Fincantieri S.p.A.

Governance roles

Reference: pages 120-126 (statement index lists GOV-1 at p.120).

The Board of Directors of Fincantieri S.p.A. had 10 members at 31 December 2025: 8 non-executive directors and 2 executive directors (the Chairman and the CEO). 40% are women and 60% men, a female to male ratio of 0.67 (p.122). The Board "does not include members representing employees or other workers" (p.122). Paolo Amato was appointed Lead Independent Director on 29 May 2025 (p.124).

Committees (pp.121-122): Control and Risk, Remuneration, Nomination and Corporate Governance, and Sustainability. All committee members are non-executive and the majority are independent (70%). The Nomination and Sustainability Committees are fully independent.

Sustainability role (p.120): the Board approves the sustainability guidelines and policies, the Parent Company's Sustainability Plan and the double materiality assessment. It approves the sustainability statement after the Sustainability Committee has reviewed it.

Expertise (pp.124-125): the Board's self-assessment shows environmental expertise at 90%, social at 100%, cybersecurity at 60% and artificial intelligence at 50%. Directors receive sustainability induction (p.124).

Management (pp.125-126): the Administration, Finance and Control Department directs the Sustainability Function, which runs the double materiality assessment, drafts the Sustainability Plan and reports to the Sustainability Committee.

Information provided to the governance bodies

Reference: pages 126 (see also GOV-1, pp.120-125, and SBM-3, pp.140-151).

The report says sustainability governance relies on internal procedures so that the administrative, management and supervisory bodies and Top Management take part in material sustainability matters. The bodies act as "managers, validators or approvers" in the process, from identifying impacts, risks and opportunities (IROs) and stakeholder dialogue to setting strategic guidelines and monitoring targets (p.126).

All IROs feed into strategy development and risk management, with continuous monitoring by the bodies or their committees. The results of the double materiality assessment were reviewed by the governance bodies; the Sustainability Committee validated them on 15 December 2025 and the Board approved them on 16 December 2025 (p.140).

Sustainability Plan targets are monitored quarterly, presented to Top Management and shared every six months with the Sustainability Committee (pp.136-137). The Committee also meets periodically with management to review due diligence, policies and metrics (p.126).

Sustainability-linked incentives

Reference: pages 126-127 (E1 cross-reference at p.161).

The 2025 Remuneration Policy covers the Chairman, the CEO and General Manager and Parent Company Top Management. The Board approves it each year on the proposal of the Remuneration Committee (p.126).

Short-term plan (MBO), p.127: the CEO's MBO keeps a sustainability index at 20% of total variable remuneration. It has three parts: climate (reduction of Scope 1 and 2 GHG emissions), health and safety (access gate: severity index within 0.2; target: frequency index below 7.5 for 2025) and sustainable supply chain (an ESG score for at least 95% of qualified strategic suppliers, 950 of 1,000). The report text gives the climate target as "-4% of GHG Scope 1 and Scope 2 emissions by 2021"; the year looks like a typo for the baseline, which a reader should check.

Long-term plan, p.127: the Shareholders' Meeting of 14 May 2025 approved the 2025-2027 LTI Plan. It keeps an objective linked to a sustainability index at 25% weight, based on the Sustainability Plan targets (Scope 1 and 2 reduction and Scope 3 category 11).

The report also says all "high risk employees" fall under the same MBO mechanisms, including the clawback clause (p.127).

Statement on due diligence

Reference: pages 128-130.

GOV-4 maps where each core due diligence element appears in the report: governance (GOV-2), policy commitments (S1-1, S2-1, S3-1, G1-1), engaging stakeholders (SBM-2, S1-2, S2-2, S3-2), identifying and assessing impacts (SBM-3, IRO-1), taking action (S1-4, S2-4, S3-4, G1-2, G1-3), and tracking effectiveness (metrics and targets of S1, S2, S3, G1) (p.128).

The human rights due diligence process has six steps and began in 2023 with identifying salient human rights issues: child labor, forced labor and human trafficking, freedom of association and collective bargaining, decent working conditions, health and safety, privacy, rights of local communities, and environmental and biodiversity protection (p.128).

The Human Rights Risk Assessment flagged Romania and China as countries with a child and forced labor risk where a material number of suppliers sit. The report says existing control measures "significantly reduce the actual risk" (p.129). Safeguards include the Suppliers' Code of Ethics as a binding contract clause, ESG supplier qualification, a supplier monitoring structure and on-site audits (p.129).

In 2025 the Group issued a "Human Rights Due Diligence" Global Procedure. Monitoring is annual and feeds a report to Top Management (p.130).

Risk management and internal controls over sustainability reporting

Reference: page 130.

The Group runs an Internal Control System over Sustainability Reporting (ICSSR) built to meet the ESRS. It uses the COSO Internal Control Integrated Framework and COBIT as assessment tools and is integrated into the Group's Internal Control and Risk Management System (p.130).

The scope is set by risk priority: companies are in scope if they contribute enough to Group totals to meet the threshold for the individual reporting indicators, with qualitative factors added for specific activities. Materiality follows the double materiality results (p.130).

Four main risks are named: information that is not timely, inaccurate, incomplete or not properly authorized. Mitigation uses process-level controls, entity-level controls and IT general controls (p.130).

The Officer in Charge monitors control effectiveness, with independent testing involving Internal Audit. A final report goes to the CEO and then the Control and Risk Committee, and the Officer in Charge reports annually to the Board and the supervisory bodies (p.130).

Strategy, business model and value chain

Reference: pages 130-139 (SBM-1 starts at p.131 in the statement index).

The Group employs 24,370 people (p.130). Group revenue and income were EUR 9,194 million in 2025 (p.180). The report refers readers to the Group Overview and the economic results chapters for the business model and segment revenue (p.130).

Value chain (pp.130-135): updated in 2025 to include the infrastructure cluster alongside shipbuilding. Six phases: contract acquisition, design, procurement, execution (ship manufacturing and construction), after-sales, and use and final disposal. Fincantieri acts as system integrator in shipbuilding and relies heavily on contractors under close supervision. Customer groups are cruise, naval, ferry, equipment, systems and services and infrastructure, and offshore and specialized vessels (p.134). The Underwater segment is not yet mapped; its value chain analysis is postponed to 2026 onward (pp.130, 152).

Strategy (p.136): the 2026-2030 Business Plan, approved 16 December 2025, has four pillars: doubling Defence production capacity in Italian shipyards, reorganizing the global production system, growing the Underwater segment, and self-financed investment with faster deleveraging. The 2026-2030 Sustainability Plan was approved at the same time.

The report states the double materiality assessment found no end-user categories exposed to significant risks from use of Group products (fn.13, p.135).

Interests and views of stakeholders

Reference: pages 136-139 (and topic-level cross-references at pp.206, 240, 252, 282).

Stakeholder categories listed with their engagement channels and frequency (pp.138-139): environment, human resources, suppliers, partners, community, trade unions, financial community, institutions and public administration, and customers. The Group also takes part in industry bodies such as Confindustria, Federmeccanica, ASSONAVE, SEA Europe and Norsk Industri Maritim (p.139).

Observations from engagement are "considered, processed and shared within the organization" and, where significant, feed business objectives, strategy and policy updates (pp.136-137). Stakeholder views on sustainability impacts are reported periodically to the administrative, management and supervisory bodies (pp.136-137).

For the 2025 double materiality assessment: around 40 company functions assessed impacts, and seven external stakeholders gave input (three trade union representatives surveyed on own-workforce impacts, plus three interviews with two opinion leaders and two trade association representatives) (pp.136-137, 154). The 2026-2030 Sustainability Plan objectives rest on the assessment, Group policies, benchmark results, stakeholder demands and the UN 2030 Agenda (pp.136-137).

On affected communities, the report says no further consultations were needed in the period (p.139).

Material impacts, risks and opportunities

Reference: pages 140-151 (topic chapters repeat the links to strategy: E1 pp.162-166, E4 p.192, S1 pp.206-207, S2 p.241, S3 p.252).

"The analysis carried out identified as material 42 impacts, 38 risks and 11 opportunities" (p.140). The Sustainability Committee validated the analysis on 15 December 2025 and the Board approved it on 16 December 2025 (p.140). Results fed the strategic priorities of the 2026-2030 Business Plan.

Impacts and financial-materiality risks and opportunities are listed by ESRS topic with policy, value chain location and time horizon (pp.140-151). Material topics: E1, E2, E3, E4, E5, S1, S2, S3, G1 and the entity-specific topic Cyber Security and Artificial Intelligence.

Changes in 2025 (p.150): Consumers and End-Users (ESRS S4) was found not material in line with the business model. The entity-specific topic Cyber Security and Artificial Intelligence was added; the Group links it to the cyber topic that sat under S4 the year before.

Financial effects (p.150): environmental risk provisions of EUR 7.2 million (Note 20); for the other material risks, no significant current financial effects, and no sign of a significant risk of asset or liability adjustments next year.

Processes to identify and assess material IROs

Reference: pages 152-154.

The Group updated its double materiality assessment in 2025 under EFRAG IG1 (materiality) and IG2 (value chain), in four steps: context analysis, identification, assessment and analysis of results (p.152).

Context (p.152): regulatory frameworks, human rights standards, global risk reports and scenario analysis, sector studies, the Enterprise Risk Management (ERM) system and earlier human rights and climate risk analyses. For the Underwater segment the value chain analysis was postponed to 2026 onward.

Impacts (p.153): 40 company functions or bodies rated impacts on likelihood and severity (severity combines scale or scope and irremediable character). Risks: assessed through an ERM campaign with around 100 internal stakeholders on probability and severity. Opportunities: assessed from Business Plan streams with Stream Leaders, on likelihood and severity.

Time horizons (p.153): impacts use the ESRS short, medium and long term; risks and opportunities follow the ERM and Business Plan horizons.

External input came from seven strategic stakeholders (p.154). The assessment is updated on Top Management signals or context changes, and the internal control system over sustainability reporting supervises the process (p.154).

ESRS disclosure requirements covered

Reference: pages 154-155 and Appendix pages 290-295 (statement contents index at pp.112-117).

The report says "A list of the disclosure requirements Fincantieri fulfils ... is included in the Appendix" and that where a requirement is not reported "the Group gives a clear indication of the case and the reasons" (p.154). The Appendix (pp.290-295) is a list of datapoints that derive from other EU legislation, each mapped to its disclosure requirement, with "Not material", "Not relevant" or an omission note where applicable. It is not a full 84-requirement concordance; the statement's contents index (pp.112-117) lists each disclosure requirement with a page number.

Omissions stated in the Appendix: E1-9 datapoints carry the note "Fincantieri omits the disclosure requirement in accordance with Appendix C of ESRS 1 and Commission Delegated Regulation (EU) 2025/1416" (pp.290-291). E1-7 is marked "Not relevant"; S4 and some E3-1 and E4-2 datapoints are marked "Not material".

Material topics and sub-topics (p.155): E1 (mitigation, adaptation, energy), E2 (air, soil, water pollution), E3 (water), E4 (impact drivers, species), E5 (inflows, outflows, waste), S1, S2 (working conditions, equal treatment, other work-related rights), S3, G1 (corporate culture, whistle-blower protection, supplier relationships including payment practices, corruption and bribery) and entity-specific Cyber Security and Artificial Intelligence.

Transition plan for climate change mitigation

Reference: pages 161-163 (targets at pp.176-178).

The report says: "Although it does not yet have a transition plan in line with the Paris Agreement, the Group has developed a decarbonization plan" (p.161). The plan covers levers, feasibility and mitigation and adaptation actions across the value chain (p.161).

Own operations: the strategy aims to cut Scope 1 and 2 emissions by 20% against a 2021 baseline and to use only renewable electricity by 2030. Main actions are electrification, new technology and digitalization of production steps (p.162). The targets are gross and, in the report's words, "not scientifically defined and aligned with science-based requirements" (fn.4, p.176).

Scope 3: category 11 (use of sold products) is almost 94% of total emissions (p.163). The report says an autonomous target is hard to set because customers define ship technical and operating requirements (p.161).

Product roadmap (pp.162-163): first LNG cruise ship delivered 2024; hydrogen fuel-cell auxiliary power in 2026; first methanol cruise ship in 2027; port-emission solutions by 2030; first net-zero cruise ship by 2035, subject to technology, market and certification. Offshore: first methanol-ready vessel delivered 2025, direct methanol propulsion in 2027.

"Fincantieri is not excluded from Paris-aligned Benchmarks" (fn.3, p.161). GHG reduction targets are part of the executive incentive plans (see GOV-3, pp.126-127).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 and the climate IRO-1 section, where this content is disclosed in the FY2025 report (pages 162-167). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Method (pp.163-164): a Climate Change Risk Assessment (CCRA) covered acute and chronic physical risks and transition risks over short, medium and long horizons. It started with the 18 shipyards (Italy, Brazil, Norway, Romania, Vietnam, United States) and about 3,800 strategic suppliers, then 35 further sites, using IPCC and Copernicus data.

Scenarios (p.164): Net Zero Scenario (equal to RCP 2.6, 1.5°C by 2100), Announced Pledges Scenario (RCP 4.5, "between 2 and 3°C by 2100") and Stated Policies Scenario (RCP 8.5, SSP5). IPCC projections and the IEA Net Zero by 2050 Roadmap were used. These include a high-emission physical scenario (RCP 8.5) and a 1.5°C scenario.

Results (pp.163-165): acute exposure is highest at Marghera, Riva Trigoso and Muggiano, then Ancona and Monfalcone; chronic exposure at Vung Tau (Vietnam) and Palermo, with water stress also at Ancona and Castellammare di Stabia. In the 2025 materiality analysis "no physical risks were identified as material"; two transition risks were (misalignment in adopting emerging technologies; technological lag against competitors) (p.163).

TCFD alignment dates from 2023, the CCRA from 2024 (pp.162-163).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 162-166). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report says that in 2024 the Group "conducted a resilience analysis of its strategy and business model with respect to climate change" using the CCRA, and that the work was folded into the Enterprise Risk Management process (pp.162-163). The report does not say the analysis was repeated in 2025.

What it shows: shipyards on the coast are "highly exposed to extreme weather events", with risk of damage, disruption, delays and contractual penalties (p.165). In the best-case scenario transition risk weighs more; in the less regulated scenario physical consequences weigh more (p.166).

Response measures (p.165): cranes with storm brakes, flood drainage, lightning protection, wind monitoring stations, an individual Mooring Plan for ships under construction, delay clauses in contracts, insurance against catastrophic events, supplier diversification for steel, and solar installations for own generation.

Strategy link (pp.162-163): the net-zero cruise ship roadmap, Navis Sapiens digital platform and cold ironing are presented as the strategic response. The report does not describe areas of uncertainty in the analysis or the Group's capacity to adjust over time.

Policies related to climate change mitigation and adaptation

Reference: pages 167-169.

Group Occupational Health & Safety, Environment, Biodiversity and Energy Policy (pp.167-169): updated in 2026. The update adds the "Protection of Biodiversity and Ecosystems" pillar and stronger decarbonization and pollutant emission commitments. Climate commitments include: assess and monitor environmental risks and impacts; improve energy performance to cut air emissions; develop technology toward zero-emission targets such as the Net Zero Cruise ship; use energy-efficient technology, renewable energy and self-generation; and raise staff awareness (p.169). The policy references the EU Green Deal, CSDDD, SBTi and SBTN guidelines, TCFD and TNFD (p.169).

Certification (p.169): ISO 14001 covers 100% of Italian shipyards and 89% of the Group.

Innovation Policy (p.169): updated in 2025 and approved by the Board. It commits to an Innovation Plan, product and process innovation across the life cycle, and partnerships with start-ups and universities. It binds all Group employees and subsidiaries adopt it by Board resolution.

Both policies are shared on the intranet and the website. Responsibility for implementation, monitoring and control sits with the Parent Company's Group Health, Safety and Environment Function, its Sustainability Function and the Operations, Investment and Industrial Asset Management Department (p.169).

Actions and resources in relation to climate change policies

Reference: pages 170-175.

Adaptation and innovation (pp.170-171): the Innovation Plan has five strands; the R&I program ran more than 180 projects in 2025, funded from own resources and European, national and regional programs, including IPCEI hydrogen and digital projects. Nine ship-design initiatives with lower environmental impact were delivered in 2025 (cruise: air lubrication, LNG cold recovery, absorption chiller, variable frequency drives; defence: probabilistic power balance, HVAC energy models, peak shaving) (p.171).

Product mitigation (pp.172-173): LNG ships delivered to Princess Cruises and Tui Cruises (with a green construction loan of up to EUR 415 million); methanol-ready offshore vessels delivered by VARD; the first hydrogen-powered ship ordered by Viking, due 2026.

Own operations (pp.173-174): LED relamping (over 6,000 MWh a year, about 2,900 tCO2e); compressed air plants at Ancona and Tulcea; extraction system upgrades at Marghera, Monfalcone and Palermo; ISO 50001 energy management; photovoltaic plants under EPC contracts and a "Solar Belt" project at Monfalcone (about 15 GWh a year each, around 8,000 tCO2e a year in total); a 10 GWh a year, 10-year PPA.

Resources (p.174): "costs exceeding euro 2 million" for own-operations GHG reduction in 2025, plus about EUR 21.5 million invested in Taxonomy-aligned low-carbon technology manufacturing.

Targets related to climate change mitigation and adaptation

Reference: pages 176-178.

Emissions targets (p.176): Scope 1 and 2 GHG emissions, baseline 2021 of 148,924 tCO2e. 2025 result: -7.4% against a -4% target. Next targets: -8% (2027) and -20% (2030). Share of electricity from renewable sources: 90% in 2025, 100% by 2030. Footnote 4 says the targets cover 100% of Scope 1 and 2 market-based emissions, are gross and were "not scientifically defined and aligned with science-based requirements".

Product targets (pp.176-178): the 2025 target was a 30% lower CO2 for cruise ships of equal tonnage and miles against the IMO EEDI-2008 baseline; ships delivered in 2025 averaged 41% lower (p.178). A later target is a 40% reduction with minimum port emissions. Milestones: first hydrogen-powered cruise ship (2026), first methanol-ready cruise ship (2027), first net-zero cruise ship (2035), where net-zero targets are subject to green fuel and port connection availability. The Scope 3 category 11 target area covers about 54% of the Group's total emissions (fn.9, p.176).

Other (pp.176-178): sustainable finance at 56% of medium and long-term funding (target 30%); 50% of special vessels delivered 2026-2030 to support energy infrastructure, mainly offshore wind; Underwater: 40% of civil revenue from GHG-reducing solutions by 2030.

The first year shown is the baseline, and targets cover the whole Group unless a perimeter is stated (p.177).

Energy consumption and mix

Reference: pages 179-180.

Total energy consumption was 850,952 MWh in 2025 (872,716 MWh in 2024). Fossil sources were 526,574 MWh (62% of the total in both years) and renewable sources 324,378 MWh (38%) (p.179).

Fossil detail: crude oil and petroleum products 304,602 MWh; natural gas 184,627 MWh; purchased energy from fossil sources 37,346 MWh; coal and nuclear zero. Renewable detail: purchased renewable electricity, heat, steam and cooling 312,002 MWh; self-generated non-fuel renewable energy 12,132 MWh; renewable fuels 244 MWh (p.179).

Electricity from renewable sources was 90% in both 2025 and 2024 (p.179). Photovoltaic plants under Energy Performance Contracts supplied 11,584 MWh of self-consumption, and a 10-year PPA delivers 10,000 MWh a year from January 2025. The Group also buys Guarantees of Origin (Italy, Romania, Norway) and Renewable Energy Certificates (United States, Brazil) (p.178). Electricity not covered by such instruments is counted as non-renewable, with no residual mix estimates (p.179).

Energy intensity (p.180): high-impact sectors are shipbuilding and infrastructure maintenance (NACE sections C and F). Intensity was 96 MWh per EUR million of net revenue from these activities (113 in 2024), on revenue of EUR 8,852 million.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 180-183.

None of Scope 1 comes from regulated emission trading schemes (p.180). Scope 3 category 11 (use of sold products) is 20,419,336 tCO2e, the bulk of the footprint. Category 1 purchased goods and services is 1,029,325 tCO2e. 2024 values for categories 11 and 15 were restated (p.180).

The report states "The percentage of primary data used for the calculation of the Group's Scope 3 categories is 0%" (p.180). Category 11 multiplies modeled annual emissions of ships delivered in the year by an assumed life of 20 to 30 years, using software from the subsidiary Cetena (pp.182-183). Categories 8, 9, 10, 13 and 14 are excluded as not applicable or not relevant (p.183). Biogenic Scope 1 emissions were 481 tCO2e (p.182).

Intensity: 2,369 tCO2e per EUR million of revenue market-based (2,326 in 2024) (p.183). Emission factors come from DEFRA 2025, Ecoinvent, AIB-2025, Terna, ISPRA and IPCC AR5 (p.181).

Policies related to pollution

Reference: pages 184-185 (policy text at pp.167-169).

The Group commits to assess and manage the risks and negative environmental impacts of its activities and to prevent incidents linked to pollution. It promotes best available technologies and lower-impact products, and runs improvement plans to contain emissions to air, water and soil (p.184).

The commitments sit in the Group Occupational Health & Safety, Environment, Biodiversity and Energy Policy. The report says the policy addresses mitigation of negative impacts from air, water and soil pollution, "including through prevention and control", and actions to avoid accidents and emergencies (p.184). E2-1 points back to E1-2 for the policy itself (pp.167-169).

Supporting controls: ISO 14001 environmental management systems at certified sites, training, emergency drills, dry docks with waste water collection and management of intermediate bulk containers (p.184). The Brazil shipyard and the Green Bay shipyard in the United States are not ISO 14001 certified (fn.19, p.185).

Actions and resources related to pollution

Reference: pages 184-185.

The Group names its most significant environmental aspects as inadequate management of atmospheric emissions and the risk of contamination of soil and water. It uses technology and continuous emission monitoring to keep within regulation (p.184).

Low-solvent paints (pp.184-185): more orders mean more painting, so the Group has kept its focus on volatile organic compound (VOC) emissions. Paint sheds were revamped to reach abatement levels above 80%. The Group is researching, testing and validating low-solvent and water-based products to replace traditional paints and has written them into the technical specifications of all current and future orders. The aim is to meet environmental permits that set local limits on maximum VOC use and emission.

Water and soil (p.184): site operational control and sampling programs check discharges against permit limits. Safeguards include training courses, periodic drills with the emergency team, dry docks with waste water collection and intermediate bulk container management.

The report gives no separate monetary figure for pollution actions in this section.

Targets related to pollution

Reference: page 186.

VOC target: the 2023-2027 plan target was a reduction of VOC emissions per hour of production against a 2021 baseline. The 2025 result was -10.0% against a -3% target (achieved). For 2026-2030 the target switches to VOC emissions per unit of revenue, "to ensure full comparability" with peers, with a baseline of 11.4 x 10^-2 tonnes of VOC per EUR million of revenue and reduction targets of -5% by 2027 and -8% by 2030 (p.186).

The targets cover the whole Group and the report notes they are voluntary because the Group is not subject to mandatory target setting by law (p.186). Stakeholder engagement, a context analysis, regulatory references and scientific evidence informed the targets (p.186).

2025 VOC emissions at the Monfalcone, Braila and Tulcea shipyards reached 506 tonnes, up from 448 tonnes in 2024, attributed to more painting (p.186). For these three shipyards the national emission limits and Regulation 166/06 reporting requirements are met (p.186).

Pollution of air, water and soil

Reference: pages 186-187.

The report consolidates pollutant emissions "only" from facilities that exceed the Annex II threshold value of Regulation (EC) No. 166/2006 (p.186).

Air: pollutants analyzed are VOC, nitrogen oxides, sulfur oxides, PM10, methane, benzene, ethylene oxides and polycyclic aromatic hydrocarbons. Where not measured directly, a calculation model uses natural gas and thermal fuel use and paint consumption, with ISPRA combustion emission factors. The model has uncertainty and does not account for abatement systems at emission points (p.186). VOC emissions at Monfalcone, Braila and Tulcea reached 506 tonnes in 2025 (448 in 2024) (p.186).

Water: emissions are estimated from chemical analyses of industrial waste water at Ancona, Marghera, Monfalcone, Muggiano, Riva Trigoso and Sestri Ponente. For sites without analyses, the amount of paint used is the proxy; the report cites literature showing a link between paint use and water pollutants. Using a conservative approach (highest concentration found at any site), the report states that, in line with 2024, no pollutant quantities in water exceed the Annex II threshold (p.186).

The pollutant quantity tables are not in the extracted text, so a reader should check pp.186-187 for per-pollutant totals. BP-2 lists pollutant emissions as a main estimation area (p.119).

Policies related to water and marine resources

Reference: pages 188-189.

The Group commits to sustainable and efficient water management where it operates, "with particular attention to those subject to water stress" (p.188). It promotes best available technologies and lower-impact products, and acts to contain consumption and limit negative effects on the environment and local communities (p.188).

The principles sit in the Group Occupational Health & Safety, Environment, Biodiversity and Energy Policy, which addresses water use and treatment in the context of a more sustainable water supply and the prevention and reduction of water pollution (p.188). E3-1 points to E1-2 for the policy text (pp.167-169).

The report states the marine resources sub-topic was not material in the double materiality assessment: ships are designed and built to eco-sustainability principles and impacts from ship operation depend on shipowners. The E3 section therefore focuses on water in production processes (pp.188-189). The Appendix marks the E3-1 "sustainable oceans and seas" datapoint as "Not material" (pp.292-293).

Actions and resources related to water and marine resources

Reference: pages 188-189.

Within the environmental management systems, the Group analyzes data from digital platforms to find large withdrawals, network losses and areas to improve. Meters across the water network supply remote withdrawal and discharge values for industrial water, available promptly for all sites in the country (p.188).

To preserve water, the Group limits discharges into surface water where technically feasible, with priority on repairing leaks in the water network (p.188).

After identifying Italian shipyards exposed to water stress and carrying out a market analysis, the Group plans to start work on a water balance at one Italian site, covering withdrawal, use and discharge, to complete the water diagnosis and improve processes and costs by 2026. Feasibility studies on process water reuse are under way (p.188).

The report notes the environmental impact on marine resources from operating the ship depends on how shipowners use and operate it (p.188). No monetary amount for water actions is given in this section.

Targets related to water and marine resources

Reference: page 190.

Water withdrawal intensity: the 2023-2027 plan target was a reduction of water withdrawal per hour of production against a 2021 baseline of 0.000097 ML per hour of production. The 2025 result was -21.9% against a -3% target (achieved) (p.190).

For 2026-2030 the target moves to withdrawal per unit of revenue, in cubic meters, "to ensure the full comparability" of metrics with peers. The 2021 baseline is 440 m3 per EUR million of revenue, and the target columns show -28% and -31% (p.190). The report does not label which years those two columns cover in the extracted text, so a reader should check the table.

The targets cover the entire Group and are voluntary, as the Group "is not subject to mandatory target setting by law" (p.190). The definition of targets took account of stakeholder engagement, a context analysis, regulatory references and scientific evidence (p.190).

Water consumption

Reference: pages 190-191.

Total withdrawal was 2,861,286 m3 in 2025 (2,901,790 m3 in 2024) (p.190). Consumption is defined as withdrawals minus discharges and "is mainly due to unidentified leaks, disposal of water not suitable for discharge, and the filling of on-board facilities" (p.190). It fell compared with 2024 because of monitoring campaigns and network repairs (p.190). Civil discharges are set equal to civil withdrawals; industrial discharges are measured where a meter exists, otherwise set equal to withdrawals (fn.21).

Areas of high water stress are the sites rated "Extremely high" in the WRI Aqueduct Tool: Palermo, Ancona and Castellammare di Stabia (p.190). Water intensity was 72 m3 per EUR million of revenue, about 24% below the 94 of 2024 (p.190). Stored water refers to fire-fighting storage.

Transition plan and consideration of biodiversity and ecosystems in strategy

Reference: pages 192-193.

The Group says it "is working on a biodiversity transition plan" to integrate protection of the natural environment into operations and the business model, to be developed over the medium term. The plan aims at compatibility of the Parent Company's activities with local, national and global biodiversity goals and the EU Biodiversity Strategy 2030 (p.192). It is still identifying and assessing impacts, dependencies, risks and opportunities. The report states "Although a resilience and adaptation plan has not yet been formalized", ongoing work will define specific strategies (p.192).

Site screening (p.192): a geolocation analysis of the 18 shipyards, started in 2024 and confirmed in 2025, used the World Database on Protected Areas and Key Biodiversity Areas (via IBAT) and the WWF Biodiversity Risk Filter (a method referenced by the Science Based Targets Network). In 2026 the Group will analyze in detail the impacts of production processes on biodiversity (p.192).

IRO result (p.193): the double materiality assessment found one material negative impact and one opportunity. None of the 18 shipyards is inside a Natura 2000 area, but 13 are near biodiversity-sensitive areas (p.193).

Policies related to biodiversity and ecosystems

Reference: pages 194-195.

In 2026 the Group updated its Occupational Health & Safety, Environment, Biodiversity and Energy Policy to formalize biodiversity principles, taking the Kunming-Montreal Global Biodiversity Framework into account (p.194). The policy covers all sites located near biodiversity-sensitive areas (p.194).

Commitments listed (p.194):

• promote a regenerative development model that limits negative impacts and supports EU ecosystem restoration targets
• define a nature and biodiversity strategy based on an assessment of dependencies, impacts, risks and opportunities
• apply the mitigation hierarchy, with avoidance first and minimization, restoration and offsetting only as secondary measures
• encourage sustainable use of natural resources across the product life cycle
• avoid interventions in areas of high ecological, biological or cultural value unless no viable alternative exists
• engage stakeholders, supply chain partners, local communities, NGOs and universities

The Appendix marks the E4-2 datapoints on sustainable land and agriculture practices, sustainable oceans and seas practices, and deforestation policies as "Not material" (pp.292-293).

Actions and resources related to biodiversity and ecosystems

Reference: pages 194-195.

LYNPHA (p.194): after the CIRCE circular economy project closed in 2024, a three-year research and innovation project started in 2025 to develop a life cycle assessment methodology for a cruise ship, including impacts linked to land use, ecosystems, acidification and pollutants.

Biodiversity project (p.195): launched in 2024 and running until 2027, leading to an action plan and possible specific targets. A 2024 screening with the ENCORE tool found potential materiality of pressures on species and habitats, climate-altering emissions and abiotic resource extraction. Dependence of the Group's direct activities on ecosystem services was found limited overall, with moderate dependence on soil and sediment retention and water flow regulation. More in-depth analysis of actual impacts and of physical, transition and systemic risks will take place in 2026 (p.195).

Underwater (p.195): a demonstration mission of the "DEEP" underwater drone system, including autonomous vehicles to map Posidonia rhizomes and detect hydrocarbon spills, and a collaboration between Fincantieri Infrastructure Opere Marittime and WSense for real-time seabed and water column data.

The report states no monetary amount for these actions.

Targets related to biodiversity and ecosystems

Reference: page 196.

The main biodiversity targets are process targets, not outcome targets (p.196): launch of the biodiversity project (baseline 2024), analysis of the impacts of production processes in 2026, and definition of actions to mitigate significant impacts in 2027. The 2026-2030 Sustainability Plan carries over the commitments of the 2023-2027 plan (p.196).

The report states "no ecological thresholds were applied in setting the targets" (p.196). It cites the ENCORE analysis, the World Database on Protected Areas, Key Biodiversity Areas and a context analysis as inputs.

The WWF Biodiversity Risk Filter found none of the 18 shipyards in critical biodiversity conditions, but seven in moderately significant areas: Riva Trigoso, Sestri Ponente, Muggiano, Promar (Ipojuca, Brazil), Vung Tau (Vietnam), Tulcea (Romania) and Monfalcone. The Group plans to focus its impact assessment on these seven (p.196).

A new target for the Underwater segment: by 2030, 20% of "unconventional" civil revenue from sustainable inspection activities for the offshore market (p.196).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 196-197.

The E4-5 section gives site proximity data. Sites near sensitive areas (p.196):

• Muggiano (15 ha), Riva Trigoso (22 ha), Sestri Ponente (26 ha): near the International Marine Protected Area, Marine Mammal Sanctuary
• Marghera (38 ha): near the UNESCO site Venice and its Lagoon
• Monfalcone (82 ha): near the Natura 2000 Foce dell'Isonzo reserve and Cavana di Monfalcone; Palermo (22 ha): near Monte Pellegrino and Capo Gallo
• Tulcea (about 76 ha) and Braila (about 50 ha) in Romania: adjacent to the UNESCO Danube Delta
• Norway: Langsten near the Tautra Vest reserve and Måslia protected area; Brattvåg Strandgata (2 ha) and Søviknes (6 ha) near other reserves
• Vung Tau, Vietnam (about 15 ha): near Can Gio, an area of biodiversity interest
• Vard Promar, Brazil: about 80 ha, of which 25 ha adjacent to mangrove forest (p.196)

Indicators from the WWF Biodiversity Risk Filter (range rarity and ecosystem condition) were normalized for comparison, and the report describes the internally developed study as methodologically sound and sufficiently representative (fn.24, p.197).

Policies related to resource use and circular economy

Reference: pages 198-199.

The Group commits to promote a circular economy through responsible sourcing and sustainable waste management, using technology to raise resource efficiency and minimize outflows. The commitments sit in the Occupational Health & Safety, Environment, Biodiversity and Energy Policy, which includes promotion of recovery, reuse and recycling of materials, and in the Innovation Policy (p.198).

Waste management model (p.198): production layouts set sequences of processing steps so materials can be selected upstream and residues sorted and grouped by type. Each production unit has areas for identifying materials and storing waste pending disposal. Waste goes to authorized sites by classification, favoring recovery, under monitoring by the Health, Safety and Environment structure at each shipyard.

CircularYard (p.198): a new company set up with the Hera Group to run an integrated waste management system, expected to process 100 thousand tonnes of industrial waste a year once fully operational.

Third-party transport, recovery and disposal in Italy is done by operators registered with the National Register of Environmental Operators, and each movement is checked through the RENTRI system (p.198).

Actions and resources related to resource use and circular economy

Reference: pages 198-201.

Steel (p.199): most hull material is ferrous and steel is 100% recyclable. In 2025 the sale of ferrous by-products in "furnace-ready" cuts to steel mills, already running at Ancona, Castellammare di Stabia and Sestri, was extended to the Palermo shipyard and to Fincantieri Infrastructure at Valeggio sul Mincio. Compliance checks for Tulcea and Braila are under way, with the initiative to be finalized there in 2026.

Ship end of life (p.200): disposal is managed by shipowners, but the Group's cruise ships carry voluntary certifications such as Green Passport, Clean Ship or Eco, and all naval vessels can be delivered with a Green Passport (inventory of materials, aligned with the Hong Kong Convention).

Office assets (p.200): a framework agreement sends obsolete assets for remanufacture, reuse or recycling. In 2024 and 2025, 60% of withdrawn assets went to recovery and reuse, about 410 printers, 1,000 PCs and 800 tablets.

Paper (p.200): digitalizing contractor work permits is expected to cut about 1 million printed pages a year.

The report gives no monetary figure for circular economy actions in this section.

Targets related to resource use and circular economy

Reference: page 202.

The 2026-2030 plan moved the waste target from production hours to revenue "to ensure full comparability" with peers (p.202). Footnote 25 says the recycling target was set in 2023, before the ESRS applied, and the new plan specifies that it refers to waste for recovery in the ESRS sense (fn.25). Targets are voluntary and cover the whole Group (p.202). The Group lists stakeholder engagement, a context analysis, regulations and scientific evidence as inputs.

Resource inflows

Reference: page 203.

Procurement of raw materials is strategic. Environmental impact over the whole life cycle is assessed at design stage, including a search for interior materials with lower impact (p.203).

Main raw materials (p.203): iron for the hull; plastics, aluminium and other construction materials; carbon dioxide, oxygen and argon for welding; paint products; and cement and concrete for the infrastructure segment.

Quantities (p.203): the total weight of technical and biological products and materials used in 2025 was 305,833 tonnes, against 286,429 tonnes in 2024 (restated from 270,289 tonnes, fn.30). Biological materials, including biofuels used for non-energy purposes, were not used in significant quantities in either year. Purchased secondary materials were about 1.1% in 2025 and zero in 2024.

Technical and biological materials follow the Ellen MacArthur Foundation Butterfly Diagram, and secondary materials are those that are not virgin but recycled (fn.31).

Resource outflows

Reference: pages 203-205.

Ships are the main product. They are built under an eco-design system that guides choices on materials, components and systems to limit the impact of dismantling and disposal, which stay the shipowner's responsibility (p.203). More than 65% of a ship is ferrous material, which the report calls "100% reusable". The average lifespan is about 25 years for cruise ships and 30 for naval and specialized vessels (p.203).

Production waste comes mainly from shipbuilding and infrastructure construction: metals, painting residues, construction and demolition residues and insulation waste during prefabrication, pre-assembly and assembly. Final outfitting adds packaging (wood, paper, cardboard, plastic) and lubricant and flushing residues at system start-up (pp.203-204).

Waste volumes are in the E5-5 waste table (see the Waste disclosure): 155,722 tonnes in 2025, up 4.8%, reflecting a higher production workload (p.204). The Group sent over 85% of waste for recovery and the VARD Group more than 80% (p.204).

The Appendix cross-references the E5-5 datapoints on non-recycled waste and hazardous and radioactive waste to this disclosure (pp.292-293).

Waste

Reference: pages 204-205.

The non-recycled ratio was 13% in both years and no radioactive waste was recorded (p.204). Landfill of non-hazardous waste rose from 4,814 to 11,486 tonnes (p.204). The overall rise of 4.8% reflects more production. Data come from the Company waste databases and cover the whole Group (p.204).

Recovery-route detail: hazardous waste mostly goes to "other recovery operations" (19,830 tonnes) and non-hazardous to other recovery (88,463 tonnes) and recycling (25,723 tonnes) (p.204).

Policies related to own workforce

Reference: pages 208-211.

Group Code of Ethics (pp.208-209): mandatory for all, affirms dignity, inclusion and no discrimination; breaches can be reported through the whistleblowing system and lead to disciplinary sanctions under collective agreements.

Human Rights Policy, "Commitment to respect for human rights and diversity" (pp.208-209): based on the UN International Bill of Human Rights, the ILO fundamental conventions, the UN Guiding Principles, the OECD Guidelines and the EU due diligence directive. It applies to all Group operations and the value chain. The report says no particularly vulnerable groups were identified. It rejects discrimination on grounds including ethnicity, gender, age, disability, sexual orientation and religion. SA 8000 certification covers Vard Vung Tau and several Italian companies, including Fincantieri Infrastructure and Fincantieri NexTech (pp.208-209).

Policy against Harassment in the Workplace (pp.208-209): Board-approved, zero tolerance, based on ILO Convention No. 190, covering third parties and off-duty conduct.

Occupational Health & Safety, Environment, Biodiversity and Energy Policy (p.210): ambition of zero accidents, covering employees and contractor workers, with training and monitoring.

Travel Risk Management Policy (pp.210-211): updated in 2025 with Board approval; conformity certificate to ISO 31030 from RINA.

Taking action on material impacts on own workforce

Reference: pages 214-225.

Health and safety (pp.214-217): a Safety Improvement Plan built on awareness, reporting and continuous improvement. Measures include monthly Safety Breaks in six languages, Safety Observation reports, Accident Committees, the "Partner in Safety" program (2025: 48 suppliers, 51 on-site and 19 in-house audits), AI-based optical sensors on cranes and forklifts, and exoskeletons. Ordinary safety expenses were EUR 7.6 million. The Safety Academy delivered over 172,000 training hours, 56% more than in 2024. ISO 45001 covers 100% of Italian shipyards and 89% of the Group (p.217).

Equal treatment (pp.217-219): the "Fincantieri everyDEI" model; about 60 trained "Antennae" employees supporting women in violent situations; Purple Points at 10 locations; UNI/PdR 125:2022 gender equality certification; EUR 1.7 million operating expenditure on equal treatment initiatives (p.219).

Skills (pp.220-223): Masters of the Sea (108 hires in 2025, 250 since the start); the "Learning for Future" campus; Talent On Board (387 participants, 32% women); about EUR 10 million of training expenditure.

Work-life balance (pp.222-224): smart working used by about 65% of eligible staff, two company crèches, and welfare bonuses (40% of the Result Bonus taken as welfare).

Data protection (pp.224-226): a GDPR privacy system; the Data Protection Officer answered about 200 guidance requests.

Targets related to own workforce

Reference: pages 226-231.

The targets come from the 2023-2027 Sustainability Plan, with 2026-2030 Plan targets added (p.228). Stakeholder engagement and the Employee Engagement Survey informed them (p.226).

2025 results against targets (p.228):

• Talent acceleration program: +240% in new participants against a +40% target
• Injury frequency rate: 4.97 against a target below 7.5 (baseline 8.14)
• Severity index: 0.17 against a target of 0.2 or less (baseline 0.28)
• Women middle managers: 19% (baseline 15%); women white collar: 24% (baseline 22%)
• Employee engagement rate: 79%, up from the 72% baseline (pp.212, 228)

New 2026-2030 commitments (pp.228-231): structured psychological support accessible to all employees by 2027; ISO 30415 diversity and inclusion certification; sustainability objectives for 100% of staff with variable pay at Fincantieri S.p.A. and its Italian subsidiaries until 2029 and in at least 85% of Group companies by 2030; a social inclusion project for young people with disabilities by 2027; a Travel Risk Management alignment road map; and autonomous inspection systems and robotics support tools.

Footnotes give the perimeters (some targets cover Fincantieri S.p.A. only or exclude US subsidiaries) (p.228).

Characteristics of the undertaking's employees

Reference: pages 230-232.

The Group had 24,370 employees at 31 December 2025, up 7.9% from 22,588, mostly from growth in Vietnam, Romania, Norway and Italy (p.230). The headcount is end-of-period, taken from structured collection systems, with 100% coverage on actual data, not estimates (p.230).

Contract types (pp.230-231): 22,239 permanent, 2,127 temporary, 4 non-guaranteed hours; 24,020 full-time and 346 part-time. Temporary staff rose in Romania and Vietnam with higher production, with fixed-term contracts converted to permanent after probation (p.230).

Turnover: 2,538 employees left in 2025, a rate of 10.4% (11.9% in 2024) (p.233).

Characteristics of non-employee workers

Reference: pages 232-233.

Non-employees totaled 1,733 at year-end 2025, against 2,070 in 2024 (-16.3%) (p.233):

• temporary or agency workers: 754 (1,136 in 2024)
• interns and trainees: 149 (182)
• other external collaborators: 830 (752)

The fall comes mainly from US shipyards after a revision of production schedules (p.233). The headcount is end-of-period from structured collection systems, with 100% coverage on actual data (p.233). The 2024 figure for temporary or agency workers was restated after a review of classification criteria, which moved 517 workers from the own workforce to value chain workers (fn.13).

The report also tracks contractor workers on site for safety, covered under S1-14 and S2 (pp.236-237, 246).

Collective bargaining coverage and social dialogue

Reference: page 233.

Employees have freedom of association across the Group. In 2025, 47.8% of employees were registered with trade unions, and every country where the Group operates has contracts or agreements regulating employment (p.233).

All employees of Group companies based in the European Economic Area (EEA) are covered by collective bargaining agreements (p.233). The coverage and workplace representation charts show Italy and Romania, the EEA countries with more than 50 employees representing over 10% of the workforce, in the 80-100% band (p.233).

The report says metrics subject to phase-in for non-EEA countries were not reported (p.233). Country detail elsewhere: Norway has national agreements, Vietnam renews agreements every two years, Romania has a company agreement with annual wage adjustment and the Fincantieri Marine Group workforce in the United States is covered by a collective agreement (pp.224-225).

Diversity metrics

Reference: page 234.

Top management (18 people): 3 women (16.67%) and 15 men (83.33%) in 2025, against 15.80% and 84.20% in 2024. Senior management means Executives with Strategic Responsibilities and Executives with Primary Responsibilities as set out in the 2025 Remuneration Report (p.234).

Age: employees under 30: 3,604 (14.79%); aged 30-50: 12,873 (52.82%); over 50: 7,893 (32.39%) (p.234). In 2024 the shares were 15.36%, 49.49% and 35.15%.

The gender split of the whole workforce is in S1-6: 3,764 women and 20,600 men (p.230). The Board is 40% women (p.122). Coverage is 100% on actual data from the Group's collection systems (p.234).

Adequate wages

Reference: pages 234-235.

The report says: "Fincantieri ensures that all employees receive an adequate wage, defined in accordance with local legislation and national collective bargaining agreements (CCNL)" (p.235). The benchmark is the national wage set by local law, minimum wages where they exist, and collective and company agreements (p.235). Pay has a fixed and a variable part.

Non-executive staff at Fincantieri S.p.A., Cetena, Isotta Fraschini Motori and Orizzonte Sistemi Navali receive a Sustainability Bonus linked to five sustainability indicators: energy consumption, water withdrawal, waste produced and VOC emissions (p.235).

The report gives no country-level table of employees paid below an adequate wage benchmark. Minimum wage arrangements are described by country: national agreements for blue collar workers in Norway and a company agreement with national minimum wages in Romania (pp.224-225).

Persons with disabilities

Reference: pages 234-235.

Taking the different legal definitions into account, the Group had 579 persons with disabilities in 2025, 2.4% of its workforce (p.234).

Related actions (pp.218-219, 230): disability is a pillar of the Fincantieri everyDEI model. The Group joins targeted recruitment events, started a partnership with Ability Garden for inclusion pathways, and launched Ability Parent Care, psychological support for employees who raise children with disabilities or neurodivergence. A 2026-2030 target commits to a social inclusion project for young people with disabilities in Italy by 2027, extended to other countries and all companies by 2030 (p.230).

The report gives the figure as a total and does not break it down by gender in this section.

Training and skills development metrics

Reference: pages 234-236.

Training delivered (p.234): an average of 27.6 hours per employee in 2025, up from 26.5 (+4.15%). Men averaged 27.2 hours and women 29.9 hours (25.6 in 2024 for women). The per capita figure divides 672,530 total hours by the 24,370 employees at year-end. Training is open to all employees without distinction of contract or level.

The increase reflects a stronger training plan, mainly Corporate University and leadership model courses and more onboarding for new hires (p.234).

Performance and career reviews (p.236): 88.8% of employees took part in 2025 (85.3% in 2024): 89.2% of women and 88.7% of men. Counting only employees eligible for the process (excluding maternity leave, new hires under six months, long-term illness and resignations) the share exceeds 90% (p.236).

Data cover the whole Group, are a year-end headcount and rest on 100% actual data (p.234).

Health and safety metrics

Reference: pages 236-237.

Days lost to work-related injuries were 7,501 in 2025 (7,814 in 2024). 260 cases of work-related diseases were recorded among employees. 89% of the Group's workers are covered by a health and safety management system based on legal requirements or recognized standards, in line with 2024 (p.237). Most injuries are falls or impacts against fixed parts, mainly to lower limbs and hands (p.236).

Other workers on site (p.237): LTIFR 7.08 (7.01 in 2024), 439 recordable accidents (434) and no fatalities. Data cover contractor personnel working at Fincantieri's sites and are precise, not estimated.

The own workforce data rely on actual data and estimates (p.237). The rate is injuries per 1,000,000 hours worked, counting injuries with at least one lost working day.

Compensation metrics (pay gap and total compensation)

Reference: pages 238-239.

Gender pay gap by occupational category (p.238): executives 16% (12% in 2024), middle managers 4% (1%), white collars 9% (11%), blue collars 0% (1%). At Group level the gender pay gap was -2.9% in 2025 against -0.3% in 2024 (restated; the 2024 report showed -8%) (p.239). A negative value means women's average pay is higher. The report ties the result to the large weight of male blue-collar employees (43% of the workforce) (p.239).

The method divides the difference between men's and women's average gross hourly pay by men's pay, using 2,076 theoretical annual working hours (p.238).

Pay ratio (p.239): the ratio of the CEO's pay to the median pay of Group employees is 65.5, in line with 2024. Median pay is global remuneration including fixed pay and variable pay with accrued incentive plan values, excluding the highest-paid employee. For the part of the workforce whose total pay is not precisely available, the category and gender average is used (p.239; BP-2, p.119).

Incidents, complaints and severe human rights impacts

Reference: pages 238-239.

The whistleblowing system collects reports of alleged human rights violations (p.238). In 2025 it received 39 reports (15 in 2024) of alleged breaches of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines (p.239):

• 30 concerned discrimination and harassment: 12 under investigation, 15 filed without action and 3 led to disciplinary action
• 2 concerned freedom of association and collective bargaining
• 7 concerned health and safety violations
• of the nine non-discrimination reports, 2 are under investigation, 6 were filed and 1 led to disciplinary action

Of the three reports still under investigation at the end of 2024, 2 were resolved without action and 1 is pending (p.239).

There were no formal human rights complaints against the company through external mechanisms such as OECD National Contact Points or the Business and Human Rights Resource Centre, and no significant fines, sanctions or compensation. The report says "In 2024 and 2025, no cases of serious human rights incidents were recorded at Group level" (p.239).

Policies related to value chain workers

Reference: pages 242-243.

Suppliers' Code of Ethics (p.242): updated in 2026 and approved by the Board of Fincantieri S.p.A., drawing on the UN Universal Declaration, the UN Guiding Principles, ILO Conventions and the UN Convention against Corruption. It applies to all Group suppliers through contract clauses, and suppliers are asked to pass it to sub-tier suppliers. The Group Procurement and Supply Chain Department disseminates and monitors it. Violations can be reported through the whistleblowing system.

Human rights policy requirements (p.242): the Human Rights Policy requires suppliers to provide safe workplaces, combat forced labor, modern slavery, trafficking and child labor, respect trade union rights, prevent harassment, protect data, and manage environmental impacts including substances of concern. Compliance with the Code of Ethics and, where applicable, the Protocol of Legality with the Ministry of the Interior and the Memorandum of Understanding with the Guardia di Finanza is a binding condition for business relationships.

The Appendix cross-references the S2-1 datapoints on human rights policy commitments, ILO conventions and non-respect of the UN Guiding Principles to this disclosure (pp.292-295). Salient issues include child labor, forced labor, freedom of association, health and safety, and local community rights (p.242).

Taking action on material impacts on value chain workers

Reference: pages 245-249.

ESG assessment and audits (pp.245-246): the four-year supplier ESG assessment program, via the SupplHi platform and e-NGAGE portal, continued in 2025. Sustainability audits at strategic suppliers produced 73 improvement plans and 6 specific non-conformities; for 2 the Group asked for immediate termination and for 4 set recovery plans due in the first half of 2026. The report says none involved a human rights violation. The Group carried out 85 supplier sustainability audits against 40 planned (Group excluding US subsidiaries) (p.246).

Certification (p.246): with the National Association of Labour Consultants' foundation, an ASSE.CO. certification pilot covers 40 leading supply chain companies, and from 2027 it becomes part of qualification requirements.

Safety training (p.246): the "Together in Safety" course, about three hours in 10 languages, is compulsory for everyone entering Italian shipyards, including contractor workers (over 30,000 people a year).

Skills (p.248): Mattei Plan recruitment (8 further workers from Ghana in 2025, 20 welders from Tunisia in 2026), the Supply Chain Development project and 14 framework agreements signed in 2025 (24 of 76 shipyard, workshop and contractor combinations, 32%, with 10 more in 2026).

A "Conflict Free" clause is applied to all product groups (p.245). The audit budget is about EUR 100,000 a year (p.268).

Targets related to value chain workers

Reference: pages 250-251.

Targets (p.250):

• Annual ESG audits on suppliers of priority or strategic interest: 85 in 2025 against a target of 40; 60 a year planned for 2026 to 2030 (Group excluding US subsidiaries)
• Human rights risk identification and assessment: formalized monitoring and maintenance plan in 2025; a Human Rights Risk Assessment for the Vard Vung Tau and Vard Promar sites in 2026
• Conflict minerals: extend clauses to relevant subsidiaries with reference to EU Regulation 2017/821. The 2027 target was achieved early, with the clause in contracts for all product groups (fn.19)

Strategic suppliers are those in the Register excluding suppliers designated or mandated by the customer (fn.17). Stakeholder feedback from supplier workshops, webinars and roadshows and interviews with supply chain experts informed the targets (p.250). The first year in each table is the baseline, and targets from 2026 onward come from the 2026-2030 Sustainability Plan (p.251).

Policies related to affected communities

Reference: page 253.

Group Code of Ethics (p.253): the Group recognizes responsibility to the communities where it operates and aims for shared value. The 2026 update adds a section on community relations and social development. It commits to open dialogue with communities, local authorities and civil society, to respect local cultures and rights, to support local employment and suppliers, and to back education, training, environmental and cultural projects. The Group rejects support for activities pursuing illegal or violent aims.

Policy on Human Rights (p.253): covers protection of human rights in local communities where the Group operates.

The report says "Fincantieri has not reported any instances of non-compliance with international regulations and guidelines involving affected communities" (p.253). The Appendix cross-references the S3-1 datapoints on human rights commitments and non-respect of UN Guiding Principles to this disclosure (pp.294-295).

Material topic: communities' economic, social and cultural rights (p.155). The material negative impact relates to workforce cultural heterogeneity (p.252).

Taking action on material impacts on affected communities

Reference: pages 255-259.

Economic development and integration (pp.255-256): school and career guidance with the ELIS Consortium (over 120 entities) against the NEET problem and skills shortages. Two in-person cultural mediation desks (Sestri and Muggiano) and the "Step2Connect" web app help foreign supply chain workers. The NAVIGARE INSIEME Italian language courses started in 2024 at Monfalcone and Sestri Ponente and in 2025 spread to Ancona, Marghera, Riva Trigoso and Muggiano: over 400 certificates and 1,300 lesson hours.

Local ties (p.256): "Open Shipyards" events, a Telethon relay with 48 employees, and Unione Fincantieri Monfalcone youth football for 250 young people of different nationalities.

Inclusion (p.257): the "Respect for Future" roadshow (5 stops in 2025) reached more than 10,000 employees and supply chain staff; support for Nave Italia and the "WOW" accessible round-the-world project.

Education and environment (pp.258-259): university funding with Bocconi, Parthenope, Politecnico di Torino and Sapienza; co-founder of the Venice World Sustainability Capital Foundation.

Crime prevention (pp.260-261): a Memorandum of Understanding with the Guardia di Finanza (March 2025) and the Legality Protocol with the Ministry of the Interior (renewed June 2025, p.268).

Targets related to affected communities

Reference: pages 260-261.

Current target (p.261): two educational and social inclusion projects, especially for disadvantaged groups and those at risk of exclusion (baseline 2023: 1; 2025 target achieved).

2026-2030 Plan commitments (p.261): ten agreements with Group partners by 2026 to increase the supply of skills needed in shipbuilding and to strengthen the economic and financial solidity of the companies involved; and, by 2028, a structured system to encourage volunteer activities during working time with local associations and organizations.

The targets came from a context analysis, regulations and standards, and community demands received through meetings, discussions and workshops (p.261). The first year in the table is the baseline (p.261).

Two legality protocols act as preventive tools: the Memorandum of Understanding with the General Command of the Guardia di Finanza and the Legality Protocol with the Ministry of the Interior (initial version 2017). Both require binding contract clauses on transparency, regular contributions, workplace safety and environmental protection, and the Ministry protocol will be extended to all Italian subsidiaries in 2026 (p.260).

Business conduct policies and corporate culture

Reference: pages 262-265.

Code of Ethics (pp.262-263): the Board approved a new Group Code of Ethics in February 2026, aligned with the UN Universal Declaration, ILO conventions, OECD Guidelines, UN Global Compact, the UN Convention against Corruption and the SDGs. It has five pillars: People, Safety, Integrity, Customer focus and Innovation. All Group companies adopt it by Board resolution. The CEO and Chairman ensure implementation, and independent control functions (including the Supervisory Body, Compliance, Internal Audit and HR) monitor it.

Anti-corruption Policy (pp.264-265): updated in 2025 with Board approval. It sets zero tolerance of bribery and corruption, direct or indirect, in public and private dealings. It covers sensitive areas such as public administration relations, customers and suppliers, hiring, donations, gifts and hospitality, conflicts of interest and sustainability reporting transactions. Monitoring sits with the Group Compliance, Anti-Corruption and Model 231 Function. Violations lead to disciplinary action or contractual sanctions.

Suppliers' Code of Ethics (p.265): updated in 2025 and approved by the Board in early 2026 (see S2-1).

The Group's ISO 37001 anti-bribery certification and training are described under G1-3. Whistleblower protection is described in G1-3 and G1-4 (pp.274-277).

Targets related to business conduct

Reference: pages 272, 274-277 (part of MDR-T disclosures).

The statement was prepared under the 2023 ESRS, where business conduct had no standalone targets requirement. The business conduct chapter does contain stated targets and tracking.

Supplier conduct targets (p.272): attribute ESG scores to 100% of strategic qualified suppliers (achieved: 1,000 suppliers, p.268), extend the ESG scoring system to European subsidiaries, build ESG scores into qualification criteria with improvement plans for weaker suppliers, run annual supplier engagement sessions (the 2025 target of at least one session was far exceeded, p.270) and test reward mechanisms linked to ESG assessments. A 2025 incentive target for the CEO also covers an ESG score for at least 95% of qualified strategic suppliers (p.127).

Anti-corruption tracking (pp.274-276): the ISO 37001 system gets an annual review by the Board for suitability, adequacy and effectiveness (p.274), and training coverage is reported by category (4,071 employees, 17%, in 2025) (p.276).

The G1 chapter lists no corruption-specific target table. Incidents are reported under G1-4 (p.277).

Confirmed incidents of corruption or bribery

Reference: page 277.

During 2025 the Group received two reports of potential corrupt acts, one of which is still under investigation. The report states: "no confirmed cases of corruption were reported as a result of audit activities" in line with last year, and no convictions or fines were imposed for violating laws against corruption or bribery (p.277). Of the three reports received in 2024, two are still being investigated and one was closed without further action (p.277).

The whistleblowing system lets employees, associates and third parties report violations of the Code of Ethics, the Organizational Model, the Anti-corruption Policy, the Suppliers' Code of Ethics, the Human Rights Policy and the law. It complies with Law No. 179/2017 and Legislative Decree No. 24/2023, protecting confidentiality and against retaliation (p.277). Reports go to a Whistleblowing Manager who works with the Supervisory Body and Anti-Corruption Function.

The Appendix links the G1-4 datapoint on fines for violating anti-corruption laws (paragraph 24(a)) to this disclosure (pp.294-295).

Payment practices

Reference: pages 277-279.

Average payment time (pp.278-279): payments to suppliers were made on average within 57 days of the contractual start of the payment term in 2025, about 10% better than 63 days in 2024. 83% of payments were aligned with standard payment terms (82% in 2024). Figures are weighted by invoice amount and do not differ significantly between SMEs and large companies. Considering 95% of total payments, 91% of invoices were settled within 15 days of the due date (90% in 2024).

Disputes (pp.278-279): 27 legal proceedings with suppliers that also complain of alleged late payment of contested sums, against 29 in 2024.

Terms and policy (pp.277-278): the Group's standard terms provide payment up to 90 days after delivery, or up to 60 days for some categories such as labor-intensive services. The report says Fincantieri "does not have a formal policy on late payments" but has defined procedures. The Parent Company runs reverse factoring with financial institutions, with supplier extensions up to 365 days beyond the invoice due date, and ESG-linked reverse factoring tied to supplier ESG scores (p.278).

The report notes Fincantieri leads a large network of small and medium enterprises (p.277).