Exosens

France|Electro-optical detection, imaging and amplification technology (optronics)|FY2025|Auditor: PricewaterhouseCoopers Audit and Baker Tilly Strego|View original report →

Sustainability statement, in full

The complete text of Exosens’s FY2025 sustainability statement is held here – 120 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 bodies
Reported

Governance roles

Reference: pages 50-52.

At 31 December 2025 the Board of Directors comprised eight full members and one non-voting member; it "does not have employee representation, as the thresholds for such representation have not been met" (p.50). Four of eight directors are women (50%) and four are independent (50%) under the AFEP-MEDEF Code (p.51).

Sustainability expertise: a self-assessed table rates each Board member's skills in social/human resources, ethics and business conduct, corporate governance and climate change (p.50). In June 2025 the Board received CSRD training, and Audit Committee members received European Taxonomy training in October 2025 (p.50).

Committee structure: the Board is supported by the Audit Committee, the Appointments and Remuneration Committee and the CSR Committee, each composed largely of independent directors; at 31 December 2025 the CSR Committee was chaired by Wendy Kool-Foulon and the Audit Committee by Brigitte Geny, both independent directors (p.51).

Allocation of responsibility (pp.51-52): the CSR Department, led since 2023 on strategy development, reports regularly to the CSR Committee and Audit Committee; Quynh-Boï Demey (CFO) oversees the CSR team. A CSR Steering Committee of four Executive Committee members meets monthly.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

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

Reference: page 53.

The CSR Committee met three times in 2025, including once specifically to review the 2024 sustainability report; the Audit Committee and the Appointments and Remuneration Committee also met several times on non-financial reporting matters (p.53).

A table of 2025 committee meetings lists the material IROs addressed by date and body (p.53), including: presentation of the Group CSR strategy 2026-2027 to the Board (June 2025) and CSR Committee (October 2025); presentation of European Taxonomy eligibility/alignment analysis to the Audit Committee (October 2025); presentation of the Group Compliance Programme to the Board (December 2025); presentation of the gender balance and equal pay policy to the Board (December 2025); presentation of the 2024 carbon footprint baseline to the CSR Committee (March 2025); and presentation of the Transition Plan and the business continuity plan to the Board and Audit Committee respectively (December 2025).

Committee chairs "systematically pass on decisions and meeting reports to the Board of Directors after each meeting" (p.53).

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Integration of sustainability-related performance in incentive schemes

Reference: pages 53-54.

Since 2024 the CEO's performance-related remuneration includes a CSR-linked component, with arrangements validated by the Board following proposals from the Appointments and Remuneration Committee (p.53).

"For 2025, 15% of the variable annual remuneration of the company's Chief Executive Officer will be based on three equally weighted quantitative objectives addressing different Group targets" (p.53): (1) improve the Group's environmental performance, measured by an EcoVadis gold medal (achieved); (2) improve engagement and well-being at work, measured by the eNPS methodology (target: +4 points vs. 2024); (3) prevent ethical risks in the value chain, measured by third-party assessment coverage of 90% of suppliers/customers and 100% of agents/distributors (p.54).

The remuneration link is to overall environmental/CSR performance (EcoVadis rating) rather than to a GHG-specific metric.

GOV-3(was GOV-4)Statement on due diligence
Reported

Statement on due diligence

Reference: pages 54-55.

Due diligence is described as "a systematic, integrated process that enables the Group to identify, assess, prevent and mitigate the negative impacts of its activities on human rights, the environment and society" (p.54).

A table maps the core elements of due diligence to sections of the sustainability statement (p.54): embedding due diligence in governance/strategy/business model references Sections 2.1.8 (SBM-1), 2.1.3 (GOV-1) and 2.1.4 (GOV-2). The report states the Group "is conducting a thorough analysis of its impacts, risks and opportunities and is developing specific mitigation measures," aiming "to gradually introduce rigorous monitoring and control processes to ensure that its actions are effective" (p.54).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls over sustainability reporting

Reference: page 55.

In its second reporting year, EXOSENS "significantly improved its processes for collecting non-financial data and adopted a dedicated, formal non-financial reporting procedure that sets out in detail the scopes, roles, responsibilities, methodologies and tools for collecting ESG data" (p.55).

The system covers a formal reporting scope, a qualitative-information method based on MDR-P/MDR-A/MDR-T, defined roles across CSR, HR, Purchasing and Internal Audit, and dedicated collection tools (p.55). Risks are assessed on a gross basis via the Finance and Administration Department's major-risk map (reviewed annually since 2023) alongside the CSR Department's double materiality exercise.

Main risks identified: "the quality and reliability of the data collected, the consistency of information between entities and periods, and the risk of non-compliance with CSRD and ESRS requirements" (p.55). The internal control system for non-financial reporting "is under development" (p.55), with a self-assessment described in Section 4.2. Results are reviewed by the CSR Committee and Audit Committee before Board approval; the Audit Committee meets "at least twice a year" (p.55).

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Reference: pages 56-58.

EXOSENS is "a high-tech company specialising in the design, manufacture and marketing of electro-optical technologies in the fields of amplification, detection and imaging," serving defense and surveillance, life sciences and the environment, industrial control, and nuclear power (p.56).

Revenue by segment (2025, EUR millions, p.57): Amplification 319.2; Detection & Imaging 150.5; total revenue 468.2, of which 454.9 within the sustainability statement scope. Total employees: 1,679 (p.56). The Group holds production and R&D sites in Europe, North America, Asia and the Middle East.

Upstream value chain: direct and indirect suppliers of components, glass and raw materials; a dual-sourcing process limits supplier-failure risk (p.57). "EXOSENS has no contact with the indirect suppliers belonging to its extended supply chain" (p.57).

Downstream: products sold to OEM customers who integrate them into end systems (p.56-57). EXOSENS won the EcoVadis gold medal in November 2025, "among the 5% most highly rated companies in the EcoVadis database" (p.57). "At this stage, EXOSENS does not have formal sustainability targets for significant groups of products and services, customer categories, geographical areas" (p.57).

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Reference: pages 58-59.

A stakeholder-engagement table (pp.58-59) lists engagement methods, interests and Group responses for: employees (internal Reveal platform, engagement surveys - work-life balance, training); financial partners (roadshows, investor conferences - financial performance, non-financial risk); direct customers/end users (satisfaction surveys, trade fairs - reliable products, ESG transparency); direct suppliers (tenders, on-site audits - fair relationships, ESG criteria); indirect suppliers (monitored via direct suppliers); agents and distributors (subject to third-party assessment); civil society; technological/scientific partners; and professional federations (EXOSENS "takes part in GICAT's CSR Committee").

During the materiality process the Group interviewed roughly 30 internal and external stakeholders (p.59, cross-referring to IRO-1). Twenty employee interviews found that "employee protection and the human element in general are at the heart of the Group's values" (p.59). Customer/end-user interviews ranked climate, industrial data cybersecurity, eco-design, diversity/inclusion and ethics as priorities (p.59).

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

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

Reference: pages 59-64.

"The material topical ESRSs are listed below: Climate change (E1), Resource use and circular economy (E5), Workforce (S1), Workers in the value chain (S2) and Business conduct (G1)." The Group also identified specific material information on protection of industrial data and responsible positioning within society (p.59).

The double materiality assessment identified 18 impacts, risks and opportunities (SBM-3 table, pp.59-61): 7 under E1, 1 under E5 (eco-design opportunity), 5 under S1, 2 under S2, 1 under G1 (corruption risk) and 2 entity-specific (positive impact from scientific/nuclear/medical research; industrial-data cyberattack risk).

"To date, the Group has not identified any current financial impact on its financial situation, financial results and cash flows from these material IROs" (p.61).

Resilience: "The Group has not yet carried out a formal qualitative analysis of the resilience of its strategy and business model... In 2025, however, the Group worked towards the publication of an initial transition plan. The resilience analysis will supplement that plan in the years to come" (p.61). Also presented under E1-3-Resilience.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

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

Reference: pages 61-64.

EXOSENS's double materiality process was introduced for CSRD in 2023, building on an existing 2023 CSR strategy. "With respect to FY25, the Group did not fully revise its double materiality assessment," instead reviewing the continued relevance of the FY24 IROs in light of new acquisitions and geography; the review "did not identify any material change" (p.62). The adequate-wages sub-topic was recharacterised in 2025 (see S1-10).

Process (2.1.11.1, p.62-63): a cross-functional Project Committee (finance, operations, strategy, purchasing, environment, HR, quality), supported by external consultants, ran an internal practice review, a peer/sector benchmark, and impact/financial materiality scoring by around 30 internal and external stakeholders, reviewed against all ESRS 1 AR16 topics.

"So far, none of these issues have highlighted any connection with the disclosure standards related to biodiversity and ecosystems (ESRS E4) or consumers and end users (ESRS S4)" (p.63); the small product size and low raw-material use limit biodiversity impact (p.63).

Assessment method (2.1.11.2, p.63-64): financial materiality is rated as severity (1-4) x likelihood on a gross basis (excluding controls); impact materiality follows the same severity/likelihood logic for negative and positive impacts.

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

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

Reference: pages 44-45, 116-126 (Annex 1: ESRS 2 IRO 2 tables).

Annex 1 lists, with cross-references to other Universal Registration Document sections, every disclosure requirement EXOSENS covers: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 (E1-1 to E1-6 only), E5 (E5-1 to E5-4 only), S1 (S1-1 to S1-6, S1-8, S1-9, S1-11, S1-14, S1-16, S1-17), S2 (S2-1 to S2-5) and G1 (G1-1 to G1-4). E2, E3, E4, S3 and S4 do not appear in the index, consistent with the SBM-3 materiality list.

A second table (pp.121-125, Annex B-style) cross-references ESRS datapoints that also derive from SFDR/Pillar 3/Benchmark Regulation/European Climate Law. Datapoints under E2-4, E3-1, E3-4, the ESRS 2 IRO-1 E4 items, S3-1, S3-4 and S4-1/S4-4 are marked "Non-material," consistent with the topic-level materiality conclusion; the E5-5 non-recycled and hazardous/radioactive waste datapoints are marked "Not applicable."

Phase-in: "In accordance with the 'Quick Fix' Delegated Regulation (EU) 2025/1416 adopted by the European Commission on 11 July 2025, the EXOSENS group has applied the transitional measures provided for in relation to 2025. Accordingly, indicators relating to early financial effects, along with certain disclosures relating to ESRS E1, E5, S1 and S2 are not presented in this report" (p.44). No specific datapoint list accompanies this statement.

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Reference: pages 69-70.

"In 2025, the Group worked on a transition plan, which is still being drafted" (p.69). Short-term (2030) and long-term (2050) targets are set out by scope: Scope 1&2 (market-based) -42% by 2030 from a 2024 baseline and -90% by 2050; Scope 3 -25% to -35% by 2030 across categories (purchased goods/services via SBTi supplier engagement covering 60% of emissions; non-current assets; fuel/energy-related activities; upstream transport/distribution; business travel; employee commuting) and -90% by 2050.

"The plan will be developed to make it consistent with regulatory requirements in 2026, particularly regarding the action plan to achieve medium-term Scope 3 targets, which was missing from the 2025 exercise" (p.69). The plan "forms part of a scenario aligned with the Paris Agreements... and with the recommendations of the Science Based Targets initiative" (p.69).

Governance: the Executive Committee approves transition-plan implementation; the CSR Committee examines the strategy and monitors implementation, reporting regularly to the Board (p.70).

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Policies related to climate change mitigation and adaptation

Reference: pages 67-69.

The Group's environmental policy aims "to operate in a responsible and sustainable way, minimising the environmental impacts of its activities while ensuring regulatory compliance and continually improving its environmental performance" (p.68), covering GHG emissions, water, energy and waste. It addresses the actual impacts (raw-material transport, product distribution, production/assembly energy consumption) and risks (GHG regulation, energy-price volatility, supplier environmental-maturity dependence, and inadequate energy recovery/recycling) identified in the DMA (p.68).

Developed by the CSR Department, the policy covers the full value chain including Scope 3 and use of sold products, and applies to all Group sites; EXOSENS "is committed to complying with the United Nations Global Compact" (p.68-69).

A dedicated carbon-footprint data collection procedure defines the organisational scope for calculating the annual footprint (Scope 1, 2 and certain Scope 3 categories), with data collected by sites, the purchasing team and business units, and the footprint calculated by an external consultant (p.69).

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Actions and resources in relation to climate change policies

Reference: pages 70-71.

Scope 1&2 action plans for the Group's most emissions-significant sites, defined 2024-2025, use four methods (p.70): (1) energy efficiency (HVAC optimisation, heat recovery, building-envelope upgrades); (2) reduced energy consumption (LED lighting with sensors, automated scheduling); (3) reduced heating emissions (e.g. the geothermal project at Photonis France, mainly Scope 1); (4) renewable energy (green electricity with guarantees of origin, photovoltaic panels at some sites).

A chart quantifies projected Scope 1&2 changes 2024-2030 (tCO2e) by method: business growth (+104), heating decarbonisation (-476), energy efficiency (-107), reduced consumption (-25), renewables (-798), taking 2,936 tCO2e (2024) to 1,634 tCO2e (2030) (p.70).

Scope 3: "targets have been defined on the basis of internal work to identify reduction methods. These methods will be formalised and related action plans will be drafted in 2026" (p.71); the Supplier Code of Conduct, rolled out since 2024, targets supplier environmental-maturity risk.

Financial planning (p.71): Scope 1&2 CapEx ~EUR 6.2m by 2030; OpEx for renewable-energy guarantees of origin EUR 30,000/year (est. gains EUR 500,000/year). Scope 3 supplier-engagement CapEx EUR 50,000 by 2040, OpEx EUR 140,000/year; other Scope 3 action costs await 2026 plans.

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Targets related to climate change mitigation and adaptation

Reference: pages 71-72.

EXOSENS signed the SBTi commitment letter in January 2024 and in 2025 "completed the second stage, i.e. the definition of decarbonisation objectives in line with the methodology, for Scopes 1, 2 and 3 and for both the short term (2030) and the long term (2050)"; validation submission is planned for 2026 (p.71).

Short-term targets (2024 baseline to 2030, p.71-72): Scope 1&2 (market-based) -42%, 100% coverage, baseline 2,936 tCO2e, 2025 2,587 tCO2e (-12%); Scope 3 (market-based) 67% coverage overall - purchased goods/services -60% supplier-engagement coverage (baseline 24,214, 2025 28,578, +18%); fuel/energy-related activities -35% (baseline 6,782, 2025 6,838); upstream transport/distribution -35%; business travel -25% (baseline 1,441, 2025 1,422); employee commuting also tracked.

Long-term targets: Scope 1&2 and Scope 3 both -90% by 2050 from the 2024 baseline (2,936 / 23,586 tCO2e), using the SBTi absolute contraction approach aligned to 1.5C (Scope 1&2, long-term Scope 3) and Well Below 2C (medium-term Scope 3) (p.72).

2024 was chosen as baseline because it reflects the post-IPO structure (listed 7 June 2024); IPO-related service emissions were excluded "to avoid having an artificially high figure" (p.72).

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: pages 73-74.

Energy consumption and mix table (2024 vs 2025, MWh, p.73): fossil fuel/electricity consumption fell from 8,950 (29%) to 7,042 MWh (23%); nuclear-source consumption fell from 826 (3%) to 750 MWh (2%); renewable electricity consumption rose from 20,750 (68%) to 22,271 MWh (74%). Total energy consumption fell slightly from 30,527 to 30,063 MWh. EXOSENS "has considered energy to be renewable only when its origin is clearly defined in the suppliers' contracts (guarantees of origin contracts)" (p.73); on-site renewable generation, purchased steam/heat and hydrogen purchases "do not apply to EXOSENS."

High-climate-impact-sector intensity (2.2.5.2, p.73-74): nine of twelve in-scope entities operate under NACE codes 26.11, 26.51, 27.90 and 27.11 (high climate impact), accounting for over 95% of Group energy consumption and revenue. Energy intensity per EUR million of consolidated revenue for high-impact-sector activities was 80 MWh/EUR m in 2024 and 64 MWh/EUR m in 2025; against revenue within the sustainability-statement scope, 81 and 66.1 MWh/EUR m respectively (p.74).

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 74-75.

Methodology follows the GHG Protocol Corporate Standard; emission factors from ADEME (2025 update), refined for purchases/transport via Ecoinvent/GLEC and electricity via IEA 2023 (p.74-75).

2025 GHG emissions (tCO2eq, vs 2024 adjusted, p.75): Scope 1: 1,182 (down 24%); Scope 2 location-based: 4,198 (+1%); Scope 2 market-based: 1,405 (+2%, 73% from contractual instruments); Scope 3 location-based: 28,547 (+14%); Scope 3 market-based: 28,578 (+14%), driven by purchased goods/services (6,838), capital goods (4,460, +72%), use of sold products (11,168, +35%) and end-of-life treatment (175, +54%).

Totals: location-based 33,926 tCO2eq (+10%); market-based 31,164 tCO2eq (+11%). Carbon intensity (market-based) improved from 235.7 to 209.9 tCO2eq per EUR million adjusted EBITDA (-11%), as adjusted EBITDA rose from EUR 119.2m to EUR 148.5m (p.75). Methodological exclusions: biomass combustion, land-use-change emissions, emissions trading systems, and carbon-credit purchases "do not apply to EXOSENS" (p.75).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Omitted
E1-10(was E1-8)Internal carbon pricing
Omitted
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 / the E1 climate-DMA section, disclosed in the FY2025 report (Section 2.2.1, page 66). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk: "the Group used scenarios SSP5-8.5 ('Fossil-fueled development') and SSP2-4.5 ('Middle of the road'). Scenario SSP5-8.5, regarded as a high-emissions scenario, anticipates an increase in global temperatures of over 4C by 2100" (p.66). Three timeframes (2010, 2030, 2050) and twenty climate hazards were examined across 11 assets (mainly production sites), per Appendix A of Delegated Regulation (EU) 2021/2139, with Axa Climate's support (p.66).

Transition risk: the Group adopted the NGFS/IEA Net Zero Emissions by 2050 scenario, "compatible with limiting global warming to 1.5C (with a probability of at least 50%)" per the IPCC Sixth Assessment Report. Using TCFD methodology, EXOSENS examined political/legal, market/technological and reputational risks and opportunities over short- and medium-term horizons (p.66); findings "will be reviewed as part of the process to update the double materiality assessment in 2026."

The physical-risk analysis "did not call into question the material IROs identified in the Group's double materiality exercise in 2023" (p.66).

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 / the E1 climate-DMA section, where this content is disclosed in the FY2025 report (Section 2.2.2, pages 66-67). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"As it indicated in 2024, in 2025 EXOSENS performed the analyses needed to establish a climate resilience strategy. At this stage, the results of those risk analyses have not yet been translated into an overall assessment of the Group's climate resilience" (p.66-67). The company states plainly that no formal resilience conclusion exists yet, only the underlying scenario work described under E1-2-ScenarioAnalysis.

"Initially, in 2026, the Group will use the results of those analyses when updating its double materiality assessment" (p.67). The impacts and risks presented in the meantime "come from the 2023 double materiality assessment" (p.67).

At the ESRS 2 SBM-3 level the report adds: "The Group has not yet carried out a formal qualitative analysis of the resilience of its strategy and business model in the face of material sustainability impacts, risks and opportunities... In 2025, however, the Group worked towards the publication of an initial transition plan. The resilience analysis will supplement that plan in the years to come" (p.61).

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Policies related to resource use and circular economy

Reference: page 78.

The Group's environmental policy (Section 2.2.3, ESRS E1-2) "addresses the opportunity to optimise resources through the integration of eco-design into new products" (p.78). The policy "is general at this stage and the planned work relating to eco-design will enable the Group to define its future targets more clearly. For this reason, the issue of transitioning away from the use of virgin resources and the use of more secondary resources, as well as the topics of sustainable supply and the use of renewable resources, are not addressed in the policy" (p.78).

ESG considerations enter purchasing decisions through the supplier assessment process described under S2-4 (p.78). Resource management is otherwise managed at subsidiary level; the Group's strategy rests on four principles: "minimise waste at source; promote reuse and recycling; integrate eco-design principles; raise awareness among all staff members and suppliers," reinforced by an annual one-day CSR event (p.78).

E5-2Actions and resources related to resource use and circular economy
Reported

Actions and resources related to resource use and circular economy

Reference: page 78.

As part of the aim to apply eco-design to all new products by 2027, the Group set an intermediate 2025 objective of training R&D project leaders; "eco-design training was provided to project leaders in R&D teams across all Group sites within the scope of the sustainability statement. The participation rate in that training was 95% at 31 December 2025" (p.78).

Site-level actions in 2025 (p.78): Photonis Netherlands communicated with managers on resource use and the circular economy and improved its anode-lens recovery process, "since these lenses are made from glass, making the recovery process more efficient directly reduces the amount of glass entering the production system." Photonis Scientific "recycle 100% of the methanol used in their processes" and began recycling tungsten crucibles and packaging to recover platinum traces and limit consumption of critical raw materials.

E5-3Targets related to resource use and circular economy
Reported

Targets related to resource use and circular economy

Reference: page 78.

The Group's headline target is to introduce eco-design into new products by 2027, with a 2025 intermediate milestone of training R&D project leaders across all in-scope sites - achieved at a 95% participation rate (p.78).

The materiality section notes the topic's scope is still being defined: "As part of the work to identify the CSRD data points applying to material issues, it became clear that the E5 standard seems to apply primarily to companies whose business model focuses on the circular economy. In this sense, EXOSENS is not certain that this ESRS is applicable to the opportunity identified above... This topic will be reviewed when the double materiality assessment is reviewed in 2026" (p.77). No further quantified E5 targets beyond the 2027 eco-design milestone are presented.

E5-4Resource inflows
Reported

Resource inflows

Reference: page 79.

2025 resource-inflow data is collected annually as part of the carbon-footprint process, covering purchases of raw materials, IT hardware and capital goods, classified using the Ellen MacArthur Foundation's technical/biological materials definitions (p.79).

Breakdown of technical and biological materials in the 2025 carbon footprint (tonnes / %, p.79): total raw-material purchases 73.28 t (100%); technical materials 70.8 t (97%); biological materials (cardboard, wood, paper) 2.48 t (3%). Materials purchasing data excludes Sinfrared and Photonis Infrared France, which are not production sites.

"For 2025, the Group is not in a position to publish: the percentage of biological materials... that come from sustainable sources; the weights and percentages of secondary reused or recycled components, secondary intermediary products and secondary materials" (p.79).

E5-5Resource outflows
Omitted
E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Omitted
E5-5(was E5-5-Waste)Waste
Omitted

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Policies related to own workforce

Reference: pages 88-89.

The Group adopted a labour and human rights policy in 2023, updated in 2025, aiming to "foster employee engagement in a context of growth," "ensure a compliant, inclusive social strategy" and "strengthen the corporate culture" (p.88). Oversight sits with the Chief People and Culture Officer; the CEO implements it, with annual presentation to the Appointments and Remuneration Committee.

The policy covers health/safety, social dialogue (freedom of association, employee representative bodies, whistleblowing), and employer attractiveness/retention (engagement initiatives, succession planning, 360-degree reviews) (p.88). It applies to all employees, all entities, all contract types, including newly acquired entities during integration (p.88).

Based on the UN Guiding Principles, ILO fundamental conventions, the UN Global Compact and the Diversity Charter signed in 2025, it covers health and safety, harassment/discrimination prevention, equality, freedom of association, well-being, and inclusion of people with disabilities and women in technology programmes (p.89).

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

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

Reference: page 89.

Social dialogue with workers' representatives is managed entity-by-entity per local legislation; "due to the Group's structural organisation, there is currently no single body responsible for an overall framework agreement with management" (p.89).

Since 2024 EXOSENS runs an annual employee engagement survey assessing sense of belonging, expectations and concerns (including engagement, job satisfaction and health/safety). Results go to site HR Directors, then to all employees via an infographic, then to local HR Managers for site-specific presentation. The survey generates the employee Net Promoter Score (eNPS), benchmarked internationally (over 70% = exceptional engagement, over 65% = very good) (p.89). The HR Department, with local management, holds operational responsibility for the survey and for feeding results into strategy.

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

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

Reference: pages 89-90.

EXOSENS introduced a whistleblowing mechanism in 2024 for anonymous reporting of health, safety or working-condition concerns, with a case manager at each site trained on the procedure (p.89). Reports are investigated confidentially; individuals concerned are notified "generally within one month" and the whistleblower informed of the outcome "within a reasonable period of no more than three months" (p.89-90). Harassment suspicions (100% of managers trained in 2025) trigger a dedicated HR investigation.

"No punitive steps will be taken against the whistleblower if investigations... do not confirm the allegation"; the company commits to protecting whistleblowers "from any harm, victimisation, harassment or intimidation" (p.90). Social and Economic Committees, Health/Safety Committees and staff representatives also play a role, alongside the annual engagement survey and a post-integration survey introduced in late 2025 for newly acquired entities' employees.

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Taking action on material impacts on own workforce

Reference: pages 90-94.

Engagement, pay and benefits (p.90): performance/career-development reviews cover 100% of employees; several subsidiaries introduced transparent salary scales; the engagement survey feeds action plans monitored at Group and local level.

Diversity and inclusion (p.92): anti-harassment training reached 100% of qualifying managers in 2025 (target: 100% of executives by 2026). Women: 20% of senior management/technical leadership, 30% of the Executive Committee (2025 target hit). "EXOSENS set a target of signing at least one partnership with a company that employs disabled staff or with a disability-oriented social enterprise in Europe by 2027... The Group hit that target in 2025 by signing two partnerships" (p.92).

Health and safety (p.93): Pulse mental-health tracking, psychosocial-risk initiatives (workspace changes, break rooms, a "stress leads" network at Photonis France), Internal Operation Plans, hazardous-substance management (CMR substitution at Xenics). The Pulse wellbeing indicator improved from 67% to 71% in 2025.

Social dialogue (p.91): succession planning covers 100% of senior management; voluntary turnover 2.8% against a sub-3% target; employee share ownership reached 53% against a 45% target.

S1-4(was S1-5)Targets related to own workforce
Reported

Targets related to own workforce

Reference: pages 94-95.

Health and safety: the lost-time accident frequency rate (TF1) fell from 4.9 (2024) to 3.22 (2025), beating the original 2026 target of 3.9 early, so the 2026 target was tightened to 3.2, with a 2027 horizon of 3.1; TF2 (with/without lost time) fell from 8.9 to 4 (p.94).

Engagement and working conditions (p.94-95): voluntary turnover target kept below 3% (actual: 2.8% in 2025, overall turnover stable at 6.5%); employee share ownership target of 45% (2025)/50% (2027) exceeded at 53% subscription; 100% of Executive Committee members completed executive coaching in 2025; 100% of qualifying office staff had remote-working access; sporting-initiative access target hit for 2025-2026; a 360-degree Feedback Review roll-out targets 100% of senior managers by Q2 2026; the eNPS target of 12 (2026) was already exceeded in 2025 at 14, so the Group is "now aiming to maintaining its eNPS in 2026."

These targets follow from the 2023 double materiality assessment and are being reassessed alongside the 2026 DMA update.

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Characteristics of the undertaking's employees

Reference: pages 95-96.

Employees by country with more than 50 employees / 10% of headcount (2025 vs 2024, p.95): France 680 (587); Germany 65 (64); Netherlands 395 (372); Belgium 74 (61); Canada 98 (89); Israel 62 (63); United Kingdom 95 (N/A); United States 88 (148).

By contract type and gender (2025, p.95): total workforce 1,573 (606 women, 967 men), up from 1,401 in 2024. Permanent contracts: 1,499 (584 women, 915 men). Fixed-term: 74 (22 women, 52 men). Non-guaranteed-hours employees: 0. Full-time/part-time breakdowns are not disclosed (marked N/A).

Age breakdown (2025, p.96): under 30: 189 (12%); 30-50: 741 (47%); over 50: 643 (41%), broadly stable versus 2024's 10%/49%/41% split.

S1-6(was S1-7)Characteristics of non-employee workers
Omitted
S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Reference: page 96.

"More than 81% (vs. 74.5% in 2024) of employees within EXOSENS... are covered by collective bargaining agreements (company or sector)" (excluding Sinfrared, Photonis Scientific and El-Mul from this calculation). The Group has no European Works Council, SE Works Council or SCE Works Council agreement (p.96).

For countries with over 50 employees / 10% of headcount, both EEA collective-bargaining coverage and workplace representation are reported in the 80-100% band. Outside the EEA, "employees in Canada and the United States are covered by social dialogue mechanisms that meet the definition of ESRS S1-8, mainly in Quebec, where labour relations are governed by a formal system... In other non-EU countries, working conditions are mainly governed by national or federal regulatory frameworks, without any formal collective bargaining mechanism at the Group entity level" (p.96).

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Reference: pages 96-97.

"Women account for 30% of the Group's Executive Committee. Women account for 23% of senior management in the Group's subsidiaries with more than 50 employees. The overall percentage of women in senior management within the group is 23%" (p.96).

Executive Committee (2025): 7 men (70%), 3 women (30%), unchanged from 2024. Senior management (2025): 73 men (77%), 22 women (23%), versus 94 men (76%)/29 women (24%) in 2024 - a headcount reduction with a broadly stable gender split. Senior management is defined as country Management Committee members plus certain reporting managers (p.97).

S1-9(was S1-10)Adequate wages
Not Material
S1-10(was S1-11)Social protection
Reported

Social protection

Reference: page 97.

"All Group employees benefit from comprehensive social protection for major life events (job loss, illness, work-related injury, acquired disability, retirement, maternity or parental leave) [owing] to the fact that all EXOSENS sites are located in countries that offer public-sector coverage of these events" (p.97).

"The only exception concerns the coverage of unemployment risk in Singapore, where there is no unemployment insurance system because of a historically low unemployment rate and where no private insurer offers this type of cover" (p.97).

S1-11(was S1-12)Persons with disabilities
Omitted
S1-12(was S1-13)Training and skills development metrics
Omitted
S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: pages 97-98.

"No deaths were recorded among the Group's employees or among other workers present on its sites as a result of workplace accidents or occupational illnesses during the reporting period, which was also the case in 2024. No serious accident was reported during the year" (p.97).

2025 (within a workforce of 1,573): 10 workplace accidents, of which 8 resulted in lost time; 273 days lost (vs. 413 in 2024). TF1: 3.22; TF2: 4, versus a 2024 TF2 of 8.9 (20 accidents, 11 with lost time) (p.98). Improvements are attributed to PPE compliance, workplace vigilance and adherence to safety guidelines, though "some minor accidents may still take place (such as falls)" (p.98).

S1-14(was S1-15)Work-life balance metrics
Omitted
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics (pay gap and total compensation)

Reference: page 98.

"The analysis shows a 15-point gap among executives and a 7-point gap among non-executives worldwide, and a 26-point gap across all grades and remuneration levels" in average gender pay (2025, all-staff annual pay basis, p.98). The Group attributes this mainly to under-representation of women in technical/scientific career pathways within optronics, "reflect[ing] ongoing imbalances that begin in education... and [does] not result from discriminatory pay practices" (p.98).

CEO pay ratio: 15.9 (median) and 13.2 (mean) based on the France-based comparator workforce (EXOSENS SAS, Photonis France, Noxant, Photonis Infrared France, Telops France - 100% of the country's workforce); on an all-Group-employee basis the baseline-year ratio was 14.5 (median) / 12.1 (mean) (p.98).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Reference: page 98.

"During the reporting period, five complaints were submitted through channels through which company staff members can voice concerns" (2024: 7), of which zero were submitted to OECD National Contact Points (2024: 1). Each was investigated internally with remedial action taken; "there were no fines, penalties or compensation for damages resulting from the incidents and complaints referred to above" (p.98).

"EXOSENS reports that no serious human rights incidents affecting its own workforce were recorded in 2025. There were no cases of non-compliance with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises" (p.98). Financial-statement reconciliation of fines/sanctions is stated as not applicable given the absence of incidents.

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

Reference: page 100.

Two policies address the identified negative impact of business-ethics/social-responsibility violations in the supply chain: the Sustainable Purchasing Policy and the Supplier Code of Conduct (p.100), launched in 2024 under the Chief Operations Officer and Group Purchasing Director, with the Group CEO as ultimate accountable owner.

Sustainable Purchasing Policy integrates ESG criteria into purchasing decisions, targets Scope 3 footprint reduction, and covers ethics/human rights and supplier innovation; monitored via KPIs (Supplier Code of Conduct sign-up rate; strategic-supplier CSR-approach adoption) reported twice yearly (p.100).

Supplier Code of Conduct sets ethical, environmental and commercial principles: legal compliance, anti-corruption, conflict-minerals compliance, human-rights protection (prohibiting child/forced labour, ensuring safe conditions and decent pay), and environmental/health-and-safety management-system expectations, with a reporting channel via the whistleblowing platform (p.101). "The Group has not yet identified any workers within its upstream value chain with particular characteristics that require special attention" (p.100).

S2-2Processes for engaging with value chain workers about impacts
Reported

Processes for engaging with value chain workers about impacts

Reference: page 101.

"EXOSENS does not currently have a formal process of regular dialogue with supply chain workers or their legitimate representatives. There is not yet any formal mechanism for proactively seeking their views or systematically factoring their feedback into decisions relating to the actual or potential social impacts that may concern them" (p.101).

The Group is a UN Global Compact signatory since January 2024, committed to its four labour-rights principles (freedom of association/collective bargaining, elimination of forced and child labour, elimination of discrimination), which guide supplier expectations via the Supplier Code of Conduct (p.100-101). "EXOSENS has no global framework agreement with international union federations regarding value chain workers and does not formally assess the effectiveness of any formal dialogue, since no such formal dialogue is in place" (p.101).

S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reported

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

Reference: pages 101-102.

The Group's whistleblowing mechanism is open to third parties, "including workers in the Group's upstream value chain," to report reprehensible, unethical or illegal conduct, and can be used anonymously (p.101). "At this stage, the Group does not have a formal process specifically dedicated to remedying material negative impacts on value chain workers. If such an impact were to arise, EXOSENS would adopt a case-by-case approach" (p.101). The Group has not yet required or assessed provision of an equivalent channel within suppliers' own workplaces (p.101).

Confidentiality of whistleblowers and any named third parties is guaranteed, with protection against retaliation extended to related third parties as well as the reporter (p.102).

S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Reference: pages 102-103.

In 2025 EXOSENS renewed its UN Global Compact commitment and continued its formal supplier-audit programme with strengthened ESG criteria applied since 2024; "In 2025, five audits including ESG criteria were carried out among those suppliers" (p.102).

A structured ESG-maturity analysis covered all strategic suppliers against a framework jointly developed by Purchasing and CSR; "At 31 December 2025, the analysis revealed that 60% of them are considered as committed to a CSR approach consistent with the defined analysis framework, exceeding the intermediate target for 2025" (against an 80%-by-2027 goal) (p.102).

The whistleblowing platform remained operational; "In 2025, no reports relating to value chain workers were submitted through the platform" (p.103). EXOSENS won the EcoVadis Gold medal in November 2025, "confirming its progress in the field of sustainability, particularly matters related to responsible purchasing" (p.103).

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (value chain workers)

Reference: pages 103-104.

"100% of our important suppliers were committed to complying with our Supplier Code of Conduct by 2025" - achieved, rising from 60% in 2024 to 100% in 2025 (p.103).

"80% of our strategic suppliers will adopt a CSR approach by 2027" - progress stood at 60% in 2025 (versus a 50% intermediate 2025 target, exceeded), up from not-applicable in 2024; "a precise action plan is currently being drawn up in line with this objective" (p.104).

The EcoVadis medal rose from silver (2024) to gold (2025). "Currently, value chain workers and their representatives are not directly involved in monitoring performance indicators relating to our objectives or in preparing measures aimed at achieving continuous improvements in those indicators" (p.104).

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

Reference: pages 107-109.

The Group's corporate culture rests on "team spirit, respect, trust, passion and entrepreneurial spirit" (p.107), assessed annually via the engagement survey. In 2025 EXOSENS consolidated its policies into a single compliance programme, addressing the Sapin II act's requirements and covering corruption, fraud, conflicts of interest and regulatory non-compliance (p.107).

The programme includes: gift management, charitable-donation oversight, export-control compliance, REACH/RoHS compliance, GDPR application, conflict-minerals monitoring, the Supplier Code of Conduct, and a delegation-of-authority procedure (p.107). Each subsidiary has a local compliance ambassador reporting annually to Group Compliance; the Group CFO is also Group Compliance Officer (p.108).

The Internal Code of Ethics sets integrity, anti-corruption and conflicts-of-interest principles, with mandatory annual training, a signature register, and reporting via the whistleblowing mechanism (p.108). The Third-Party Assessment Procedure rates counterparties (low/medium/high risk) using the IndueD tool, covering all upstream/downstream relationships (p.109). The Whistleblowing mechanism, open to all stakeholders, guarantees confidentiality, acknowledges reports within 7 business days and updates whistleblowers within 3 months (p.109).

G1-2Management of relationships with suppliers
Reported

Management of relationships with suppliers

Reference: page 110.

EXOSENS addresses supplier-base reduction risk from tightening regulation through the Supplier Code of Conduct and Sustainable Purchasing Policy (cross-referenced to Section 2.6.3 / S2-1), with actions including Code of Conduct deployment and strategic-supplier ESG-maturity assessment (cross-referenced to S2-4), and targets of 100% important-supplier Code sign-up by 2025 and 80% strategic-supplier CSR adoption by 2027 (cross-referenced to S2-5) (p.110).

"In line with our supplier selection procedure, the Group pays particular attention to environmental and social practices. However, these aspects do not currently constitute outright exclusion criteria" (p.110).

G1-2(was G1-3)Prevention and detection of corruption and bribery
Reported

Prevention and detection of corruption and bribery

Reference: pages 111-112.

Prevention/detection/handling rests on the compliance programme built around the eight measures of the Sapin II act (p.111): the Code of Ethics (all staff, annual campaign, e-learning for exposed roles), third-party assessments (pre-commitment integrity screening), the whistleblowing mechanism (per-site case managers), accounting/financial controls, regular internal audits (reported twice yearly to the Executive Committee and Audit Committee), and sanctions for proven Code breaches.

Exposed-employee training: executives, purchasing/sales/HR/legal/audit/quality/marketing/finance managers, contract managers, those dealing with external partners/government bodies or financial transactions, and staff in international/high-risk contexts. Training coverage rose from 80% (2024) to 99% of the most exposed staff by 31 December 2025 (p.111); the Board itself received compliance/ethics training on 15 December 2025.

Third-party assessment coverage (31/12/2025, p.111): agents/distributors 100%; customers over EUR 100,000 96%; suppliers over EUR 100,000 91% (against a 2026 target of 98%).

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Targets related to business conduct

Part of MDR-T/GDR-T disclosures. Reference: pages 105, 111.

The SBM-3 materiality table for business conduct lists explicit targets alongside the Corruption sub-topic: "100% of the Group's most exposed employees to be trained by 2025," "Deployment of third-party assessments for agents and distributors, important suppliers and customers within the scope," and "ISO 37001 certification in 2027" (p.105).

Progress against the training target is tracked at G1-3: exposed-employee training reached 99% by 31 December 2025, up from 80% in 2024 (p.111). Third-party assessment deployment reached 100% (agents/distributors), 96% (customers over EUR 100,000) and 91% (suppliers over EUR 100,000) against a 2026 goal of 98% coverage (p.111). No further detail on the ISO 37001 certification target's progress is given beyond the 2027 target date.

G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Reference: page 112.

"The Group was not convicted of any violation of anti-corruption laws during the reporting period. The amount of fines for violating anti-corruption laws is therefore zero" (p.112).

Number of convictions for breaches of anti-corruption and anti-bribery laws: 0. Amount of fines for violating anti-corruption and anti-bribery laws: 0 (p.112).

G1-5Political influence and lobbying activities
Not Material
G1-6Payment practices
Not Material