels: locally with trade unions/employee representatives; nationally (in France, via the French Group Works Council); at European level via the European Works Council (EWC), which has "supra-legal resources" pending French transposition of the relevant EU directive; and globally via the "Global Forum," chaired by the CEO and meeting annually with international federations (p.154). A "Global Agreement" on fundamental rights and social responsibility, signed with international federations and French trade unions in January 2022, covers "ethics and duty of vigilance, anti-harassment, safety, workplace well-being, diversity and inclusion, skills development and training"; renewal negotiations were underway in 2026 (p.154).

Effectiveness is evaluated via meeting quality, the number of agreements signed, and the number/duration of labor disputes, plus the biennial "ENGIE&Me" survey - the 2024 wave logged an 82% participation rate, 88% positive responses on the decarbonization strategy, and 85% willing to recommend ENGIE as an employer (p.154).

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

Reference: page 151.

Employee channels include "the Group's ethics whistleblowing system via the Ethics & Compliance Officer or by email to ethics@engie.com," managerial and HR/legal/health-safety relationships, confidential professional emails, social dialogue bodies, and specialized French systems "'Allodiscrim' and 'Allosexism'" dedicated to discrimination and sexism reports (p.151). The Whistleblowing System is publicized via the Ethics Code of Conduct (available in 15 languages), the intranet, the website and posters, and "concerns all the Group's stakeholders, whether they are victims or witnesses of an incident" (p.151). Full procedural detail (handling, effectiveness assessment, anti-retaliation protection) sits in Section 3.1.4.1.5, cross-referenced rather than repeated.

Taking action on material impacts on own workforce

Reference: pages 154-155.

Two headline actions: revising the Global Agreement (2026, new coherence framework for working conditions) and mapping collective agreements by country (2026) - both considered to have "a non-material financial impact" given the nature of the spend (p.154). On restructuring specifically, ENGIE describes a "social diagnosis process" run with consultative bodies before any restructuring with employment impact, comparing the Group's and social partners' impact analyses and adapting support (mobility bonuses, pay-gap compensation, relocation cover, spouse job-search assistance) accordingly (p.154-155). In France, "an agreement on Jobs and Career Path Management within ENGIE was signed on July 9, 2025... covers approximately 85% of employees based in France," with an amendment on skills development under negotiation for signature in March 2026 (p.155).

Targets related to own workforce

Reference: pages 155-156, 160-165, 169.

S1-5 targets span the chapter: social-dialogue effectiveness is assessed via meeting quality/frequency rather than a numeric target (p.155); women in management, 33.1% (2025) against a 40-60% 2030 target (p.160); apprentices, 7.3% (2025) against a 10% 2030 target (p.160); average training participation, 89.7% (2025) against a 100% target (p.164); gender pay gap, 3.0% (2025), down from 4.3% (2024), with no fixed numeric target stated but tracked annually (p.163); Lost Time Injury Rate, 1.7 (2025 and 2024) against a 1.5-by-2030 target, and workplace fatalities, 1 (2025) versus 3 (2024), against a zero target (p.169). Target governance sits with the Human Resources Department, validated by the Executive Committee and broken down by Business Unit and region for the diversity targets specifically (p.160).

Characteristics of the undertaking's employees

Reference: pages 151-153.

At December 31, 2025 ENGIE employed 91,189 people in more than 30 countries, with France (44,185, 48% of the workforce) the only country exceeding 10% of total headcount; other significant countries include Belgium (7,954, 9%), Germany (5,573, 6%) and Romania (4,638, 5%) (p.152). By gender: 66,308 male (73%) and 24,833 female (27%) employees, plus 8 "Other" and 39 "Unspecified" (p.152). By contract type: 93% of the workforce (84,786 employees) held permanent contracts, 7% (6,358) held fixed-term contracts, and 45 employees held non-guaranteed-hours contracts (p.153). Total personnel costs were €8,648 million (2025) versus €8,623 million (2024) (p.151).

Collective bargaining coverage and social dialogue

Reference: page 156.

"The European Labour Relations Agreement applies to all Group employees based in Europe (as in 2024)," and "the Global Framework Agreement on Fundamental Rights and Social Responsibility applies to all Group employees without exception (as in 2024)" (p.156). "The European Works Council, which comprises 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" (p.156). Outside Europe, "the Group is implementing a process to determine the percentage of employees covered by collective agreements by region (excluding the European Economic Area)" - i.e., that metric is not yet available globally (p.156).

Diversity metrics

Reference: pages 160-161.

"Top Management comprises 310 employees (vs. 294 in 2024), of whom 94 are women and 216 are men (92 and 202 in 2024, respectively)" (p.160), defined as "the highest level of decision-making and responsibility in the company," evaluated via the Korn Ferry Hay methodology. The workforce age breakdown (2025): under 30, 13,958 employees; 30-50, 36,389; over 50, 20,200 (total 91,189/66,308 by other cross-cuts as tabulated) (p.161), though the report notes "due to a change in the definition of age groups in 2025, a year-on-year comparison with 2024 is unavailable." ENGIE states it has "not set targets or metrics related to the origin, gender identity or sexual orientation of its employees" given legal constraints on identifying such populations (p.160).

Adequate wages

Reference: page 156.

"ENGIE employees receive an adequate wage in countries with benchmarks. ENGIE refers to legal minimum wage data or local minimum wages established by collective agreements. For four of the Group's countries - Switzerland, Saudi Arabia (non-nationals), United Arab Emirates and Singapore, which represent 4.4% of Group employees - no such references exist" (p.156). "ENGIE has not set any targets at this stage. The Group complies with minimum social standards on pay in all countries where it operates and ensures that it offers competitive pay to all its salaried employees, in particular through compensation surveys," and states it "will continue to reflect on the issue of the adequate wage in line with best practices" (p.156).

Social protection

Reference: page 156.

Social protection is addressed principally through "ENGIE Care," reaffirmed as a long-term commitment by the Group Human Resources Department at the Global Forum on October 15, 2025 (p.156). Separately, "the Group measures and recognizes its pension and other employee benefit obligations in accordance with the laws and practices of each country, in terms of pensions, early retirement, severance pay and healthcare plans" (Note 18 of the financial statements), and "analyzes the pension plans granted to its former employees in order to estimate more precisely the risk of a significant increase in the costs associated with these benefits, with a view to defining, where appropriate, targets and/or metrics for measuring this risk" (p.156) - i.e., no dedicated social-protection coverage metric (e.g., % of employees covered) is disclosed for 2025.

Training and skills development metrics

Reference: pages 164-165.

"In 2025, on average, 89.7% of the Group's employees completed at least one face-to-face, digital or hybrid training course, across all countries and activities" (p.164), down from 94.6% in 2024, against a 100% 2030 target. Average training hours per employee by gender in 2025: men 21 hours, women 16 hours, "Other" 11 hours, total average 20 hours (unchanged from 2024's total of 20) (p.165). "The denominator used to calculate training metrics is headcount" (p.165). Training priorities are set annually by ENGIE University and the Business Academies steering committees, and development interviews let managers and employees "take stock of development actions, career aspirations and mobility" (p.164).

Health and safety metrics

Reference: pages 167, 169.

Key 2025 metrics: Lost Time Injury Rate for employees, temporary workers and subcontractors, 1.7 (unchanged from 2024), against a 2030 target of 1.5 and a 2025 target of "≤1.7"; workplace fatalities, 1 (2025) versus 3 (2024), against a zero target; fatality rate 0.003 (2025) versus 0.009 (2024) (p.169). Rates are calculated per million hours worked, and "in 2025, approximately 44% of subcontractors' hours worked were estimated" from invoice amounts rather than measured directly (p.169).

On scope: "Regarding non-employees, ENGIE has chosen to apply a transitional provision for its 2025 reporting by publishing only data relating to temporary workers" (p.167) - i.e., the transitional provision narrows the non-employee population covered by these metrics, without displacing the core employee/temporary-worker disclosure itself, which remains reported.

Work-life balance metrics

Reference: page 156.

Work-life balance is addressed together with social protection under "ENGIE Care," reaffirmed by the Human Resources Department at the Global Forum on October 15, 2025 as part of "a long-term vision" (p.156). No standalone work-life-balance metric (e.g., parental-leave uptake or flexible-working coverage) is quantified in this section; the disclosure instead points to the biennial "ENGIE&Me" survey, described in the S1-2 processes section, as the channel through which employee perceptions of well-being are monitored (p.154, "the ENGIE&Me survey also makes it possible to monitor employees' perceptions of their remuneration and well-being").

Compensation metrics (pay gap and total compensation)

Reference: page 163.

"For 2025, the calculated gender pay gap was 3.0% (vs. 4.3% in 2024)" and "the calculated remuneration ratio was: 74.7 (vs. 71.3 in 2024)" (p.163). The pay-gap metric "compares the average pay of women with that of men for each group corresponding to the Group's age groups and to the four socio-professional categories (workers, employees, technicians and supervisors, engineers and executives) or with employee classification levels" (p.163). Compensation data are drawn from Group Social Reporting aggregated data, with 2025 also using centralized HRIS data for long-term incentives - "an improvement" the report flags explicitly (p.163).

Incidents, complaints and severe human rights impacts

Reference: pages 160-161.

"In 2025, 151 allegations of discrimination and harassment affecting company workers were reported via the ENGIE Whistleblowing System and via the Group's managerial reporting system for ethics incidents (vs. 75 in 2024 via the ENGIE Whistleblowing System)" (p.161). "During the same period, 38 allegations related to other social and human rights of employees (health & safety and working practices) were filed via these same systems (vs. 22 in 2024...). No complaints were submitted to the National Contact Points for the OECD Guidelines for Multinational Enterprises (as in 2024)" (p.161). "No serious human rights incidents affecting employees occurred in 2025 (as in 2024)" (p.161).

Policies related to value chain workers

Reference: pages 172-174.

ENGIE's policies for value chain workers are "based on international human rights protection standards," led by the Human Rights Vigilance Policy, the Ethics Code of Conduct, and the Code of Conduct in Supplier Relations - all aligned with "the UN Guiding Principles on Business and Human Rights" (p.173). Procurement vigilance combines risk mapping (using Maplecroft country-risk analysis for child/forced labor exposure) with a supplier-selection CSR assessment via EcoVadis: "A risk reduction plan is systematically applied for suppliers with an EcoVadis score under 45/100" (p.173). Six procurement categories are flagged high-risk: solar panels/batteries, wind turbines, electrical equipment, IT equipment, safety gear/clothing, and turnkey EPC contracts (p.172).

"Regarding workers in the ENGIE value chain, in 2025 no instances were reported of non-respect of (i) the UN Guiding Principles on Business and Human Rights, (ii) the ILO Declaration... or (iii) the OECD Guidelines" (p.174).

Processes for engaging with value chain workers about impacts

Reference: pages 175-176.

Engagement centers on subcontractor health & safety at ENGIE sites, governed by "a Group Rule on health & safety for subcontractors (GR02)" covering company qualification (assessing H&S maturity), subcontractor selection (H&S-weighted questionnaire), contract clauses requiring subcontractors to flow the same rules down to their own subcontractors, mandatory work-preparation and safety-briefing stages, on-site supervision (safety visits, inspections, audits), and post-work H&S performance assessment (p.175-176). "The Group's Health & Safety Policy sets a clear objective for the health & safety of subcontractors: to guarantee a degree of prevention and protection at least equivalent to that of employees" (p.175).

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

Reference: page 174.

"ENGIE has set up a single whistleblowing mechanism whereby all its stakeholders, including value chain workers, can report any infringement of their rights" (p.174), managed by a third party that "guarantees their anonymity." "The Code of Conduct In Supplier Relations invites suppliers to report any ethical incident concerning ENGIE through the ENGIE Whistleblowing System, the address of which is notified to them" (p.174). Full procedural detail on handling, effectiveness assessment and anti-retaliation protection is cross-referenced to Sections 3.1.3.1 and 3.2.6 rather than repeated in this section.

Taking action on material impacts on value chain workers

Reference: pages 174, 176.

"No severe human rights issues or incidents connected to value chain workers were reported in 2024 and in 2025" (p.174). Following a 2021 external assessment of its health & safety maturity, ENGIE built the "ENGIE One Safety transformation plan," including manager training, awareness campaigns and regular audits on serious/fatal-accident prevention (p.176). In 2025 "the ENGIE One Safety Induction e-learning course... was extended to the Group's subcontractors," available via a dedicated website with versions "translated into the main languages used by subcontractors" (p.176). Resources include "specialized teams tasked with carrying out due diligence on suppliers and auditing sites identified as 'at risk'" (p.176).

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

Reference: page 176.

Value chain worker health & safety shares ENGIE's Group-wide metrics: Lost Time Injury Rate 1.7 (2024 and 2025), against a 2030 target of 1.5, and fatality rate 0.009 (2024) improving to 0.003 (2025), against an implicit zero-fatality goal (p.176). ENGIE states it "uses standardized methods to calculate and monitor its metrics and outcomes, including internal control processes and risk assessment tools in the areas of human rights and health & safety," but also discloses a limitation: "The company has not directly involved value chain workers, their legitimate representatives or other proxies in the target-setting process" (p.176).

Policies related to affected communities

Reference: pages 181-182.

Affected-community engagement rests on the Human Rights Vigilance Policy and the Stakeholder Engagement Policy, with specific provisions for "indigenous peoples and local communities" (p.181). ENGIE commits to respecting rights to health, a healthy environment, ownership, an adequate standard of living, and access to natural resources, and in displacement situations to ensure "that displaced communities have given their free, prior, and informed consent, as well as their agreement to fair and adequate compensation" (p.181), citing the UN Declaration on the Rights of Indigenous Peoples and ILO Convention No. 169.

On a specific case: "In April 2023, a complaint was lodged by NGOs with the OECD's Dutch National Contact Point against ENGIE and other companies, alleging that the companies had failed to meet the standards expected of them by the OECD Guidelines... in relation to serious acts alleged to have taken place in certain production areas of the Group's former coal suppliers in Colombia... In 2024, the plaintiffs decided to withdraw the complaint against ENGIE" (p.181-182).

Processes for engaging with affected communities about impacts

Reference: pages 179, 182.

"The Group's engagement with affected communities is based on key international frameworks that define human rights principles for undertakings," operationalized through "a mapping process to identify stakeholders, then a process to carry out risk analyses, and finally a process to implement action plans" for dialogue with affected communities (p.179). ENGIE identifies five community types with geographic detail: residents (all regions), vulnerable communities (indigenous peoples in the US/Canada, Brazil, Chile, Mexico, Peru, North Africa, Southeast Asia, Australia, Saudi Arabia, French Polynesia and New Caledonia), neighboring communities (fishermen, farmers, hunters - France, Europe, Brazil), and human rights defenders (all regions) (p.180). "A stakeholder engagement plan is drawn up... setting out the actions to be taken, in consultation with stakeholders, to enable remedy for potential negative impacts... ENGIE's aim is to cover all its industrial activities by 2030" (p.182).

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

Reference: page 182.

"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" (p.182). At local level, "the entities also put in place appropriate mechanisms at operational level for affected communities to raise their concerns," and are asked to "inform external stakeholders about the existence of local and Group-level grievance mechanisms" (p.182).

Taking action on material impacts on affected communities

Reference: pages 183-184.

Two 2025 examples: in South Africa, Xina Solar One's "Climate Change Warriors program" in the Pofadder region "benefited 535 young people in 2025," providing certified solar-field training to graduates from four rural communities (p.183); in Brazil, ENGIE Brasil Energia's "Odontovan" oral-health program with Instituto Água Viva reached 300 people near the Umburanas and Campo Largo wind farms, and a vision-health program with NGO Renovatio and the OneSight Foundation "served more than 2,000 people" (p.183). "No severe human rights issues or incidents connected to affected communities were reported in 2025" (p.184). At Group level, a 2023/2024 Local Footprint(R) socio-economic study (Utopies methodology, 2022 data) found ENGIE "supports over 2.2 million jobs worldwide... and has generated over €125 billion in GDP" (p.184-185).

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

Reference: page 184.

Target: "Proportion of industrial activities with a stakeholder engagement plan for consultation with local stakeholders," 54% (2024) rising to 85% (2025), against a 100% 2030 target (p.184). "This target ensures that the Group's stakeholder engagement approach is deployed throughout the Group... All Group activities are covered by this target, which is monitored annually" (p.184). The jump from 54% to 85% is attributed to "the strong mobilization of the Country Sustainability Officer teams in connection with structuring the ESG sector" (p.183).

Policies related to consumers and end-users

Reference: pages 186-187.

ENGIE's consumer/end-user policies cover two material sub-topics - "just transition" and "personal data protection" - drawing on the Just Transition Policy, the Stakeholder Engagement Policy, and the Personal Data Protection Policy, all layered on the general Human Rights Vigilance Policy (p.186). "The Personal Data Protection Policy commits ENGIE to protecting the personal data and privacy of its employees, customers, partners, service providers, subcontractors and suppliers," led by the Group Data Privacy Manager and country-level Data Privacy Managers, aligned with the EU GDPR (p.187). "No cases of non-compliance with the UN Guiding Principles..., ILO Declaration... or OECD Guidelines... involving consumers and end-users were reported in 2024 and 2025" (p.187). ENGIE serves "19.1 million energy contracts (gas and electricity) in seven countries" (p.186).

Processes for engaging with consumers and end-users about impacts

Reference: pages 186-189.

Engagement on the just-transition sub-topic is daily (call centers, digital channels) or periodic (satisfaction/marketing surveys, product-testing panels), with recognitions noted for 2025: "Customer Service of the Year" (Energy Supplier category, France), a first Canstar Energy Award in South Australia, and Italy's "Top Qualita-Prezzo 2025" label (p.187). ENGIE supported energy-poverty customers through the French "Chèque Énergie" scheme - "approximately 700,000 households" received an additional €50 discount in 2025, and the Group's contribution to the Housing Solidarity Fund doubled to "€12 million (contribution of €6 million in 2024)" (p.188).

On personal data protection, customers can report a breach "either by telephone or via a dedicated mailbox," and ENGIE notifies the relevant authority (e.g., France's CNIL) "within a specified timeframe" for severe breaches (p.188).

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

Reference: page 189.

"Grievance mechanisms for consumers and end-users are set up in each country in compliance with local regulations issued by regulators and/or ombudsmen" (p.189), including "customer relations telephone numbers, dedicated email addresses that refer directly to the Data Privacy Officers (DPO) or the competent authorities," plus a Group-level web portal for reporting potential data breaches (p.189). ENGIE "monitors the volume of incident reports processed internally (sent directly to ENGIE) and externally (sent to the competent authority)" (p.189), and "a reminder of the channels is posted on the country websites" (p.189).

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 187-189.

Actions to help consumers "consume less" and "consume better" include country-specific green-gas blends (e.g., France's "Référence" offer with 5% biomethane, up to 100% via "Gaz vert +"; the Netherlands mandating 1% biomethane in all new contracts from January 2025), consumption-monitoring apps (Ma Conso+ in France, Smart App/Energy Monitor in Belgium, Energy Tracker in Australia, Slim Laden in the Netherlands), and time-of-use pricing programs such as Belgium's "Empower Flextime" (45% cheaper super-off-peak hours) and France's "Happy Heures Vertes" (p.187-188). "No serious human rights issues or incidents involving consumers and end-users were reported in 2024 and 2025" (p.189). On personal data, actions center on "the application of the Group's customer personal data protection policy" (p.189).

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

Reference: pages 189-190.

Target: "Percentage of green electricity contracts in total electricity contracts (average in Europe)," 89.5% (2024 baseline) rising to 95.1% (2025), against a 2030 target range of "[90-95%]," covering Belgium, France, Italy, the Netherlands and Romania (p.189). "In 2025, three European countries had a portfolio of 100% green electricity contracts, and the greening of other portfolios has continued apace" (p.189). ENGIE "did not directly involve consumers and end-users or their legitimate representatives in the process of drawing up targets" (p.190). On personal data protection: "The Group has not defined any targets related to personal data protection at this stage," monitoring effectiveness of actions instead (p.190).

Business conduct policies and corporate culture

Reference: pages 190-193.

Ethics oversight runs from the Board's EESDC through the Group Corporate Secretary and Chief Legal Officer to the Ethics, Compliance & Privacy Department (ECPD), which "coordinates the network of Ethics & Compliance Officers and ethics correspondents (more than 245 people in 2025) and Data Privacy Managers (300 people in 2025)" (p.191); the Group Compliance Committee "met four times in 2025" (p.191). ENGIE's ethics culture rests on two principles: "zero tolerance" for ethical misconduct and "speak up/never be left alone" (p.192). The framework comprises the Ethics Code of Conduct plus three reference systems - "Integrity" (fraud/corruption/influence-peddling prevention, including a Gifts, Hospitality and Technical Travel Policy and a Conflicts of Interests Policy), the Human Rights Vigilance Policy, and "Ethical Compliance" (embargoes, sanctions, export controls, competition law, HATVP lobbying-disclosure compliance) - plus professional codes including the Code of Conduct in Supplier Relations and the Code of Conduct on Lobbying (p.192).

Targets related to business conduct

Back-filled from the business conduct chapter under MDR-T, disclosed in the FY2025 report (page 195). G1-3 became a standalone DR only in the 2025/2026 ESRS; under the 2023 ESRS, business-conduct targets fell under MDR-T.

ENGIE discloses one explicit training-effectiveness target directly tied to corruption prevention: "Percentage of people most exposed to corruption risk who receive training," 83.8% (2024 reporting) rising to 87.7% (2025 reporting), against a 2030 target of ">95%" (p.195). This sits alongside the Group's broader statement that all proven ethics incidents "result in appropriate disciplinary or commercial action as well as an assessment of the measures needed to prevent the incident from recurring" (p.194), and the confirmation that in 2025 the Group faced "no convictions or fines for any significant violations of anti-corruption laws" and "no significant violations of its procedures or the anti-corruption standards to which it adheres" (p.195).

Incidents of corruption or bribery

Reference: page 195.

"In 2025, the Group did not face any convictions or fines for any significant violations of anti-corruption laws" and "did not face any significant violations of its procedures or the anti-corruption standards to which it adheres" (p.195). Dedicated actions and resources cited include the Group's mandatory ethics and compliance training plan (repeated every three years for covered staff), enhanced competition-law training for Local Energy Infrastructures entities since 2023-2025, and joint Procurement/ECPD training for buyers ("Ethics and supplier relations in practice") (p.195). Resource allocation for this action plan is considered to have "no significant financial impact" given the nature of the spend (p.195).

Payment practices

Reference: pages 199-200.

"ENGIE's disclosures only cover the metric relating to the number of legal proceedings currently outstanding for late payments. At this stage, the Group does not yet have the necessary consolidated metrics to meet all ESRS requirements in terms of responsible payment practices" (p.200). "At the reporting date, a legal recovery procedure for late payments remained outstanding in France. This metric is reported for the following scope: France, Italy, Belgium, the Netherlands, Romania and the United States. In 2025, these countries accounted for 70% of Group purchases" (p.200).

Policy: the Group "applies regulatory payment terms (which differ from country to country)" and pays "particular attention to the situation of SMEs" - a 2023 survey by the French organization SME Pact "cited [ENGIE] as one of the most virtuous companies" on payment practices with French SMEs (p.199).