Ferrovial

Governance roles and composition

Reference: pages 73-76.

Ferrovial has a one-tier Board of Directors with an Audit and Control Committee and a Nominating and Remuneration Committee (page 73). In 2025 the Board had twelve members: two executive directors (Chairman and CEO) and ten non-executive directors, "75% of whom met the independence criteria of the Dutch Corporate Governance Code". Eight members were men (66.66%) and four were women (33.33%), a women-to-men ratio of 0.5 (page 73). Employees have no seat on the Board but are represented on occupational risk committees (page 73).

Oversight of sustainability (pages 73-74). The Board, directly or through the Audit and Control Committee, reviews the double materiality matrix and the enterprise risk system, and monitors the ESG indicators in the sustainability strategy. It reviews the climate strategy report each year and presents it to the AGM for an advisory vote. Both bodies also hold business conduct roles: the Code of Ethics, anti-corruption policies, and human rights and labor standards.

Skills (pages 74-75). The report gives Board experience by region, function and industry. A Sustainability Committee chaired by the Sustainability Director, with members from the four business units and corporate areas, reports to the Board, the Management Committee and the CEO (page 75).

Information provided to the administrative, management and supervisory bodies

Reference: pages 74, 76.

Reporting lines (page 76):

• The Sustainability Department reports to the Board at least once a year on progress against the Sustainability Strategy, including the most relevant projects.
• The Management Committee checks progress every four months.
• The Sustainability Committee meets three times a year and its Chair submits an annual report to the Board.

Each year the Communication and Corporate Responsibility Department reports to the Audit and Control Committee on the non-financial (including sustainability) report, which contains the double materiality assessment, and on progress of the reporting process. The Internal Audit and Risk Director reports to the Committee at least twice a year, and to the Board once a year, on the risk map (page 74).

ESG topics addressed in 2025 (page 76): the 2030 Climate Strategy and its targets; the water footprint target (Business Water Index down 20% by 2030 from 2017); biodiversity and TNFD; circular economy; equal opportunities; health, safety and well-being; business ethics and compliance; and ESG performance across the supply chain. Innovation, cybersecurity and sustainable finance follow the same reporting approach.

Integration of sustainability-related performance in incentive schemes

Reference: pages 76-77.

Remuneration combines fixed pay with annual and long-term variable pay (page 76).

Annual variable (pages 76-77):

• Chairman: target 125% of fixed pay, maximum 190%. 80% quantitative (net income 55%, cash flow 45%) and 20% qualitative and ESG goals. The report says "ESG goals represent 60% of the objectives", including a greenhouse gas reduction goal with a total weight of 6.7%.
• CEO: target 100% of fixed pay, maximum 150%. 70% quantitative and 30% qualitative and ESG. The report says ESG goals represent 61% of these objectives, including a greenhouse gas goal with a total weight of 2.7%.

Long-term incentive, 2023-2025 (page 77): maximum 150% of fixed pay for both; 40% activity cash flow, 50% relative TSR and 10% ESG metrics, including emissions reduction (5%), belonging and inclusion, and occupational health and safety. Paid in shares, with malus and clawback clauses.

The company states that "Ferrovial does not have specific associations between IROs and the compensation given to the governing bodies", though the scheme links to ESG metrics tied to several material IROs (page 77). The Nomination and Remuneration Committee proposes the policy and the Board approves it.

Statement on due diligence

Reference: pages 81-82.

Ferrovial says it builds due diligence into its management model through Ferrovial Risk Management (FRM), which periodically assesses potential human rights risks in its global operations, using specific tools to identify risks at different stages of the project life cycle (page 81).

It plans to extend the process to value chain management, commercial transactions and procurement, with added controls and closer work with suppliers and partners (page 81).

Page 82 contains a table that maps the core elements of due diligence (integration in governance, strategy and business model; engagement with affected stakeholders; identification and assessment of adverse impacts; actions on those impacts and tracking their effectiveness) to sections of the statement: Business strategy (risk management and control; interaction with stakeholders), Corporate governance (ESRS 2), Double materiality, SBM-3, and the topical chapters, specifically S2-4, S3-4, G1-2 and the human rights due diligence procedures in this GOV-4 section.

The main due diligence content sits in the S3 chapter, which also holds the Human Rights Policy, with due diligence references in E3, E4 and E5 (page 82).

Risk management and internal controls over sustainability reporting

Reference: pages 57-60.

The Board adopted a Risk Control and Management Policy based on COSO ERM and the Three Lines Model, last updated in 2025 (page 57). Risk identification and assessment run twice a year, bottom-up from project level to the Management Committee, rating inherent and residual risk on likelihood and on economic and reputational impact (page 58). Enterprise Risks reports to the Audit and Control Committee; Internal Audit is the independent third line (page 58).

In 2025 Ferrovial built a risk alert system using Key Risk Indicators for all risks, including ESG risks, with critical or high impact, and started a project to update the FRM model with a new governance, risk and compliance system due to run in 2026 (page 58).

For sustainability reporting, the report describes controls on the EU Taxonomy assessment: the Sustainability and Finance departments and the business Quality and Environment functions analyze all active contracts (those with revenue or CapEx in the year), checked on a sample at the lowest control unit (the CEBE) at the end of the first half and again at the end of the third quarter, with a dedicated IT application (page 60). Issues on sustainability information, double materiality or internal controls over non-financial information go to the Audit and Control Committee (page 60).

Strategy, business model and value chain

Reference: pages 55-57.

Ferrovial reports 22,609 employees and 9,627 million euros of revenue, with five core markets: Spain, the United States, Canada, Poland and India (page 55). Four business units double as reporting segments: Highways (managed lanes in the US and Canada, plus India), Airports, Energy (transmission lines and renewables) and Construction. An "Other" category holds the parent company, Ferrovial Digital Infrastructure (created in 2024 for data center investments) and minor subsidiaries, including UK waste management plants (page 55). A footnote confirms no involvement in the Division 20.2 chemicals, controversial weapons or tobacco (page 55).

Value chain (page 56): a B2B model. Upstream: supply chain partners, contractors and subcontractors. Downstream: partners, customers and end users. 94.8% of purchases come from local suppliers. The main purchased materials by volume are asphalt bitumen, concrete, corrugated steel, aggregates, cement and asphalt agglomerate.

Strategy (page 57): four pillars: People, Sustainable growth, Operational excellence and Innovation.

Interests and views of stakeholders

Reference: pages 62-63.

Ferrovial names six stakeholder groups: customers and users, employees, suppliers, shareholders, local communities, and governments and regulators. A table sets out for each the communication channels, the purpose and the responsible internal owner, for example business units for customers, the Communications Department for employees, and Procurement, Project Managers, Compliance and the Sustainability, Health and Safety and Quality departments for suppliers (pages 62-63). Each construction site or asset has a designated person for dialogue with local communities (page 63).

Examples of views gathered (page 63):

• A 2025 health, safety and wellbeing culture survey of employees and contractor personnel drew 27,857 responses. Ferrovial concluded that its prevailing culture is "primarily compliance-based" and says it is changing its approach.
• On cybersecurity, phishing drills are run "on a biweekly basis", with training tailored after each simulation.

The Board, through the Audit and Control Committee, is told each year the results of the double materiality analysis, which includes consultation with internal and external stakeholders (page 63).

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

Reference: pages 68-70, plus the topical IRO tables on pages 83, 95, 108, 113, 126, 132, 150, 157, 165, 174 and 178.

Ferrovial states that it "identified material impacts arising exclusively from its own activities", stemming from its business model, and that they do not depend on external business relationships (page 68). Time horizons: short term is the next year, medium term up to five years, long term beyond five (page 68). Page 69 lists actual and potential effects on the business model, risks and opportunities, for example GHG regulation costs, weather damage to infrastructure, and opportunities in resilient infrastructure and EV charging.

Financial effects (page 70): in 2024 Hurricane Helene stopped variable pricing on the I-77 highway for 5 weeks, costing $2.4M, and the Valencia DANA floods cost EUR 0.87M. For 2025 "no specific information or estimates are available to quantify these effects, which is acceptable given that this requirement is subject to phased-in application".

The report notes that its 2023 report was prepared under the Spanish non-financial reporting rules and assessed impact materiality only (page 70). Page 68 adds that payment practices datapoints were not reported because no material IRO was identified.

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

Reference: pages 65-66, 70-73.

Ferrovial uses ESRS 1 AR 16 as the base list and builds on EFRAG guidance, GRI, SASB, legislation and investor requirements (page 65). Scope covers all four business lines and the main geographic areas, including the value chain. The long list held 67 impacts, 42 risks and 35 opportunities (page 65).

Scoring (pages 65-66): impact materiality is severity times likelihood (scale, scope and irremediability for negative impacts); financial materiality is magnitude times likelihood. A five-point scale (Critical, Significant, Important, Informative, Minimal) is used and IROs in the top two categories are material. Where an IRO spans several locations, the highest score is kept rather than an average. Stakeholders consulted include employees, communities, NGOs, investors, customers, suppliers, public administrations and partners. IROs feed the FRM risk process (page 66).

Topic processes (pages 70-73): climate uses TCFD, RCP and IEA scenarios; biodiversity follows TNFD LEAP; governance, cybersecurity and innovation have their own steps. The 2025 method was broadly the same as 2024 and is due for review in 2026 (page 66).

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

Reference: page 82; pages 183-185 (Annex: ESRS content index).

Page 82 says the Annex "ESRS content index" sets out the disclosure requirements covered, selected from the double materiality results, and lists the datapoints included for other EU legislation. Page 77 says Ferrovial applies the ESRS "on a voluntary basis, as the Dutch transposition into national law has not yet taken place".

The index (pages 183-184) gives standard, disclosure requirement, page and comment. It lists ESRS 2 (BP-1 to IRO-2), E1, E3, E4, E5, S1, S2, S3 and G1, plus two entity-specific topics: Cybersecurity (page 174) and Innovation, digitalization and technology applied to the business (page 178). Rows with no page carry a comment: "Phased-in" on E1-9, E3-5, E4-6, E5-6, S1-7, S1-11 and S1-15, and "Not material" on one ESRS E2 row, one ESRS S4 row, G1-5 and G1-6. S1-13 and S1-14 have pages plus partial phase-in notes (performance review; non-employees).

Datapoint table (pages 184-185): SFDR, Pillar 3, benchmark and climate law datapoints marked "Material", "Not Material" or "Phased-in", with a page.

Transition plan for climate change mitigation

Reference: pages 99, 101-102.

Ferrovial has had a 2030 Climate Strategy since 2011. The Quality and Environment Steering Committee, chaired by the Sustainability Director, carries it out and meets at least quarterly; the Management Board approves and monitors it each year (page 99). Since FY2021 the Annual Climate Strategy Report goes to the General Shareholders' Meeting for an advisory vote ("Say on Climate").

Targets have been validated by the Science Based Targets initiative (SBTi) since 2017; new targets in line with 1.5C were validated in February 2025 (pages 99, 101). The Deep Decarbonization Path (DDP) names the levers: renewable electricity, energy efficiency, low-carbon heavy machinery, an electric vehicle fleet and biofuels (page 99).

Blocked emissions (page 99): emissions from waste treatment assets in the UK and Poland are treated as blocked emissions in 2030. Traffic emissions of its concessions are not counted, being use-phase emissions of customers. The report states Ferrovial is not excluded from EU Paris-aligned Benchmarks.

Progress (page 99): Scope 1 and 2 (market-based) fell from 522,473 tCO2e in the 2020 base year to 284,009 in 2025. The plan "is reviewed annually" and its investment is in financial planning (page 101).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 70-71) and the E1 SBM-3 section (pages 95-97), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical vs transition (page 96): the report lists them separately. Physical hazards named: heat waves, warm and high temperatures, heat stress, wildfires, thermal expansion and drought. Transition risks include missed SBTi targets, tighter emissions reporting, lost bids, limits on transport modes, new technology gaps and the cost of electricity and raw materials.

Method: ADAPTARE, built with the University of Cantabria's Institute of Environmental Hydraulics on the IPCC risk framework (hazard, vulnerability, exposure), using asset geolocation and horizons of 2025, 2030 and 2050 tied to contract length (pages 95-96).

Scenarios: physical RCP 4.5 (2.6C by 2100) and RCP 8.5 (above 4.4C); transition IEA STEPS (2.4-2.8C), APS (1.9-2.3C) and NZE (1.3-1.5C) (pages 95-96). Limits named: climate projection and variable choice, and the pace of decarbonization (page 70). The report says the risks assessed are those of its own operations (page 95).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 resilience section (pages 70, 95-98), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Ferrovial states that, through its scenario analysis and measures, "it ensures that the Company's strategy and business model are resilient and adaptable to future climate conditions" (page 95). Page 96 headlines the "results of the Company's resilience analysis".

Physical risks: more maintenance, shutdowns and extraordinary repairs, handled with ADAPTARE, design experience (such as materials that stand higher temperatures), business continuity and winter maintenance plans, and a high level of insurance cover (page 96).

Transition risks: answered with governance controls, energy monitoring, ISAE 3410 verification of GHG data, the Deep Decarbonization Path, shadow carbon pricing, tender cost forecasting and technology search (pages 96-97).

Uncertainty and exposure: projections and the pace of decarbonization (page 70). No assets were found that are incompatible with a climate-neutral economy (page 70). Opportunities in mobility, water, energy and infrastructure are on page 98.

Policies related to climate change mitigation and adaptation

Reference: page 100.

The policy covered is the Quality and Environment Policy. Its stated aim is to add value for stakeholders by developing and operating sustainable infrastructure and cities, using resources efficiently and cutting environmental impact. Through it Ferrovial manages climate risks and opportunities in all its activities and commits to reducing greenhouse gas emissions (page 100).

Linked IROs (page 100): impacts: GHG emission reduction and carbon footprint compensation, sustainable and resilient infrastructure, and GHG emissions from its activities. Opportunities: energy infrastructure, efficiency services, renewable generation and mobility emission solutions. Risks: more or tighter climate legislation, limited new technology, and extra maintenance after severe weather.

Scope: Ferrovial SE and Group companies worldwide, members of governing bodies, and employees, with no exclusions. It applies to the value chain through its objective (page 100).

Approval: the Board approves it; the Quality and Environment Committee implements it. It is prepared under Dutch Corporate Governance Code recommendations 2.1.5 and 2.1.6, is on the website, and has had no changes (page 100).

Actions and resources in relation to climate change policies

Reference: page 101.

Actions follow the Deep Decarbonization Path levers, with expected reductions by 2030 against 2020:

• Electric and more efficient fleet: 17,000-22,000 tCO2e
• Efficiency on construction machinery: 800-3,000 tCO2e
• Asphalt plant efficiency: 7,000-12,000 tCO2e
• Biofuels: 13,000-18,000 tCO2e
• 100% renewable electricity (2025 target): 30,000-40,000 tCO2e

Total expected: Scope 1 down 37,000-55,000 tCO2e and Scope 2 down 30,000-40,000 tCO2e.

Scope 3: low-carbon cement and concrete through a Supplier Collaboration Program, lower-carbon bitumen with recycled content, a green procurement catalog (15,000-20,000 tCO2e), design to cut carbon-heavy materials, local sourcing, and the Circular Economy Plan (80,000-85,000 tCO2e). Expected Scope 3 reduction: 595,000-645,000 tCO2e by 2030 (500,000-540,000 of it from supplier and materials actions).

On resources, the report says Taxonomy investments under Delegated Regulation 2021/2178 are not directly tied to the DDP, and refers to the MDR-A section for the financing gap (page 101; page 78).

Targets related to climate change mitigation and adaptation

Reference: pages 101-102.

New targets were validated by SBTi in February 2025 (process started July 2024), with a goal of net zero by 2050 or earlier (page 101):

• Cut Scope 1 and 2 emissions by 42% by 2030 from a 2020 base year, in absolute terms
• Cut Scope 3 emissions by 25% by 2030 from 2020, absolute (purchased goods and services, upstream transport, waste and fuel and energy)
• Cut Scope 1, 2 and 3 emissions by 90% by 2050 from 2020

The report says the Scope 1 and 2 targets match 1.5C and the Scope 3 target is "at the threshold of well below 2C" (page 101).

Targets use market-based emissions and the same scope as E1-6 (page 102). Ferrovial has had Scope 1, 2 and 3 targets since 2017; 2020 became the base year in 2024 (page 102). It has no formal direct process of consulting stakeholders on the targets and checks effectiveness through internal evaluations (page 102). Page 61 shows progress: Scope 1 and 2 down 45.6% and Scope 3 down 17.5% against base in 2025.

Energy consumption and mix

Reference: page 102.

Total energy consumption: 1,097,712 MWh in 2025 (970,848 MWh in 2024).

Shares in 2025: fossil 80.84%, nuclear 0.14%, renewable 19.02% (2024: 85.62%, 0.23%, 14.15%). Crude oil and petroleum products are the largest fuel at 822,305 MWh.

Intensity: 114.02 MWh per million euros of net revenue from high climate impact sectors, up 7.4% from 106.14. Ferrovial counts all activities as high climate impact (NACE sections A to H and L).

Energy production: renewable 53,990 MWh in 2025, down 43.9% (96,229 in 2024); non-renewable 1,571 MWh. Renewable output excludes Thalia for lack of data, and 2024 coal use was recalculated with fuel-specific calorific values (page 102).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 103-106.

Total location-based emissions were 2,265,940 tCO2e (+0.3%). Intensity: 235.4 tCO2e per million euros (location-based) and 228.56 (market-based). 3.63% of Scope 1 is under emissions trading schemes (page 103).

Scope 3 (pages 103-105): Ferrovial calculates 9 of 15 categories, 92% from primary data. The largest are purchased goods and services at 1,056,290 (+15%), upstream transport at 312,472, waste at 273,870 and capital goods at 143,960.

Method: GHG Protocol, ISO 14064-1:2018, DEFRA factors, operational control for Scope 1 and 2 (page 104). Two UK joint ventures and the HS2 Main Works (15% share) are excluded as not relevant (pages 103-104).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 106.

Ferrovial aims for net zero by 2050 or earlier through reductions plus voluntary offsetting of what cannot be cut, using neutralization and mitigation projects outside its value chain based on nature-based solutions (page 106). Credits come from recognized standards such as VCS and Gold Standard, checked for additionality, permanence and double counting.

Cancelled credits: 29,062 tCO2e in 2025 (26,842 in 2024). In 2025, 92.5% came from reduction projects and 7.5% from removal projects (biological sinks). By standard: Verra VCS 23.2%, Gold Standard 75.3% and other (Spanish MITECO-recognized projects) 1.5%. 0% qualified as corresponding adjustments.

Future: credits expected to be cancelled in 2026 under contracts: 63,973 tCO2e, a high-level estimate.

Own removal project: Compensa, reforestation of burned or farmed land at Torremocha del Jarama (Madrid): 7.7 hectares, 4,000 trees, about 2,000 tCO2e expected to be absorbed, built to MITECO rules. In 2025 MITECO gave Ferrovial its top recognition for calculating, reducing and offsetting (page 106).

Internal carbon pricing

Reference: page 107.

Ferrovial applies a shadow carbon price to its most relevant investments to price climate risk into decisions. It covers Scope 1 and 2 plus the Scope 3 emissions that matter for a project, with prices that vary by time horizon, geography and project type. Prices come from current carbon taxes, trading schemes and fuel taxes, and from IEA and IRENA studies.

Average price: EUR 34 per tonne of CO2 in 2025, rising to EUR 62 in 2030, EUR 118 in 2040 and EUR 178 in 2050.

Process: the manager responsible for a project enters business unit, infrastructure type, country, dates and emissions in a tool that computes the net carbon footprint, its yearly distribution over the concession and the applicable prices. Geographies include Australia, Brazil, Canada, Chile, Germany, Ireland, Mexico, the Middle East, Peru, Poland, Portugal, Spain, the UK, the US, India and Colombia; project types include airports, highways, waste, water, gas energy assets, data centers and construction.

The price is a decision aid, is not recognized in the financial statements, and no locked-in emissions were found for 2025 (page 107).

Policies related to water and marine resources

Reference: pages 108-109.

The Water Policy treats water as a finite and irreplaceable resource and access to water as a fundamental human right. It commits Ferrovial to comply with water legislation, back regulatory frameworks for efficient water use, manage water responsibly across the whole cycle, cut water use including in water-risk areas, and find solutions to growing demand for drinking water and falling quality (page 108).

Linked IROs: positive impact and opportunity from Cadagua's water treatment work, and a negative impact from water extraction, consumption and discharge in water-stressed areas (page 108).

Scope: Ferrovial SE and Group companies, governing body members and employees, worldwide, across the whole value chain, with no exclusions. The Board approves the Sustainability Policy; the Quality and Environment Committee oversees the Water Policy. It follows the Water Footprint Assessment Manual, the Global Water Tool and GRI-G4, is on the website, and has had no changes (page 109).

Actions and resources related to water and marine resources

Reference: pages 109-110.

Ferrovial's water footprint method takes water stress factors by country from the Aqueduct Water Risk Atlas; Medium-high and High are treated as water-stressed and Extremely high as high water-stressed (page 109).

Examples (page 110):

• Porto circular metro line: excavation and tunneling water reused for foundations, jet-grouting, site cleaning and dust control; 85,931 m3 reused since the start, 21,642 m3 in 2025.
• Barcelona Metro Line 8, in a drought: a different pile type saves an estimated 300 m3 and a different bentonite slurry more than 10,000 m3.
• Cadagua, Ter drinking water plant (Catalonia): the largest in the region at 8 m3/s, a EUR 102 million concession over 48 months, adding activated carbon and ozonation to remove emerging contaminants such as pharmaceuticals. Isotherm tests of seven carbons were completed in 2025.

Resources: 277 employees worked in Quality and Environment departments at end 2025, with expenditure of "approximately 18.69 million" (currency not printed); the footnote says this indicator excludes Budimex (page 110).

Targets related to water and marine resources

Reference: pages 110-111.

Ferrovial's targets use its own water footprint method, built on the Water Footprint Assessment Manual and the Global Water Tool (page 110).

• Reduce the Business Water Index (BWI) by 20% by 2030 from a 2017 base of 3,110,263. In 2025 the BWI fell 25.1% against 2017 (down 3.5% on 2024); the target-year value is 2,488,210.
• Annual compensation of 70 times the BWI through the Water Treatment Index (WTI) and Water Access Index (WAI). In 2025 it was 175 times the BWI (printed as 1265 for 2024).

Indices: WTI -407,705,107 (2025) vs -303,277,607 (2024); WAI -664,536 vs -496,703; BWI 2,329,144 vs 2,412,394 (page 111).

The targets cover the financial consolidation scope and were set voluntarily. Trend analysis and analyst and investor requirements were considered, and they follow the Water Policy. Effectiveness is checked through internal assessments (page 111).

Water consumption

Reference: pages 111-112.

Consumption was 6,778,048 m3 in 2024 and 6,260,816 m3 in 2023. Intensity: 645.79 m3 per million euros of revenue (740.93 in 2024). Withdrawal sources shown include surface freshwater, groundwater, rainwater, supply network, water from wastewater, pre-treated water at Cadagua and recycled water, with pre-treated water at Cadagua the largest at 4,328,765 m3 (page 111).

Water-stressed areas are the countries where Ferrovial operates: Australia, Chile, Colombia, Spain, France, Poland, Portugal and Turkey (page 112). Discharge of sanitary and vehicle-wash water is estimated (page 79). 2022-2024 figures were restated, and HS2 Main Works and Ontario Transit Group Constructor GP are excluded as not relevant (page 111).

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: pages 114-116.

Ferrovial builds nature into strategy through its Biodiversity Policy, applied across the company and value chain. Principles: conservation of species and ecosystems, the mitigation hierarchy, responsible use of natural resources, combating deforestation, nature-based solutions, natural capital in risk management, and "no net loss" moving toward "net positive impact" (page 114). The dated nature targets sit under E4-4.

Resilience analysis (pages 114-116): follows TNFD LEAP, covers own operations and the value chain, and weighs physical, systemic and transition risks. Four TNFD scenarios were used (#Ahead of the game, #Go fast or go home, #Sand in the gears, #Back of the list) at three horizons: current, 2030 and 2050, matching its climate horizons.

Responses: ADAPTARE for physical risk; INCA (Integrated Natural Capital Assessment) to estimate project impact on biodiversity and ecosystem services; and a "Go - No Go" procedure approved in 2025 setting environmental criteria for new projects. Five stated assumptions include the mitigation hierarchy and community consultation (page 116).

Policies related to biodiversity and ecosystems

Reference: pages 117-118.

The Biodiversity Policy covers regulatory compliance, protection of sensitive areas, responsible management of natural resources, combating deforestation, biodiversity in risk management, monitoring targets, and training and awareness (page 117). On deforestation it sets acquisition of certified wood as a principle, plus restoration and reforestation. It applies to all Group companies and subcontractors.

Linked IROs (page 117): impacts on protected areas and endangered species, "no net loss", and risks from scarce ecosystem services (natural resources, climate regulation, soil structure).

Scope: Ferrovial SE and Group companies, governing body members and employees, worldwide, covering owned, leased or managed sites including those in or near sensitive areas, with no exclusions (page 118). Approved by the Quality and Environment Steering Committee; the Board approves the Sustainability Policy above it. Consistent with the UN Convention on Biological Diversity, TNFD, the Kunming-Montreal framework and CITES. It reaches suppliers through the Suppliers' Code of Ethics, is on the website and has had no changes (page 118).

Actions and resources related to biodiversity and ecosystems

Reference: pages 118-120.

Where a project has an Environmental Impact Assessment, Ferrovial applies the required measures under the mitigation hierarchy, some compensatory. It states it "has not implemented any biodiversity offset measures as part of its action plans to date" (page 118).

2025 actions (page 119):

• "Ecological hydroseeding" on shotcrete slopes at the Oural tunnel (Monforte to Lugo, Spain), using a high-adhesion substrate and a seed mix of mosses and lichens, intended to need little upkeep and avoid plastic meshes.
• An artificial reef at Port Olimpic, Barcelona, of 3D-printed biotopes in five designs installed in 2024, with underwater cameras and sensors. In 2025, a year after installation, more than 100 marine species were identified.

Aims: nature-based solutions, TNFD-based decision-making, resilience to impact risks, and protecting areas of special interest. The report says no indigenous populations are located where the actions took place (page 119). Staffing in Quality and Environment departments is described under E3-2 (page 120).

Targets related to biodiversity and ecosystems

Reference: pages 120-121.

Three nature-specific targets:

1. TNFD-based nature disclosures begun in FY2025 (baseline: first TNFD report in 2024), covering global operations and material value chain activities. TNFD included Ferrovial's report in its list of reporting examples in 2025.
2. Neutralize 100% of residual GHG emissions by 2050 through nature-based solutions. In 2025 Ferrovial offset 29,062 tCO2e, 24.7% from nature-based projects. No base year.
3. "Go / No go" procedure on 100% of projects of controlled subsidiaries above a significant budget. No milestones or base year.

Existing climate, water and circular economy targets are also mapped to the mitigation hierarchy: avoidance (Go / No go, GHG and water footprint targets), minimization (circular economy targets of 70% C&D waste recovery and 80% soil reuse) and restoration or compensation (100% neutralization, water compensation of 70 times the BWI) (page 121).

Targets were built with the Kunming-Montreal framework and the EU 2030 Biodiversity Strategy; "no ecological thresholds were applied" and no offsets were used in setting targets (page 121). Ferrovial may consider Science-Based Targets for Nature.

Impact metrics related to biodiversity and ecosystems change

Reference: pages 122-125.

Sites in or near protected areas (page 122): Ferrovial detected 113 sites within or near protected areas or areas key to biodiversity in 2025, covering 9,457 hectares. The method changed from counting protected areas to counting assets in or near them, so 2024 is not comparable (page 122, footnote 6).

Species (page 122): a table counts species on the IUCN Red List and on regional or local lists whose habitats lie in areas affected by operations, split by conservation status from Critically Endangered to Least Concern.

Named areas: the report lists priority locations (for example Isle of Wight Area of Outstanding Natural Beauty in the UK, Rocky Run Stream Valley in the US and Dalaman Wetland in Turkey) and many other protected areas by country, in Spain, Poland, Chile, the UK, the Czech Republic and elsewhere (pages 122-125).

Restoration and consents (page 125): 73 restoration actions in 2025 (89 in 2024); 30 new projects with an Environmental Impact Statement or equivalent (42 in 2024).

Land-use change (page 125): 9 assets saw land-use change since project start, mainly cropland and forest land turning to settlements.

Policies related to resource use and circular economy

Reference: pages 126-127.

The Quality and Environment Policy carries the circular economy principles. Ferrovial applies eco-efficiency through efficient use of resources and the reduction, reuse or recycling of waste, explores waste management as a business, and aims to move away from virgin resources by using recycled and renewable materials and sustainable sourcing (page 126).

Linked IROs: impacts: higher raw material use and waste in construction, and efficient use through reduction, reuse and recycling. Opportunity: new business through authorized waste management (page 126).

Scope: Ferrovial SE and Group companies, governing body members and employees, worldwide, across the value chain, with no exclusions. The Board approves it and the Quality and Environment Committee implements it; it is prepared under Dutch Corporate Governance Code recommendations 2.1.5 and 2.1.6, is on the website and has had no changes (page 127).

Actions and resources related to resource use and circular economy

Reference: pages 127-128.

The Circular Economy Plan applies the waste hierarchy: avoid waste, raise reuse and recycling through on-site segregation, use other recovery, and dispose only as a last resort (page 127).

Actions (pages 127-128):

• Zero Waste certification renewed in 2025 by SGS for projects in Spain, Portugal, the UK, Australia and the US (minimum 90% of waste recovered, at most 10% to landfill).
• Albertia Tunnel (Basque high-speed line): more than 15,000 tons of concrete reused on site; 8,000,000 litres of water reused since August 2023.
• Alamo NEX I-35, San Antonio: 13,165 tons of crushed concrete reused, 2,532 tons of asphalt milled and reused, 5,000 tons of metal recycled in 2025.
• Cadagua BIOKAR project (2025-2027): turning sewage sludge into biochar to remove emerging contaminants.

Staffing in Quality and Environment departments is covered under E3-2 (page 128).

Targets related to resource use and circular economy

Reference: pages 128-129.

The Circular Economy Plan sets three targets that follow the waste hierarchy (page 128):

• Recover at least 70% of non-hazardous construction and demolition waste each year (EU Taxonomy level): 76% in 2025 (75% in 2024).
• Reuse or recover 80% of excavation soils each year: 87% in 2025 (90% in 2024).
• Cadagua treatment plants to recover 80% of sewage sludge for agricultural use, composting or thermal drying: 85% in 2025 (76% in 2024).

The targets cover the financial consolidation scope and were set voluntarily. Trend analysis and analyst and investor requirements were considered, and they follow the Quality and Environment Policy. Effectiveness is checked through internal reviews (page 128). The report ties the targets to reuse and recovery strategies that cut primary raw material use (page 129).

Resource inflows

Reference: page 129.

Ferrovial reports materials purchased by weight, concentrated in construction. Total 2025: 15,898,779 t (17,758,020 t in 2024). The text prints these as "million tonnes", but the table is in tonnes.

Biological materials are not material in its purchases. Weights come from recorded purchases per project; where weight is missing, a price-to-weight conversion with material and country price benchmarks is used, with stated uncertainty from price changes, mixed invoices and currency (pages 129, 79). HS2 Main Works (15% share) is excluded as not relevant (page 129).

Resource outflows

Reference: pages 129-131.

Waste is the outflow Ferrovial reports. Most of it comes from construction: construction and demolition waste (stone: concrete, asphalt, mixes; other: wood, plastics, cardboard, metals, ceramics, gypsum) and excavation soil. Water treatment adds sewage sludge, sand, fats and oils. Hazardous waste includes hazardous product packaging, contaminated absorbents, used oils and contaminated soil. Radioactive waste is not generated (page 131).

Share of waste (page 130): 86% was diverted from disposal in 2025 (88% in 2024), and 94% was non-recycled waste, 26,809,107 t (93% in 2024).

Waste is reported by every business line through a corporate tool, using operational control; where the treatment is unknown, Ferrovial assumes disposal. No estimates were made, and no outside body validated the metric (page 131). Joint operations HS2 Main Works, Ontario Transit Group Constructor GP and Metro Paris Ligne 3A are excluded as not relevant (page 130). Tonnages are under E5-5-Waste.

Waste

Reference: pages 129-131.

The fall in non-hazardous waste reflects less construction and demolition waste; the rise in hazardous waste is because one construction company generated very little in 2024 (page 129).

Separate tables (page 130): construction and demolition waste was 2,118,613 t in 2025 (1,614,439 t diverted, 504,174 t to disposal); excavation soil was 25,922,133 t (22,640,275 t diverted, 3,281,858 t to disposal, almost all to landfill).

2024 was restated to add Webber's construction and demolition waste, and excavation soils and construction and demolition waste are now in the total (pages 80, 130).

Policies related to own workforce

Reference: pages 133-136.

Five policy tables are given:

• Global Anti-Harassment and Anti-Discrimination Policy: dignity, equal opportunity and confidential handling of allegations; covers employees, contractors and relevant third parties; the CEO approves it (pages 133-134).
• Human Rights Policy: health and safety, freedom of association and collective bargaining, equal opportunity, child and forced labor, community and indigenous rights, privacy; covers entities under Ferrovial's control, suppliers and partners. The Board updated and approved it on 18 June 2025 (page 134).
• Flexibility and Work-Life Balance Policy: leave options, sabbatical, flexible hours; applies to Group staff in Spain only; the CEO approves it (page 135).
• Health and Safety Policy: global, no exclusions; the Board updated it on 18 December 2025 (pages 135-136).
• Belonging and Inclusion Policy: equal opportunity regardless of age, gender identity, disability and other characteristics; global; the Board updated it on 28 May 2025 (page 136).

Each table links the policy to its material IROs, and several name the Ethics Channel as a route for concerns. The Human Rights Policy table lists exclusions as "Not explicitly stated" (page 134).

Taking action on material impacts on own workforce

Reference: pages 139-141.

Working conditions (pages 139-140): the Equality Plan applies only in Spain and has more than 80 initiatives; the Digital Disconnection Policy and the Flexibility and Work-Life Balance Policy also apply to employees in Spain. Ferrovial says its whole workforce is covered by the labor law and collective agreements that apply to it, and in Construction in Spain 100% of workers are represented by trade unions. In Construction it also has a global framework agreement with unions and BWI (Building and Wood Workers' International, more than 350 unions).

Health and safety (pages 140-141): 293,432 hours of occupational health and safety training in 2025. The Board monitors health, safety and well-being at each meeting. The HSW Strategy, approved in December 2019 and extended to 2026, targets serious injury and fatality prevention, with four well-being pillars: physical, mental and emotional, social and financial. 95% of respondents say well-being improves their motivation and productivity (page 141).

Training (page 141): 593,314 hours in total, of which 299,881 general and 293,432 health and safety. For the energy transition, support includes re-skilling, career counseling, coaching, internal relocation and early retirement plans (page 140).

Targets related to own workforce

Reference: pages 141-142.

The statement opens with "no specific quantitative targets have been set" and then gives two measurable ones (page 142):

• Leadership gender balance: at least 30% women and 30% men in the Leadership Team (management positions as defined in the Dutch Corporate Governance Code, excluding US employees) by December 2025. At year-end 2025 women were 29%. Ferrovial says it is "very close" and gives reasons: women are underrepresented in infrastructure disciplines and promotion depends on role availability and mobility.
• Serious Injury and Fatality Frequency Rate (SIF-FR): cut by 31.8% in 2026 against 2022 (0.69 in 2022), with milestones of 10% (2023), 19% (2024) and 27.1% (2025). It covers employees and subcontractors on all direct Group operations. Ferrovial built its own method because no international standard exists.

Other objectives are policy-based: the Spanish work-life balance rights, social dialogue records (minutes of the National Negotiating Committee and works councils), and training goals set in annual goal-setting with line managers (pages 141-142).

Characteristics of the undertaking's employees

Reference: pages 143-144.

Headcount: 22,609 employees at end 2025, down from 25,501, mainly because of the divestment of Ferrovial Services Chile and Broadspectrum Chile. 18,225 men (80.6%), 4,384 women (19.4%), none reported as other.

Contracts: 19,839 permanent and 2,770 temporary; 22,319 full-time and 290 part-time; no non-guaranteed hours.

Regions: Europe 15,172; America 7,122; Asia 189; Oceania 125; Africa 1.

Largest countries (page 144): Poland 6,988; Spain 6,297; United States 4,948; Canada 1,262; United Kingdom 1,148; Chile 628; Germany 525.

Hires and turnover: 7,478 new hires (16,043 in 2024), 13.81% filled by internal candidates; turnover 26.6% against 58.7%, with 5,574 leaves (15,541 in 2024), again mainly explained by the Chile divestments (page 144).

Data come from Workday, uploaded to Workiva; no estimates are used for headcount. Joint venture employees are included where Ferrovial manages them and in reported indicators where partners do (page 143).

Collective bargaining coverage and social dialogue

Reference: pages 145-146.

56% of the global workforce is covered by collective bargaining agreements: 12,574 employees, 55.62% (60.90% in 2024).

Workplace representation (page 145): in the EEA (Spain and Poland), 11,621 employees, 51.4% of the total (37.8% in 2024); outside it (USA and Chile), 509 employees, 2.25% (29.5% in 2024, down because of the Chile divestments).

Ferrovial has no European Works Council; each European company has its own union representation, and a 2012 Framework Agreement with UGT FICA, Comisiones Obreras and an international union federation applies (page 146). It says more information on coverage outside the EEA should be provided (page 146).

Diversity metrics

Reference: pages 145-146.

Gender in the workforce (page 146): 80.61% men, 19.39% women. In management positions of all levels, 78.24% men and 21.76% women; in junior management 78.01% and 21.99%; in top management (up to two levels from the CEO) 75.29% and 24.71%. In revenue-generating management roles 84.06% and 15.94%; in STEM positions 84.30% and 15.70%. Apart from the overall workforce split, these indicators are entity-specific.

Governing and senior bodies (page 145): the Executive Committee had 2 women of 11 members (18.18%; 23.08% in 2024); BU Executive Committees and Corporate Directors 25.68%; Affiliate Executive Committee and Heads of Department 25.48%; Managers 21.99%; Senior Professionals 35.80%; Blue Collar 4.50%. The Board has 4 women of 12 (page 73).

Age (page 146): 4,248 employees under 30, 11,799 aged 30-50, 6,562 over 50. Managers and higher: 3,805 (78% men, 22% women). The fall in the over-50 group reflects the Chile divestments.

Adequate wages

Reference: page 147.

Ferrovial tests adequacy each year against Living Wage Foundation data. In the countries where it is most active (Australia, Canada, Chile, Colombia, Germany, Poland, Portugal, Puerto Rico, Spain, Turkey, the United Kingdom and the United States), 99.61% of employees earn above the living wage. For the remaining 0.39%, in Brazil, France, India, Ireland, Italy, the Netherlands, Peru, Saudi Arabia, Slovakia and Tunisia, "additional measures are being evaluated".

EEA: pay is checked against legal minimum wages; where there is none, the lowest salary is compared with 60% of the national average wage and 50% of the average gross wage, in line with Directive (EU) 2022/2041. In Spain, wages exceed the construction sector minimum wage tables, with specific exceptions and for new hires with experience.

Outside the EEA: Ferrovial complies with local minimum wage law, and where none exists it uses international reference indices and the Wage Indicator Foundation, Fair Wage Network and Anker methods.

Persons with disabilities

Reference: page 147.

172 employees with a disability at 31 December 2025 (175 in 2024), 0.8% of the workforce at year end.

Ferrovial uses the definition in the Spanish General Act on the Rights of Persons with Disabilities and their Social Inclusion (LGDPD), which counts people with physical, cognitive, intellectual or sensory impairments likely to be permanent, including those granted a permanent disability pension.

Disclosure is voluntary. To be recognized and receive related benefits, an employee uploads an official certificate to the HR system. Data sit in Workday, which holds data on all employees (page 147).

Related measures appear elsewhere: partnerships with disability organizations and adjustments for employees with disabilities or dependants with disabilities under the Work-Life Balance Policy (pages 135, 139).

Training and skills development metrics

Reference: page 148 (also page 191).

593,314 training hours in 2025, an average of 26.2 per employee (27.0 in 2024). Women averaged 48.9 hours (46.7 in 2024) and men 20.8 (22.8).

By category, total hours were: Executive Committee 93; BU Executive Committee and Corporate Director 7,376; Affiliate Executive Committee and Heads of Department 34,083; Business Positions Leads 29,111; Managers 178,727; Senior Professionals and Supervisors 109,622; Professionals 166,050; Administrative and Support 39,569; Blue Collar 28,683 (page 191).

Ferrovial says it "applies the phase-in approach this year exclusively over quantitative performance evaluation data" (page 148), so quantitative performance evaluation data are not given. Health and safety hours are included, with the gender and category split estimated from the other hours. Cybersecurity hours are about 1% of the total and are excluded (pages 79, 148).

Health and safety metrics

Reference: pages 148-149.

Fatal accidents: 0 involving employees (2 in 2024) and 2 involving contractors (5 in 2024). Days lost: 9,624. Work-related health issues among employees: 3 (7 in 2024). Severity rate 0.2; absenteeism rate 3.4 (4.9 in 2024); 1.6 million absenteeism hours; occupational disease frequency rate 0.1.

Coverage: 70% of workers are covered by an occupational health and safety management system such as ISO 45001 (80% in 2024), reflecting divestments of certified units (page 148).

By gender (estimated hours, page 149): 279 recordable incidents among men and 12 among women; recordable frequency rate 7.19 for men and 1.32 for women. Page 149 states rates are given only as ratios, and gender hours are estimated from workforce shares.

Compensation metrics (pay gap and total compensation)

Reference: page 149 (also pages 189-190).

Gender pay gap, average salary: 4.54% in 2025, up from 2.10% in 2024 and -0.65% in 2023. Formula: (men's salary minus women's salary) divided by men's salary. A positive figure means men earn more.

Ferrovial says the shift towards men comes partly from including the Executive Committee and from the Chile divestments, which changed the workforce profile. The sample is 96.40% of the workforce (Canada, Chile, Germany, Poland, Spain, the United Kingdom and the United States); two people were not classified as female or male. 2025 uses actual annual variable pay, where 2024 used the target.

Annual total compensation ratio: 160.88 in 2025 (194.09 in 2024), the highest paid executive's total pay against the median employee pay (base salary annualized plus actual supplements).

Hourly wages are estimated from total hours and year-end gender shares (pages 79, 149). Average Director pay in 2025 was EUR 200 thousand for men and EUR 170 thousand for women (page 190).

Incidents, complaints and severe human rights impacts

Reference: page 149.

50 incidents of discrimination, including harassment, in 2025 (58 in 2024), reported through the Ethics Channel and other platforms: 8 of discrimination and 42 of harassment. All have been investigated and resolved or are under investigation.

Severe human rights incidents: none. No fines, penalties or compensation were recorded for such incidents and grievances.

Other communications: 174 on matters such as privacy data and conflicts of interest (123 in 2024).

The Ethics Channel breakdown on page 170 agrees on discrimination or harassment (50 reports in 2025, 58 in 2024) and also shows 12 corruption and bribery reports, 8 privacy data reports and 6 conflict of interest reports.

Policies related to value chain workers

Reference: pages 151-154.

Policies in the tables: the Sustainability Policy (all Group entities), the Global Purchasing Policy (ESG principles in supplier selection, with the Suppliers' Code of Ethics and the Ethics Channel), the Suppliers' Code of Ethics (updated in 2025; sets ethical principles, allows audits and termination, and bars child labor, forced labor and human trafficking) and the Anti-Harassment and Anti-Discrimination Policy by reference to S1 (pages 151-153). All apply worldwide with no exclusions; the Board approves the first two, and the CEO approves the Code (page 153).

The Human Rights Policy, introduced in 2014, updated in 2022 and again approved by the Board on 18 June 2025, covers the whole value chain (page 153). Ferrovial states there were no severe human rights incidents along the value chain. A Due Diligence Procedure evaluates collaborations, partnerships and procurement, and the Supplier Quality Evaluation and Follow-up Procedure tracks supplier performance (page 153). Contracts carry human rights and labor clauses (page 150).

Taking action on material impacts on value chain workers

Reference: pages 155-156.

Actions (page 155):

• Supplier assessment with ESG criteria, supported by Supplier 360, with outcomes of warning, improvement plan or disqualification.
• The free "Training Program Sustainable Suppliers" for SMEs, with the UN Global Compact in Spain and the UK, ICEX and the ICO Foundation.
• The Ethics Channel, which suppliers must confirm they know.
• The Suppliers' Code of Ethics, accepted before contracting.

A supplier with three negative evaluations in a year is proposed for disqualification and, once the proposal is reviewed and approved, may no longer work with Ferrovial. Incident steps are formal notice, tailored improvement plans and disqualification criteria under the Construction Supplier Quality Assessment and Monitoring Procedure.

The actions cover Ferrovial's own activities and its upstream value chain worldwide (page 155). Suppliers in high-risk sectors or countries are flagged, and contracts bar child labor, forced labor and trafficking (page 156). Ferrovial says it identified or received no reports of serious human rights violations in its upstream or downstream value chain in 2024 and 2025 (page 156).

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

Reference: page 156 (see also pages 164, 172).

The S2-5 section states no target for value chain workers. Ferrovial states it "continuously assesses the effectiveness of its sustainability targets and initiatives through internal evaluations and stakeholder engagement", with no formal process for working with value chain workers or their representatives on lessons learned (page 156).

It also says it "has not yet defined specific objectives or targets in relation to the participation of credible spokespersons for workers' representatives", and that this "could be further strengthened" in future (page 156).

A related supplier target sits outside S2: Ferrovial Construction aimed to evaluate suppliers representing at least 60% of its 2025 purchasing volume (page 164). Page 172 reports the result as 70.79% (see G1-2).

Policies related to affected communities

Reference: pages 157-158.

The Human Rights Policy (see S1-1) is the main policy for affected communities. Ferrovial says it respects the rights, culture and customs of local communities and minorities, with attention to vulnerable groups such as immigrants (page 157).

In 2025 it approved a procedure governing engagement with local communities: map the affected communities, with extra attention to vulnerable groups and any indigenous peoples; set up dialogue channels (hotlines, meetings, reporting mechanisms); assess human rights impacts and make any material risk public with the response; and report incidents and set objectives with stakeholders (page 157). It is still being developed in part, including its attention to indigenous, tribal and native peoples (page 158).

The Engagement and Relations with Stakeholders Policy covers shareholders, investors and local communities (page 158). Ferrovial says no cases of non-compliance with the UN Guiding Principles were reported, and no cases of violation of indigenous peoples' rights were detected in 2024 and 2025 (page 158).

Taking action on material impacts on affected communities

Reference: pages 161-163.

Ferrovial runs environmental and social impact studies before execution and a go/no go decision process; risk assessments for each project or asset run every six months (page 161). Its engagement procedure applies to projects above EUR 50 million or any project with a material social risk. Financial resources are in project budgets and are "not itemized separately" (page 161).

On the Move for People (pages 161-162): On the Move for Water funds three projects a year in Africa, Latin America and India (up to EUR 150,000 each); Zero Hunger refurbishes soup kitchens; Education promotes STEM; On the Move Together involves employees, with 1,456 volunteers in 2025.

2025 results (page 162): 388 community initiatives benefiting 348 organizations and more than 399,000 people. Community investment was EUR 4.61 million (8.31 million in 2024, which included emergency aid for the Valencia floods and Hurricane Helene).

Ferrovial says no material negative or systemic impacts on communities were identified in recent years, and reports a social return of EUR 9.4 per euro invested (page 163). At HS2 it holds monthly community liaison meetings and issues advance works notifications.

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

Reference: page 164.

Ferrovial states that it "has not established quantitative targets in this area". It says that, within its 2030 Sustainability Strategy, it sets specific targets with deadlines to reduce negative impacts on affected communities and promote positive effects, and that it works with affected communities, their representatives and sustainability experts to define, monitor and improve them.

The local communities engagement procedure is described as the first step towards setting targets with communities. Results are to be broken down by affected community, with the support of the UN Global Compact, GRI standards and the EU Taxonomy.

The only target on the page is a supplier one: Ferrovial Construction aimed to evaluate suppliers representing at least 60% of its 2025 purchasing volume (page 164). For upcoming years Ferrovial has set no global community investment commitment, only specific annual programs (page 162).

Business conduct policies and corporate culture

Reference: pages 166-171.

The Board approves and supervises the Compliance Program, whose policies include the Anti-Corruption Policy, Compliance Policy, Ethics Channel and Management of Queries, Reports and Complaints Policy, and the Code of Ethics and Business Conduct (updated May 2025) (pages 166-169). Each table gives objectives, linked IROs, scope (global, with the Code applying to all Group companies) and follow-up.

Culture (page 169): a first Global Compliance Week in November 2025; a Compliance Network of about 56 employees plus about 36 Compliance Ambassadors (92 in total); a Privacy Network of 39; and an Ethics Council meeting quarterly.

Training (pages 169-170): the Code refresher reached 4,941 employees, blue-collar training reached 5,229, and mandatory training totaled 15,223 hours (27,073 in 2024).

Ethics Channel (page 170): 224 reports in 2025, up 24% from 181; 91 (41%) anonymous; 71 (32%) substantiated; corrective measures in 100% of substantiated cases. Whistleblower protection follows Directive (EU) 2019/1937. Third parties must accept the Code and Anti-Corruption Policy (page 171).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed through MDR-T rather than a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Ferrovial's G1 chapter has one stated target: Ferrovial Construction's measurable indicator to evaluate suppliers representing 60% of total purchasing volume by 2025, achieved at 70.79% (pages 164, 172).

It also tracks effectiveness of its conduct measures:

• The Chief Compliance Officer reports to the Board at least once a year on the effectiveness of the Compliance Program, and Internal Audit audits it (page 172).
• Awareness of the Ethics Channel is surveyed after mandatory training: 95.5% aware of the channel, 97.05% aware of the retaliation rule (page 171).
• Ethics Channel volumes, anonymity and substantiation rates are reported yearly (page 170).

No numeric target is given for corruption cases or training coverage in the G1 chapter. Page 78 says all Minimum Disclosure Requirements were fully addressed, except for the CapEx and financial resources breakdown.

Incidents of corruption or bribery

Reference: pages 170, 173.

Ferrovial states it "did not receive any convictions or fines related to violations of anti-corruption and anti-bribery laws in either 2024 or 2025" (page 173).

The Ethics Channel received 12 communications on corruption and bribery in 2025 (10 in 2024) out of 224 reports in total (page 170). The report notes that most communications relate to internal fraud or misappropriation by employees or collaborators, and that no reports of potential bribery of public officials or influence peddling involving Group companies were received (page 170).

Remediation of substantiated reports is mainly disciplinary action including termination, training, or changes to processes, applied in line with collective agreements and local law; corrective measures were taken in 100% of substantiated cases (page 170).

The G1-4 section is one sentence and gives no separate figures for dismissals, disciplinary actions or contract terminations tied to corruption.