Exel Industries SA
Material Topics
Sustainability statement, in full
The complete text of Exel Industries SA’s FY2025 sustainability statement is held here – 80 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
Governance roles
Reference: pages 65-66.
The Board of Directors "sets the strategic guidelines... and validates the proposals made and in particular the strategy, business model, IROs, objectives, results achieved and URD." Three bodies feed it: the CSR Committee (chaired by Sonia Trocme-Le Page), the Remuneration and Appointments Committee, and the Audit Committee (internal control of ESG data).
Management side: the Group Executive Committee, each company's Executive Management (assisted by a CSR manager), and three CSR Commissions (one per E/S/G theme). The Group Chief Sustainable Transformation Officer, Patrick Tristani, leads sustainable development for the companies and holding company.
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information flows to the bodies
Reference: pages 66-67.
Each Chief Executive Officer's CSR head reports to their CEO and, where applicable, the Executive Committee. The Group Chief Sustainable Transformation Officer meets the CEO regularly and shares consolidated work with the Executive Committee twice a year. CSR Commissions meet quarterly. The CSR Committee meets three times a year with Board members present, issues an opinion on the sustainability report (put to a vote), and "the IRO identification process and the assessment results were supervised and validated by the CSR Committee."
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Sustainability in incentive schemes
Reference: page 67.
Executive Committee variable remuneration includes personal objectives incorporating sustainability performance criteria. For 2024-2025 these were qualitative: "help identify and evaluate material IROs; provide the resources needed to develop all initiatives in response to the most material environmental, social and governance matters; complete the coverage of carbon assessments for the missing companies." The CEO's objectives are approved by the Board; other Executive Committee members' objectives are validated by the Remuneration and Appointments Committee.
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 67.
The report gives a table mapping the five due-diligence core elements to specific report sections rather than narrative text: embedding due diligence (GOV-2, GOV-3, SBM-3), stakeholder engagement (SBM-2, IRO-1), identifying/assessing adverse impacts (SBM-3, IRO-2), taking action (a list of 16 sub-policy sections across 4.2-4.4), and tracking effectiveness (13 numbered "Objectives and results" sub-sections tagged by ESRS topic).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls
Reference: page 68.
"EXEL Industries has considerably improved its internal control and audit system" to integrate sustainability data. Concrete actions taken: "drafted a methodological note for the subsidiaries... trained 17 new internal auditors on skills in environmental, social and governance issues; carried out 1 audit involving the CSR process." A gap is flagged: a list of ESG-specific controls for the internal control manual is scheduled for H1 2026, not yet in place.
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 69-71.
Three segments: Agricultural Equipment (15% of turnover), Leisure/Garden (29%), Industry/Industrial Spraying (56%). €983M turnover, 27 countries, 3,962 employees. The Leisure-Garden and Industry-Technical Hoses activities are "the only two Group activities that are vertically integrated," transforming plastic (petroleum-derived) into hoses/gardening equipment; agricultural equipment assembles steel, aluminum, plastic, rubber and electronics. Distribution is mainly B2B through dealer networks.
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: page 74.
"During the double materiality process, we consulted 346 stakeholders worldwide." Engagement channels named: monthly Executive Committee ESG discussions; an annual employee satisfaction survey (all countries); customer ESG questionnaires and assessment bodies; twice-yearly investor/analyst presentations and annual bilateral bank meetings (loans carry ESG-linked bonuses); membership of professional/ESG working groups; and outreach to scientific institutes on environmental issues.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities
Reference: pages 75-81.
The double materiality exercise "identified 81 IROs and retained 25 covering 15 issues and 8 ESRS" (E1, E2, E3, E4, E5, S1, S4, G1 - S2 and S3 are not among them). Each of the 25 rows in the SBM-3 table carries an explicit risk/opportunity/impact type and horizon, e.g. "Downstream Scope 3 GHG emissions" (short-term negative impact, E1), "Corruption, fraud and unfair competition" (short-term negative impact, G1). A value-chain diagram maps each IRO to upstream, operations or downstream.
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Process to identify and assess material IROs
Reference: page 82.
The process "complies with EFRAG recommendations and in particular ESRS 1 - Chapter 3 and ESRS 2 paragraph 53," starting from ESRS 1 Appendix A AR16 topics supplemented by industry/competitive benchmarks and external references (UN, Paris Agreement, Common Agricultural Policy). "We identified 81 IROs and retained 25." Because the Group's three business sectors share some risks but differ in others, "the identification and rating work was carried out at the level of each company," producing a double materiality matrix per company that is then consolidated at Group level (weighted by turnover for financial materiality; unweighted for impact materiality, threshold: score strictly greater than 9).
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation and adaptation
Reference: pages 88-91.
The Group states it already has "identified decarbonisation levers... a qualitative identification of our locked emissions; a governance that approves the project; resources dedicated to the transition; intermediate targets," but explicitly lacks "a shared GHG reduction target trajectory and scenario analyses." The Board's goal is "a decarbonization trajectory aligned with the 1.5°C objectives of the Paris Agreement." 85% of emissions arise from product use (Scope 3 Cat. 11); own operations (Scopes 1+2) are 1%. Overall decarbonization potential is "estimated at between 4% and 40%," to be refined via 2025-2026 workshops. The plan states plainly: "the Company does not include carbon absorption projects in its plan, and does not currently use internal carbon pricing."
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 SBM-3 (pages 76-77) and the E1 transition plan section (page 89); this disclosure requirement did not exist under the 2023 ESRS the report was prepared against, and the report states no scenario analysis was carried out.
The SBM-3 table classifies climate IROs by type: physical risk ("Consequences of physical climate risks on assets, production, employees and suppliers," medium-term risk, citing the 2024 Valencia floods' effect on rail manufacturer Stadler's supply chain) and transition-linked impacts (upstream and downstream Scope 3 emissions, both short-term negative impacts). The transition-plan section confirms exposure was assessed at both own-operations and value-chain level ("Physical and transitional IROs were also identified as significant"), but states explicitly that the plan is presented "with the exception of... scenario analyses," so no named climate scenario, temperature projection or scope-of-analysis is disclosed.
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from ESRS 2 SBM-3 and E1 Policy 1 "Adapt to the consequences of global warming" (pages 92-93); this disclosure requirement did not exist under the 2023 ESRS the report was prepared against, and no formal ESRS-defined resilience analysis is described.
Adaptive-capacity actions are disclosed instead: renegotiated insurance coverage ("an increase in the contractual indemnity limit of €20 million"), an inventory of business continuity plans backed by a new "Risk Management" commission, and reliance on "diversification of its activities, customers and suppliers to mitigate" downstream climate risk. Site-level prevention assessments "will begin at three sites in 2026." No quantified financial flexibility or asset-redeployment analysis is given.
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: pages 88, 92.
Policy 1, "Adapt to the consequences of global warming," targets physical-risk resilience through insurance and business continuity planning. Mitigation policy runs through Policies 2 and 4: a three-stage energy-transition approach for products ("optimizing energy consumption... introducing hybrid energy sources... developing alternatives to fossil fuels") and, for manufacturing, "optimizing energy consumption at our sites; increasing the share of renewable or low-carbon energy consumed," aligned with ISO 14001/50001 and the European Green Deal.
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 92-93, 96-97, 102-104.
Adaptation: broker change to an international insurer, site-by-site prevention audits, and a harmonization drive for business continuity plans. Mitigation: the TRAXX autonomous straddle carrier and hybridization R&D for agricultural equipment; HVO trials replacing diesel at AGRIFAC; electrification and PRiNTEC printing-based paint application at SAMES; LED lighting rollout, photovoltaic panels at G.F. (Italy) and AGRIFAC (Netherlands), heat recovery at TRICOFLEX, and a laser-cutting upgrade at HARDI Denmark ("almost 20% reduction in electricity consumption").
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 95, 97, 102-104.
No single consolidated Group GHG target exists ("A consolidated objective at Group level has not yet been defined"), but several intermediate, dated targets are given: VOC emission reduction from new industrial-spraying products, 40% (2024-2025) rising to "up to 100%" by 2029-2030; average GHG saving per machine replaced, from three technology axes, targeting 11% (energy optimization), 18% (hybridization) and 24% (fossil-fuel alternatives) by 2029-2030; and upstream Scope 3 GHG emissions from garden/hose raw materials and packaging, -47% (2024-2025) against a -56% target by 2029-2030, both versus a 2021-2022 baseline.
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: page 91.
Total energy consumption for 2024-2025 (LHV, MWh basis, reported in KWh/L rows): fuel from crude oil/petroleum products 2,331,396 L (27,969,900 KWh HHV); other fossil fuels 5,310,381 KWh; purchased electricity/heat/steam/cooling from the grid 36,991,234 KWh; renewable fuels including biomass and hydrogen 1,106,271 KWh; purchased renewable electricity/heat/steam/cooling 5,564,031 KWh; self-generated non-fuel renewable energy 495,576 KWh. Coal consumption is nil. Figures are given alongside a 2021-2022 comparison column.
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 90-91.
2024-2025 Group totals (metric tons CO2e): Scope 1 = 12,456; Scope 2 market-based = 10,331; Scope 3 = 1,082,977 (dominated by Category 11, use of products sold, at 994,125); Total GHG (market-based) = 1,105,763. A per-activity breakdown is given (e.g. Agricultural Equipment Scope 3 = 970,431; Industry = 108,158). Comparable 2021-2022 reference-year figures are shown alongside (Scope 1 = 15,136; Total = 2,247,185), reflecting a change in methodology and Group scope (two companies added).
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
GHG removals and GHG mitigation projects financed through carbon credits
Reference: page 89.
Nil disclosure, stated plainly: "the Company does not include carbon absorption projects in its plan." No GHG removals, carbon-credit-financed mitigation projects, or planned use of such instruments are described anywhere in the climate chapter.
E1-10(was E1-8)Internal carbon pricingReported
Internal carbon pricing
Reference: page 89.
Nil disclosure, stated plainly in the same sentence as E1-7: the Group "does not currently use internal carbon pricing." No shadow price, internal levy or carbon fee scheme is described.
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunitiesReported
Anticipated financial effects from climate-related risks and opportunities
Reference: page 65.
Disclosed in aggregated, not topic-by-topic, form: "In accordance with Appendix C of ESRS 1 and the 'Quick Fix' delegated act, the anticipated financial effects are not published in detail and are aggregated for all our environmental policies," citing "the strategic sensitivity of the data" and estimation uncertainty ("technical options are not clear-cut" and limited cost-accounting granularity). No monetary range, by acute/chronic physical risk or transition risk, is disclosed for climate specifically.
E2 – Pollution
E2-1Policies related to pollutionReported
Policies related to pollution
Reference: pages 93-95.
Sub-policy "Reduce input consumption," explicitly tagged (E1; E2; E4), targets pollution linked to product use: "reducing the risks of water, air or soil pollution, and of negative impacts on biodiversity," driven by the Group's "right dose in the right place at the right time" precision-application philosophy across Agricultural Spraying, Industrial Spraying and gardening.
E2-2Actions and resources related to pollutionReported
Actions and resources related to pollution
Reference: pages 93-95.
Product-level actions listed under "Input reduction initiatives": nozzle-by-nozzle dose modulation (BERTHOUD Spraytronic, TECNOMA, EVRARD, AGRIFAC, HARDI, APACHE ranges saving "between 40% and 60%" of product depending on use); GEOSELECT drone-guided precision spraying (up to 60% input reduction); the 3S camera-guided spot-spraying sensor (up to 80% reduction); and, for Industrial Spraying, transfer-efficiency paint equipment (Xcite, K3, Airless/Airmix) and the PRiNTEC printing process aimed at zero VOC loss.
E2-3Targets related to pollutionReported
Targets related to pollution
Reference: page 95.
"In Industrial Spraying, the Group aims to provide its customers with products that reduce VOC emissions by 40% to 100% by 2030." Achieved figure for 2024-2025 is 40% (average VOC reduction of new products versus the ranges they replace). For Agricultural Spraying input reduction, the report states plainly: "we are unable to set any targets at present," due to the absence of a standardized, multi-product measurement protocol; workshops to build one are planned for 2026.
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunitiesReported
Anticipated financial effects from pollution-related impacts, risks and opportunities
Reference: page 65.
Covered by the same aggregated disclosure as E1-9: financial effects "are not published in detail and are aggregated for all our environmental policies," under the ESRS 1 Appendix C / Quick Fix relief, citing data sensitivity and estimation uncertainty. No pollution-specific monetary figure is separately disclosed.
E3 – Water
E3-1Policies related to water and marine resourcesReported
Policies related to water and marine resources
Reference: pages 96-97.
Sub-policy "Control water consumption" addresses "IROs relating to the negative impact of water consumption associated with product use, the potential risk of more stringent regulations, and rising water costs," noting that agricultural spraying's water use is dominated by watering rather than phytosanitary product spraying itself, and that "controlling the amount of water used is a material matter for the Garden Watering activity."
E3-2Actions and resources related to water and marine resourcesReported
Actions and resources related to water and marine resources
Reference: page 97.
Actions are product-focused: solar-powered drip irrigation controllers ("AQUATIME Solar UNO.3 Kit... drip-feeds up to 20 vases or zones directly at the root, leading to water savings of up to 70% compared with conventional systems"), modular underground irrigation systems with rain sensors, and variable-flow multi-jet spray guns for flower beds.
E3-5Anticipated financial effects from water and marine resources-related impacts, risks and opportunitiesReported
Anticipated financial effects from water and marine resources-related impacts, risks and opportunities
Reference: page 65.
Covered by the aggregated environmental financial-effects disclosure under ESRS 1 Appendix C / the Quick Fix relief (see E1-9); no water-specific monetary figure is separately given. The IRO table does describe the risk qualitatively: "Declining demand for irrigation products due to rising costs and restricted water consumption" could reduce revenue from customers in the agricultural and gardening sectors (page 77).
E4 – Biodiversity and Ecosystems
E4-2Policies related to biodiversity and ecosystemsReported
Policies related to biodiversity and ecosystems
Reference: pages 93-95.
The sub-policy "Reduce input consumption," explicitly tagged (E1; E2; E4), states its purpose includes "reducing the risks of water, air or soil pollution, and of negative impacts on biodiversity" through precision-application technologies that limit "the infiltration of active substances into the environment and their associated negative effects."
E4-3Actions and resources related to biodiversity and ecosystemsReported
Actions and resources related to biodiversity and ecosystems
Reference: pages 93-95.
The same product actions that address E2 pollution are described as addressing biodiversity: nozzle-by-nozzle dose modulation across the BERTHOUD, TECNOMA, EVRARD, AGRIFAC and HARDI ranges, the GEOSELECT drone-guided and 3S camera-guided spot-spraying systems (up to 80% reduction in phytosanitary volumes applied), and the TRAXX mechanical weeding robot, which "aims to work the soil mechanically and thus completely replace the use of herbicides," reducing pesticide-driven biodiversity loss described in the SBM-3 table.
E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunitiesReported
Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities
Reference: page 65.
Covered by the aggregated environmental financial-effects disclosure under ESRS 1 Appendix C / the Quick Fix relief (see E1-9); no biodiversity-specific monetary figure is separately given.
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: pages 98-99.
Policy 3, "Circular Economy," is described as "a key strategic lever for reducing dependence on certain raw materials and creating a business model capable of cushioning the cycles of the agricultural and automotive markets," structured around three sub-policies: increasing recycled material content, designing repairable/longer-lasting products, and processing end-of-life waste. It applies to all Group activities and is aligned with the AGEC law and LNE recycled-content certification.
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: pages 99-101.
TRICOFLEX invested in extruders to combine virgin/recycled PVC with industrial waste (e.g. swimming-pool liner offcuts); the RECO range ("over 70% recycled plastic") and FOR OCEAN collection ("between 50% and 80% recycled Ocean-Bound Plastic," with #Tide Ocean Material) are cited by name. After-sales/circular-economy actions include preventive maintenance, remanufacturing/reconditioning, retrofitting, and a 2025 partnership between HOZELOCK EXEL, TRICOFLEX and an eco-organization to build a dedicated recycling loop for post-consumption PVC hoses.
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: pages 99, 101.
Three dated targets: TRICOFLEX to redesign 100% of existing products with at least 50% recycled plastic by 2027-2028 (33% achieved in 2024-2025); garden/hose activities to reach 59% recycled PVC content by 2029-2030 (33% achieved, up from 12% at 2021-2022 baseline); and after-sales activities to reach 28-30% of Group turnover by 2030/2034-2035 (17.5% achieved in 2024-2025, versus 18% in 2023-2024).
E5-4Resource inflowsReported
Resource inflows
Reference: page 99.
Two indicators are tracked: the share of existing TRICOFLEX product ranges redesigned with at least 50% recycled plastic (33% in 2024-2025), and the rate of recycled plastic (PVC, PP, ABS) incorporated into finished products across the garden and hose manufacturing activities, also 33% in 2024-2025 versus a 12% reference-year figure. Named product examples carry higher recycled shares: the RECO range ("over 70% recycled plastic") and TRICOGREEN hoses ("80% recycled plastics," LNE-certified).
E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunitiesReported
Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Reference: page 65.
Covered by the aggregated environmental financial-effects disclosure under ESRS 1 Appendix C / the Quick Fix relief (see E1-9); no circular-economy-specific monetary figure is separately given.
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 105-107.
Policy 5, "A responsible and rewarding employer," is built on three pillars: employee safety ("active prevention of workplace accidents and the fight against occupational diseases"), attracting and retaining talent (skills, training, diversity and equal opportunity), and well-being at work. The Group runs a decentralized model: each company adapts initiatives to local law and context within a shared Group framework communicated through HR departments.
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workforce
Reference: pages 74, 112-113.
A global social barometer, "EXEL mood," launched June 2024 with 19 questions across six themes plus an Employee Net Promoter Score; the June 2025 re-run reached an 80% participation rate (up 11 points). Results feed entity-level action plans. Separately, SBM-2 records "employee representatives" as a consulted stakeholder group via the double-materiality interviews/questionnaires (page 74).
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Remediation processes and channels for own workforce
Reference: pages 116-117.
The Group's ethics whistle-blowing system, open to "Group employees and third parties," is reachable via a dedicated "Ethics Hotline" e-mail or the Legal Cluster intranet tool, both routed solely to the Ethics Committee. Its use "is not compulsory": the primary channel is the line manager (unless implicated), then the company's HR Department or the Group HR Director, with all channels set out in the Code of Conduct.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 107-112.
Safety: ten Group-wide "golden rules," "Flash accidents" incident-sharing via Teams, quarterly Safety Commission meetings, and "Safety Days" at every site. Attraction/retention: an HR Commission meeting three times a year, a 2025-launched HR chatbot pilot for onboarding, and the 25-year-running "EXEL Academy" manager-training program. Well-being: the EXEL mood barometer feeding local action plans, and ergonomics/psychosocial-risk initiatives chosen per entity.
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 108, 111.
Frequency Rate 1 (lost-time accidents per million hours): target 7 by 2026-2027 (8.7 achieved in 2024-2025, down from 11.7 in 2022-2023). Turnover rate: target 11% by 2026-2027 (12.3% achieved). Absenteeism: target to hold at roughly 3% through 2026-2027 (3.1% achieved). Gender diversity: 25% women Group-wide and among managers by 2029-2030 (21% and 19% achieved respectively), 18% on Executive Committees (12% achieved).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 105-106.
Total headcount 3,962 as of September 30, 2025 (806 women, 3,156 men), broken down across ten geographic areas (e.g. France 1,664; Western Europe 1,008; North America 284; Asia 92). The table also reports part-time employee counts (183 Group-wide) and full-time-equivalent detail by region.
S1-6(was S1-7)Characteristics of non-employee workersReported
Characteristics of non-employee workers
Reference: page 106.
The headcount table includes a "Number of temporary workers" column alongside the employee breakdown, reporting 111 temporary workers Group-wide as of September 30, 2025 (e.g. 39 in France, 69 in Western Europe), covering fixed-term, apprentice and open-ended-adjacent categories as defined in the headcount note.
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: pages 108, 111.
Gender diversity is tracked at three hierarchical levels: overall workforce (21% women in 2024-2025, target 25% by 2029-2030), managers (19%, same 25% target), and Executive Committee (12%, target 18% by 2029-2030, and "at least 25%... in the longer term"). No age-band distribution or persons-with-disabilities breakdown is given alongside the gender data.
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: page 111.
Stated as a compliance confirmation rather than a percentage: "At the Group, all employees receive remuneration in line with the legal thresholds in force in the countries where they are employed, in compliance with local minimum wage legislation." No separate adequate-wage benchmark distinct from statutory minimum wage is described.
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: page 108.
Frequency Rate 1 (lost-time accidents per million hours worked): 8.7 in 2024-2025, down from 9 in 2023-2024 and 11.7 in 2022-2023, against a 7 target for 2026-2027. Underlying accident count fell "from 81 in 2023-2024 to 61 in 2024-2025."
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 113, 115, 120-121.
Policy 6, "Improve the health and safety of users," targets ergonomics and reduced contact with hazardous substances during product use. Policy 7's personal-data sub-policy commits to "ensure the protection of personal data" for equipment users, underpinned by a privacy policy, cookie policy and GDPR-compliant contract clauses that each Group entity is required to publish.
S4-2Processes for engaging with consumers and end-users about impactsReported
Processes for engaging with consumers and end-users
Reference: page 74.
The SBM-2 stakeholder section states: "some of our customers have drawn up ESG questionnaires in order to assess us, or ask us to go through assessment bodies in order to evaluate our ESG policy," and that the Group "provide[s] customers with products that enable them to reduce their environmental footprint and are safe to use." No dedicated end-user consultation process beyond this is described.
S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concernsReported
Remediation processes and channels for consumers and end-users
Reference: pages 113-114, 121.
For product safety: a customer-complaints channel, though the report admits "with the exception of the spraying companies located in France and of the gardening business, we do not keep a separate record of claims relating to health and safety." For data protection: the dedicated address privacy@exel-industries.com for data-subject rights requests and breach reports, published in contracts and privacy policies.
S4-3(was S4-4)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 actionsReported
Taking action on material impacts on consumers and end-users
Reference: pages 113-114, 119-122.
Product safety actions: pressurized, filtered cabs on spraying equipment; ventilated automatic paint-robot cabins removing operators from VOC exposure; ergonomic redesign (hydraulic/mechanical coupling simplification) and user training/PPE guidance. Data protection actions: a Group-wide GDPR program (processing register via the Adequacy tool, breach-management and rights-request procedures, standard contract clauses), with "no personal data breaches... reported to the Group Legal Department" and "no significant fines" in 2024-2025.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to consumers and end-users
Reference: pages 114, 122.
For product-safety complaints, no target is yet set: "To date, no target has been set, mainly due to the absence of historical benchmarks"; 144 complaints were logged in 2024-2025. For personal data protection, a dated target exists: 100% roll-out of the GDPR program by 2030, tracked via GDPR Committee attendance (46% achieved in 2024-2025 against a 40% objective) and reported personal data breaches (zero in 2024-2025).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 115-117.
The Code of Conduct (originally a 2017 Code of Good Conduct and 2021 Ethics Charter) "formalizes EXEL Industries' zero-tolerance policy towards corruption," was approved by the Board, and covers "workplace inclusion, human rights, the environment, integrity... insider trading," plus an International Sanctions Compliance Policy, Gifts Policy and Insider Trading Prevention Policy. Governance runs through the Board, CSR Committee and Group Legal Department, with an Ethics Committee of three permanent members (CEO, HR Director, Chief Legal Officer).
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers
Reference: page 123.
The Group adheres to the French "Responsible Supplier Relations" Charter (Mediateur des Entreprises / Conseil National des Achats, 3,000+ signatories) and its ten commitments. General Conditions of Purchase carry an ethics/anti-corruption clause referencing the Code of Conduct; suppliers are screened via purchasing software and third-party due diligence. Three subsidiaries (SAMES, EXXACT ROBOTICS, HOZELOCK EXEL) have their own Responsible Purchasing Charter; a Group-wide multi-year roll-out is planned.
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: pages 116-118.
A corruption risk-mapping exercise, aligned with French Anti-Corruption Agency (AFA) guidelines, "identified 38 corruption scenarios and three functions most exposed to corruption risks: Sales, Purchasing and Alliances & Partnerships." Controls include the Code of Conduct (94% of employees had signed it, 54% trained on it in 2024-2025), an Ethics Hotline, an internal-audit team of two Legal Department auditors, and Compliance Committee meetings of all entity Ethics Officers.
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Reference: pages 118-119. Prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a standalone DR.
Four dated MDR-T-style targets/results: business-conduct documents drafted, 100% (achieved, 2024-2025); people trained by the Group Legal Department, 100% target for 2025-2026; employees trained on the Code of Conduct, 54% achieved in 2024-2025 against a 50% objective, rising to 100% by 2029-2030; employees who signed the Code of Conduct, 94% achieved against a 90% objective, rising to 100% by 2029-2030.
G1-6Payment practicesReported
Payment practices
Reference: page 123.
"The Group's General Conditions of Purchase provide for payment terms of '45 days from the end of the month.' All local terms and conditions must be aligned with this standard, or with a local standard if it is more favorable." No average actual payment time, percentage of on-time payments, or outstanding legal proceedings for late payment is separately quantified.