Fluvius System Operator Cv

The role of the administrative, management and supervisory bodies

Reference: page 67. Board composition and diversity are incorporated by reference from the "Composition of governing bodies and management" section of the management report (pages 43-48; cross-reference listed on page 65).

• The Board of Directors delegates day-to-day management to the Management Committee, which "is therefore responsible for monitoring impacts, risks and opportunities". The Board "retains ultimate responsibility" (p.67).
• In 2025 Fluvius set up a sustainability department under a sustainability manager at senior management level. The manager reports directly to the CEO, "who also acts as sponsor". The department builds the sustainability strategy, coordinates initiatives, prepares the CSRD reporting and runs the double materiality analysis (p.67).
• "The governance framework for sustainability has been revised since the previous reporting year." The Management Committee acts as the sustainability committee and receives quarterly progress reports. A sounding board group of senior managers, the successor to the CSR board, can review steering group decisions in advance (p.67).
• In the annual strategy review, the Strategy Department and the Management Committee test whether mission, vision and strategy still fit stakeholder views, feed in the double materiality results and assess whether extra skills are needed (p.67).

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

Reference: page 68.

The Management Committee is informed about sustainability and material impacts, risks and opportunities through four channels (p.68):

• Strategy review: the annual review uses the double materiality results and is run with the Management Committee. The updated strategy is validated by the Strategy Committee and the Board of Directors.
• Sustainability committee: the Management Committee is informed quarterly on sustainability performance.
• Divisions: they own policy on sustainability issues and report weekly to the Management Committee through the decision sheet.
• Decision sheets: each Management Committee decision "should include an understanding of the impact on people and the environment".

Fluvius states that "actions have been taken on all material sustainability topics in the past financial year 2025", with key actions listed in MDR-A (p.68). It says its sustainable approach means "we work with a long-term perspective" (p.68).

Integration of sustainability-related performance in incentive schemes

Reference: page 69.

Management Committee pay has a fixed part and a variable, performance-based part. The variable part uses long-term indicators set each year by the Management Committee in the quarter before the new financial year (p.69).

"The long-term indicators are fully linked to sustainability topics." The share of variable remuneration linked to sustainability targets and/or impacts is 100% of total variable pay (also 100% in 2024) (p.69).

Indicators named on page 69:

• Environment: delivery of the investment plans for the energy and climate transition; digitization and automation of public lighting; the 2025 roadmaps for data, future energy networks and sewerage; cooperation within the water sector on climate adaptation.
• Social: Great Place To Work score, safety results, absenteeism rate, customer satisfaction, complaint handling, customer centricity, timely execution of core tasks, eliminating blocked access points, reputation.
• Governance: managing ESG risks; securing long-term sustainable revenue streams and financing for the energy and climate transition.
• Entity-specific: network performance.

Other governing bodies are paid by meeting attendance plus expenses. Managers and office staff are eligible for a performance bonus (CAO90) tied to pre-defined sustainability targets such as customer satisfaction, kilometers driven and safety performance (p.69).

Statement on due diligence

Reference: page 70.

Fluvius states its commitment to "a sustainable and just society, in which respect for people and the environment is central" and says it puts its transition plan and human rights policy into practice with its value chain and stakeholders (p.70). Its strategy for the energy and climate transition rests on the Flemish Energy and Climate Plan, and its policies recognize human rights as set out in ILO conventions and national law (p.70).

Page 70 maps the core due diligence elements to specific disclosures:

• Integrating due diligence in governance, strategy and business model: GOV-2, GOV-3, SBM-3.
• Engaging affected stakeholders: GOV-2, SBM-2, IRO-1.
• Identifying and assessing negative impacts: IRO-1, SBM-3.
• Taking measures: the MDR-P/A/M/T overview (page 92).
• Tracking effectiveness: the same MDR-P/A/M/T overview.

Further due diligence detail sits in S1, S2 and S4 (people) and E1-1 (environment). Fluvius runs a whistleblower procedure for reporting and handling irregularities, and "the integrity of persons who report incidents is protected at all times and in all circumstances" (p.70).

Risk management and internal controls over sustainability reporting

Reference: page 71.

The Sustainability Department prepares the sustainability report, which forms part of the annual report and is approved by the board, management and supervisory bodies (p.71).

Fluvius states that the 2024 report "was subject to a limited assurance review by the auditor and found to be compliant", and that the 2025 report is being prepared on the same guidelines (p.71).

An internal audit in 2024 covered a selection of sustainability indicators. Its action plan "was implemented in 2025 and the identified risks were mitigated" (p.71). The risk management and internal control system was changed so that its scope matches CSRD reporting, prioritization can be applied, extra mitigation tools exist, control roles match the relevant functions and the reporting process is documented (p.71).

The 2025 statement itself carries a limited assurance report from the statutory auditor (pages 278-282).

Strategy, business model and value chain

Reference: pages 73-79.

Strategy (p.73). Besides the general four-pillar strategy, Fluvius has had a sustainability strategy "since 2025" with five pillars: footprint (climate neutrality in its own operations through decarbonization levers), handprint (delivering the energy transition and climate adaptation in Flanders), value chain, resilience, and employment.

Business model (p.74-79). Fluvius operates networks for electricity, natural gas, sewerage, public lighting and heat, with 5,448 active employees (5,271 in 2024), all in Flanders (p.74). It is sewerage manager in 83 municipalities, 29% of Flemish municipalities (p.76), and runs grid and data management for all Flemish distribution system operators (p.75, p.79).

Fossil fuel activity (p.74). "Fluvius has operations in the fossil fuels sector, more specifically in the natural gas distribution sector", with revenue of 403 million euros in 2025 (410 million in 2024). It is not active in coal, oil, chemicals, controversial weapons or tobacco.

Value chain (p.78-79). Two main activities: construction and maintenance of networks, and enabling management and use of the grid. Upstream inputs are raw materials and (sub)contractor services bought under public procurement. Downstream users are private customers, business customers and local authorities. Fluvius "has no influence on the origin" of the product in its networks (p.78).

Interests and views of stakeholders

Reference: pages 80-81.

Fluvius assigns each external stakeholder a single point of contact and a responsible division, and separates stakeholders from key stakeholders, who are monitored more closely and may get cooperation agreements (p.80).

Key stakeholder groups named on pages 80-81: politics (Flemish, federal and European level), regulators, suppliers (energy suppliers, aggregators, flexibility service providers), network operators, local authorities and provinces (shareholders, partners and an important customer segment), sector organizations, employee organizations (trade unions), environmental organizations, organizations representing energy consumers, and innovation and research institutions.

Forms of engagement (p.80): strategic and operational consultations, cooperation agreements, round tables, participation in platforms and working groups, advocacy and info sessions.

Regular themes (p.81) include energy and climate policy, the investment plan for the energy and climate transition, the data management plan, market operations, cooperation between utilities, value chain management and customer and employee centricity.

Stakeholder feedback feeds the annual strategy review in the Strategy Division, with the Management Committee and Strategy Committee closely involved (p.81).

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

Reference: pages 82-83. Topic-level IRO tables sit at the head of each chapter: E1 p.115, E3 p.145, E5 p.156, S1 p.168, S2 p.206, S4 p.219, ES1 p.232, ES2 p.247, G1 p.257.

The double materiality analysis was first carried out in 2023, and the entire value chain was considered (p.82). "All ESRS themes were found material except 'Biodiversity and ecosystems', 'Pollution' and 'Affected communities'", plus two entity-specific topics: network reliability (ES1) and smart data and infrastructure (ES2) (p.82). Materiality sits mainly in upstream procurement, construction and maintenance of networks, network management and downstream users (p.82).

Fluvius says its impacts "are therefore predominantly positive", mostly current, with a usually short time horizon (p.83). Financial effects relate mainly to investment for the energy and climate transition, and to customer tariffs and affordability (p.83). Page 65 states that expected financial impact (paragraph 48(e)) is reported only in qualitative terms under a phase-in.

The results went to the Management Committee and Board. Fluvius adds that changes to strategy "may not be directly attributable" to the analysis (p.82).

Counting the rows in the nine topic tables gives 70 IROs (our count; the report states no total).

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

Reference: pages 85-88.

Process (p.85). The double materiality analysis was first carried out in 2023 and follows five phases: define scope and stakeholders; identify IROs; evaluate; validate; report. Scope is the Fluvius Economic Group plus the value chain. A new analysis is due "no later than 2026".

Stakeholders (p.86-87). Government, shareholders and investors, employees, suppliers, customers, environmental organizations, local communities and NGOs, consulted directly or via a single point of contact, plus literature research, workshops and interviews.

Topics (p.87). The "Climate" theme was split into climate mitigation, climate adaptation and energy. Two entity-specific themes, "Network reliability" and "Smart infrastructure and data", were added.

Scoring (p.87-88). Impact materiality combines severity, scope, restorability and likelihood: the score for scale, scope and recoverability is summed and multiplied by a probability factor; an impact is material if the score is "higher than 8 out of 15". Financial materiality multiplies magnitude by a probability factor; a risk or opportunity is material at "3 out of 5" or above. A theme is material as soon as one underlying IRO is.

Integration (p.88). Risk classification is linked to the existing enterprise risk management approach.

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

Reference: pages 89-90 (material topics); pages 397-399 (list of disclosure requirements complied with, with page numbers); page 400 onward (datapoints from other EU legislation). The list is the company's own ESRS content index.

Material topics per the double materiality analysis (p.89): climate mitigation, climate adaptation, energy, water and marine resources, material use and recycling, own employees, employees in the value chain, consumers and end users, business conduct, network reliability, and smart infrastructure and data.

Not material (p.90):

• Biodiversity and ecosystems: underground networks, limited above-ground footprint and temporary works restored afterwards.
• Pollution: "now treated in an integrated manner within the broader contexts of Climate change (E1) and Water and marine resources (E3)".
• Affected communities: now integrated within consumers and end users (S4) and network reliability (ES1).

The content index (pp.397-399) lists BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P, MDR-A, MT, E1-1 to E1-8, E3-1 to E3-4, E5-1 to E5-5, S1-1 to S1-17, S2-1 to S2-5, S4-1 to S4-5 and G1-1 to G1-6. It lists no E2, E4 or S3 disclosure requirement, and no E1-9, E3-5 or E5-6. Page 65 states that E1-9 and E3-5 are omitted under phase-in.

Transition plan for climate change mitigation

Reference: pages 117-121 (E1-1 listed at page 117 of the content index).

Targets (p.117). Carbon neutrality "across all our operations and value chains by 2050 at the latest". Scope 1 and 2: base year 2020 (339,266 tCO2eq), a 47% cut by 2030 (179,811 t), carbon neutral by 2040 with offsetting of what is not avoided (market-based Scope 2 is used). Scope 3: base year 2023 (991,917 t) and an end-to-end carbon neutral value chain by 2050; the table gives no 2030 or 2040 Scope 3 values.

Levers (p.118-119). Fleet electrification (leased vehicles by 2030 at the latest), energy-neutral buildings by 2050, decoupling public lighting from grid losses by 2030, methane reduction under OGMP 2.0, SF6 phase-out, a sewerage emissions baseline, and supplier and procurement cooperation for Scope 3.

SBTi (p.117). Fluvius cannot claim that its transition plan follows SBTi, because SBTi does not recognize Fluvius as eligible given its gas distribution activities. SBTi has temporarily paused validations for fossil fuel sectors.

Locked-in emissions (p.120). Gas distribution emissions are locked in, with no legal indication of a full gas phase-out.

Funding and approval (p.121). No total decarbonization budget can yet be set. The plan was approved by the Management Committee in December 2024 and reconfirmed in December 2025. Progress: a 41% Scope 1 and 2 reduction in 2025 (13% in 2024), while Scope 3 is "on the rise".

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate sections (E1.SBM-3 and E1.IRO-1, pages 122-123), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (p.122). Each material climate risk is marked as physical or transition. All four material risks are transition risks: falling gas demand, energy consumption peaks, no heat network regulation, and stranded gas assets.

Physical risk method (p.123). The Network Management Division runs the analysis across all asset types for short, medium and long term. Because asset lifetimes run "between 50 and 100 years", the scenario looking furthest ahead (up to 50 years) is used. Exposure was assessed per asset location, and hazards were underpinned by "the 'Representative Concentration Pathway 8.5' (RCP8.5) climate scenario".

Findings (p.122). A 2023 analysis of all assets, done to EU Taxonomy requirements, found wind and water risks most significant, with overhead lines, substations, transformers and public lighting most exposed. Temperature and land risks were not material; a deeper heat analysis began in 2025.

Transition risk (p.123). The Strategy Division identifies these through research and stakeholder consultation. No transition scenario or temperature projection is named.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate sections (pages 83, 120-122, 133, 136), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report gives no stand-alone resilience analysis with quantified results. It does say:

• Strategy (p.122). "Climate adaptation is an integral part of Fluvius' business strategy." Transition risks are handled through strategic commitments and the Energy and Climate Transition Division.
• Investment capacity (p.83). The company says it is "highly resilient in terms of its ability to respond to challenges", working within the regulatory framework and permitted revenue set by the tariff methodology.
• Gas network (p.120). Fluvius is "examining various scenarios to determine the technical and financial impact on gas operations". Gas expansion funds were dropped from the investment plan, and gas investment falls to about 60 million euros per year by 2035.
• Pace of investment (p.120). The pace can be slowed or brought forward with energy policy and stakeholder consultation.
• Adaptation plan (p.133). Four themes: risk asset analysis, flood impact reduction, asset management integration and adapted design rules. The first flood-prone cabin was replaced in 2025.
• Gap (p.136). "No specific objectives have yet been set to manage the physical climate risks of Fluvius' assets."

Policies related to climate change mitigation and adaptation

Reference: pages 124-128.

Fluvius's climate policy "follows directly from the identified decarbonisation levers" and is monitored by the relevant departments and the Management Committee (p.124). Policy areas covered:

• Buildings (p.124): design criteria on energy performance and renewables, aiming for carbon-neutral buildings by 2050. Solar panel capacity is 1,747 kWp.
• Transport (p.124): a Reduce, Sustain, Change mobility policy with gradual phase-out of fossil-fuelled vehicles.
• Electricity network (p.125): the energy efficiency first principle from the EU Fit for 55 package.
• Heat (p.125): heating grids only where a sustainable source can meet 100% of demand.
• Methane (p.125): reduction in line with EU Regulation 2024/1787 (monitoring, leak detection and repair, limits on venting and flaring).
• SF6 (p.125): a ban in new switchgear up to 24 kV from 1 January 2026.
• Environment (p.126): an environmental management system following ISO 14001 principles, with preparation from 2026 and full implementation by 2028.
• Adaptation (p.127): physical risk analysis informs an adaptation plan, with nature-based solutions favored.
• Energy (p.128): digital meter roll-out and full LED conversion of public lighting by 2028 (74.03% in 2025, 60.87% in 2024).

Actions and resources in relation to climate change mitigation and adaptation

Reference: pages 129-135.

Scope 1 and 2 plan (p.129). The action table sets 2030 reductions by lever, from a 339,266 t base: electricity distribution network 227,039 t falling to 90,816 t (60%), gas distribution network 91,003 t falling to 72,236 t (21%), heating 5,625 t (8%), and fleet 11,395 t (16%), for a total of 179,811 t (47%). Scope 3 reductions "are still under investigation".

Fleet and buildings (p.130). 3,861 vehicles (3,819 in 2024) and 581 charging points on Fluvius sites. A new regional building opened in Bruges in June 2025.

Methane (p.131-132). PE pipe replacement, inspection of 20 to 25% of the gas network every year, bicycle-mounted leak sensors from late 2025, a new leak detection tender from 1 January 2026, and OGMP "Gold Standard Reporting".

Scope 3 (p.132). A supplier survey found the market not ready for raw material passports, so Fluvius is now requesting EPDs. Pilot projects for climate-neutral construction sites start in early 2026.

Adaptation (p.133). A four-theme plan built around flood risk.

Energy (p.134). A 2026-2035 Investment Plan, with transformer upgrades, digital meters and a congestion action plan with Elia.

The report gives no total climate budget (see E1-1, p.121).

Targets related to climate change mitigation and adaptation

Reference: pages 136, 117, 139-140.

Mitigation (p.136). Climate neutral by 2050 across all activities and the value chain. Fluvius segments this: climate neutrality by 2040 for core and support activities (Scope 1 and 2) and 2050 for Scope 3. It says the objectives "are compatible with limiting global warming to 1.5°C" because they aim for neutrality by 2050. A multidisciplinary team set them from GHG Protocol emission flows and the expected effect of the decarbonization levers, and the Management Committee validated the results.

Numbers (p.117, 139-140). Scope 1 and 2 base year 2020, with a 47% reduction by 2030. Scope 1: 108,401 t (base) to 57,453 t in 2030. Total emissions target for 2050: 69,952 t (location-based and market-based). Annual reduction rates are shown as -2.71% (Scope 1), -3.33% (Scope 2) and -3.17% (Scope 3).

Adaptation (p.136). Tied to the sewerage targets. "No specific objectives have yet been set to manage the physical climate risks of Fluvius' assets."

Energy (p.136). Tied to the Investment Plan, after consultation with sector federations, academia, policymakers and Elia.

Verification (p.136). Emission totals are reviewed by the auditor in the limited assurance engagement. Fluvius submitted its transition plan to CDP in 2025 and "achieved a total score of D".

Energy consumption and mix

Reference: pages 137-138.

Total energy consumption was 924,250 MWh in 2025 (1,254,768 MWh in 2024) (p.137).

Self-generated non-fuel renewable energy was 1,056 MWh (p.137). Fluvius reports no coal consumption (p.137).

Electricity losses in the distribution network make up 89.07% of energy consumption (p.137). Revenue from activities in high climate impact sectors is 2,895,536,000 euros, all of Fluvius's net revenue, and energy intensity is 319 MWh per million euros (463 in 2024) (p.138). Fluvius states that all its NACE codes belong to a "High climate impact sector" (p.137).

The 2024 comparatives were restated because the electricity mix source changed from Elia data to AIB data (reference year 2023), which carries no renewable share (p.62-63).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 139-143, restatements on pages 62-64.

Base year is 2020 for Scope 1 and 2 and 2023 for Scope 3 (p.140). Purchased goods and services (659,126 t) and capital goods (353,306 t) are the largest Scope 3 categories (p.139). Use of sold products is 188,462 t (p.140).

Intensity is 0.0004984 tCO2eq per euro of net revenue, location-based (p.140). Scope 1 emissions from regulated trading schemes are 0% (p.139).

Method and quality (p.141-142). GHG Protocol; 2024 methane is used as the best estimate for 2025 because a full OGMP 2.0 calculation was not possible. Categories 1 and 2 are spend-based, which "entails material uncertainty". Only 0.05% of Scope 3 uses primary emission factors (p.142).

2024 Scope 2 figures were recalculated for a methodology change (p.64).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 144 (E1-7 listed at page 144 of the content index).

Fluvius reports a nil position: it "does not currently use carbon credits" (p.144). It reports no GHG removals and no mitigation projects financed through carbon credits for 2025.

The intention is forward-looking only. As stated in the transition plan, Fluvius intends to offset unavoidable Scope 1 and 2 emissions "by 2040 at the latest". It says this could use carbon credits, carbon capture and storage projects or forest planting, and that the compensation strategy will be developed in the coming years (p.144, and p.118, which targets 2026 for further exploring the offsetting strategy).

The same page covers E1-7 and E1-8 together.

Internal carbon pricing

Reference: page 144 (E1-8 listed at page 144 of the content index).

Fluvius reports a nil position: "Internal carbon pricing is also not yet being applied" (p.144).

The company adds that "the possibilities of this mechanism are being actively investigated" and that internal carbon pricing "may be integrated into our asset management policy in the near future" (p.144). No price level, scheme type or covered emissions are disclosed.

The disclosure shares one page with E1-7 (greenhouse gas removals and carbon credits).

Policies related to water and marine resources

Reference: pages 147-150 (E3-1 listed at page 147 of the content index).

Fluvius's water policy "is twofold": the sewerage activity carried out for cities and municipalities, which affects watercourses and the water cycle in Flanders, and Fluvius's own water use (p.147). The Environment Department monitors the objectives (p.147). The policy follows the Water Framework Directive, the Floods Directive and the Flemish Integrated Water Policy Decree (p.147). Two actions serve the Water Framework Directive standards: raising the connection rate and limiting incidental discharges from overflows (p.147).

The "Vision on sewerage in the water cycle" was validated by the Management Committee (p.148). Fluvius is the largest municipal sewerage operator in Flanders, active in 83 municipalities (87 in 2024), with goals including a 50% purification rate per municipality by 2027 and rainwater and drought plans (p.148).

For its own buildings, Fluvius applies the Flemish GRO method with criteria for water consumption, reuse and disposal, at an "Excellent" ambition level (p.150).

No material IROs were identified for marine resources (p.146).

Actions and resources related to water and marine resources

Reference: pages 151-153.

Funding (p.151). A ten-year sewerage investment plan was drawn up in 2024. By 2027, 916 million euros will have been invested, which is estimated to reach 97% of the targets if preconditions are met. A further 771 million euros for 2033 should reach 82%. Total budget: 1.69 billion euros. Fluvius says "not all objectives will be achieved" and is discussing priorities with stakeholders. Flemish Environment Agency subsidies are sought for projects.

Sewerage action plan (p.152). Seven actions under four targets: reduce drinking water consumption (joint digital water meter installation; alternative water sources for households), maximize circular water use and restore the natural rainwater cycle (collecting pollution load, buffering and infiltrating runoff, recovering discharged water), make networks fit for the future (digitization and automation), and share sewerage information with users. All measures relate to areas with water risk and high water stress, "as the entire Fluvius operating area is located in such areas" (p.152).

Partnerships (p.153). Synductis coordinates works with drinking water utilities. Fluvius endorsed the Ijzer and Handzame Valley Pact. The 2025 environmental action plan targets groundwater drainage in sewerage and utility works.

Targets related to water and marine resources

Reference: page 154.

Sewerage targets. The European Water Framework Directive requires clean water bodies by 2027. The Flemish Environment Agency set "reduction targets" per municipality that fix the sewerage rate Fluvius must reach in a given period. Compared with 2017, the pollution load discharged into watercourses must fall, and by 2027 every municipality must reach a treatment rate of at least 50%, "not yet the case for all municipalities" that have given Fluvius their sewerage management. Investment in sewerage networks in line with the EU Taxonomy was 163 million euros in 2025 (150 million in 2024).

Rainwater and drought plans. Fluvius set itself a voluntary target of plans in 100% of its sewerage municipalities by 1 January 2025, and says it achieved this "by the end of 2024".

Buildings. Pipe length from water heater to tap of at most 12 metres, at least half of water demand met by reuse, at least 90% of maximum available rainwater reused, leakage rate under 1 l/s/ha and drainage time under 6 hours.

Drinking water. Digital water meters in all Flemish households by 2030 is a target for the drinking water companies, "not for Fluvius".

Water consumption

Reference: page 155.

Total water consumption in Fluvius's own activities was 27,493 m3 in 2025, against 23,077 m3 in 2024. All of it falls in areas at water risk, including areas of high water stress. Fluvius explains that its "entire operating area (Flanders) is located in a region with water risk and high water stress", and that it "has no material dependence on water for its activities".

Scope: the figures include drinking water and rainwater consumption and storage in buildings, whether or not they are connected to the network. Water flows within the sewerage activity are excluded, because Fluvius only transports those wastewater flows to the supra-municipal system and does not consume them.

Method: figures rest on water meter readings, billing data and distribution keys. Where no measurement exists, for example in rented offices, extrapolation uses the occupancy rate and the number of employees in the building (p.155).

Policies related to resource use and circular economy

Reference: page 158 (E5-1 listed at page 158 of the content index).

Circular material use is one of the levers for the 2050 climate neutrality goal and for cutting value chain CO2 (p.158). Fluvius built a circular material use strategy on three pillars covering the full material life cycle (p.158):

1. Inflow reduction (Reduce): less new raw material in purchased materials, tracked in tonnes and as the share of non-primary materials.
2. Maximizing service life (Reuse): longer lifespan, measured in years.
3. Material conservation (Recycle): more reusable raw materials, tracked in tonnes and as a share of total material used.

The strategies follow the R ladder, where higher steps save more material and prevent more waste. The policy responds to the two negative impacts found in the double materiality analysis: use of virgin raw materials with limited recycled content, and waste in operations and the value chain with limited circular use of decommissioned materials (p.158). It is promoted within the Network Management Department, and Fluvius monitors innovations in materials and processes (p.158).

Actions and resources related to resource use and circular economy

Reference: pages 159-160.

Levers on page 159:

• Knowledge: in 2025 Fluvius decided to capture material data through suppliers' EPDs (environmental product declarations).
• Procurement requirements: circular design criteria in selection and award, and options such as extended warranties, mandatory take-back of packaging or residual lengths, and leasing.
• Efficiency gains: smart network management, targeted expansion and flexibility to avoid unnecessary investment.

Ongoing measures on page 160:

• Transformer reuse: transformers are inspected and adapted for a new use, given shortages and long delivery times.
• Digital meters: since early 2025 usable electricity meters are collected and refurbished by the social enterprise Vlotter.
• LED conversion: old fixtures and pavement boxes are dismantled and sorted into metal, copper, plastic and electrical parts by a specialist company.
• Laptops: old laptops go to Digital for Youth.

Fluvius planned a framework for prioritizing new measures for 2025 but "will now be carried out in 2026" (p.160). The report gives no monetary amount for these actions.

Targets related to resource use and circular economy

Reference: page 161.

The report sets out no numeric company target. Fluvius says targets "will be formulated" for each of the three pillars (reduce, reuse, recycle) along two dimensions: purchase of new grid-bound and non-grid-bound materials, and management of existing materials in the networks (p.161). The 2024 baseline measurement is to be improved and short-term targets set.

The indicator named is the Circular Material Use Rate: "CMUR = U/M", circular material use over total material use (p.161). Target areas listed: circular product design, a higher share of circular material use, minimal use of primary raw materials, sustainable procurement of renewable raw materials, and waste management (p.161).

"All targets are set voluntarily at company level." The report notes general Flemish circularity targets of 30% by 2030 and 100% by 2050, which companies need not adopt immediately (p.161).

The report's own wording is future tense ("In 2025, the focus will be on..."), so the 2025 report presents a plan for targets, not set values.

Resource inflows

Reference: page 162 (E5-4 listed at page 162 of the content index).

Method change (p.162). Last year's figure of 56,037 t used financial data. Fluvius now uses logistics reporting and counts only grid-related stock materials actually installed, such as cables and transformers. Secondary materials are mainly recovered transformers and digital meters plus an estimate of the circular share of materials consumed. "This share is still limited today."

Value chain relief (p.162). Sewerage and heat materials are bought by contractors, not Fluvius. A "significant amount of material (in tonnes) is expected" there, but Fluvius lacks weight data and cannot estimate it accurately, and says "we invoke the 'transitional provision' for value chain information mentioned in ESRS 1 10.2". Page 65 repeats this phase-in.

Weights come from EPDs where available, then logistics item master data, then group averages (p.162).

Resource outflows

Reference: page 163 (E5-5 listed at page 163 of the content index). Waste metrics are under E5-5-Waste (pages 164-166).

Fluvius says it contributes to the circular economy by integrating circular principles into the products and materials it uses and returns to circulation after first use. In procurement, circularity and related targets are taken into account at agreed ambition levels in exclusion, selection, technical, performance and award criteria (p.163).

Examples named on page 163: closing the water cycle in sewerage activities, and "light as a service" financing for public lighting, where Fluvius carries out the investment, installation, management and maintenance and the local authority pays an annual fee.

On durability, Fluvius says the networks it builds and manages are rated highly for sustainability, repairability is "very high", and rapid repair of defects matters for network reliability (p.163).

No quantified outflow data appear on this page. The waste figures are on pages 164-166.

Waste

Reference: pages 164-166.

Radioactive waste: 0 (p.165).

Data come from an accredited collector, waste dealer or broker, include all streams under the Flemish VLAREMA rules, and are described as high quality because they are "largely direct measurements" (p.165). Scope limits (p.165): no waste detail for De Stroomlijn; contractor-generated waste and earthmoving are excluded; Fluvius's share of Synductis sites is included.

Policy (p.164): waste reduction on the reduce, reuse, recycle pillars; hazardous waste is flagged with an asterisk on its EWC code and routed through D (disposal) or R (recovery) codes. Page 166 lists the EWC categories, including transformer oil and PCB-containing oil, asbestos-containing materials and grid components.

Policies related to own workforce

Reference: pages 172-183 (S1-1 listed at page 172 of the content index).

The policy "is based on a clearly defined HR strategy" that takes account of HR trends, ambitions, human rights, safety, diversity and inclusion. The HR director is responsible for developing, approving and supervising it, and it applies to all employees of Fluvius SO and Fluvius OV (p.172).

• Human rights (p.174): the general policy sits in the EU Taxonomy minimum safeguards and GOV-4. The Board has ultimate responsibility and the Management Committee operational responsibility. Fluvius recognizes freedom of association and collective bargaining in line with ILO standards. "No incidents related to human rights policy were reported in 2025."
• Safety (p.175): the stated goal is "ZERO accidents". The Global Prevention Plan was revised in 2025 for 2026-2030, with themes including compliance, well-being, safety culture and awareness.
• Diversity and inclusion (p.176): zero tolerance of transgressive behavior and discrimination; the target group is first limited to own employees, applicants, students and trainees.
• Culture (p.177-179): an annual Great Place To Work survey run by Vlerick Business School since 2019; shared leadership; 5,997 colleagues.
• Development, working model and well-being (p.180-183): talent mobility and Fluvius Academy, the New Way of Working, ADKAR-based change management, and a well-being team.

Taking action on material impacts on own workforce

Reference: page 189 (S1-4 listed at page 189 of the content index).

Impacts found through risk analysis, complaint channels, internal reporting or social consultation are assessed by HR, prevention and management. Actions are then chosen by severity and by how far Fluvius can influence the impact, formally decided, followed up and periodically evaluated (p.189).

Actions named for 2025 (p.189):

• The annual Great Place To Work questionnaire drives yearly actions. To keep certification, the focus was leadership, diversity and inclusion, and retention. "For the first time, all five main pillars scored above 70%".
• A learning plan for executives and team trajectories for shared leadership.
• A CEO roadshow at sixteen sites each spring.
• Safety actions under the 2026-2030 prevention plan.
• A diversity and inclusion action plan with four ambition levels to 2030, and a commitment to sign the Diversity Charter Belgium in 2025.
• A 13-week boot camp training people without a technical degree as connection technicians.

On resources: they "are fully included in the total personnel costs and the operational budget", so no separate budget is defined per action (p.189).

Targets related to own workforce

Reference: page 190.

Fluvius "sets result-oriented and time-bound objectives". Two long-term indicators go to the Management Committee and Board: the Great Place To Work score and the absenteeism rate (p.190).

Fluvius also names qualitative challenges for culture, shared leadership and employee-centric transition trajectories (p.190), and a CAO90 bonus tied to safety, efficiency and customer care objectives.

Page 190 adds that "the metrics were not validated by any external party other than the auditor".

Characteristics of the undertaking's employees

Reference: pages 191-192.

As at 31 December 2025, Fluvius counts 5,814 employees (5,645 in 2024), all in Belgium, split between Fluvius SO (5,448) and De Stroomlijn (366) (p.191).

Contract type, 2025 (p.192): 5,683 permanent employees, 131 temporary (181 in 2024), no non-guaranteed hours employees, 4,627 full-time and 1,187 part-time. Total FTE is 5,564.9.

Turnover was 335 employees, or 5.32% of the average headcount (352 and 5.74% in 2024) (p.191).

Fluvius OV employees have no direct contract with the Consolidated Group, so they are reported under S1-7, but other S1 sections treat them as employees (p.191).

Characteristics of non-employee workers in the undertaking's own workforce

Reference: pages 193-194 (S1-7 listed at page 193 of the content index).

Fluvius OV staff have no direct payroll contract with the Consolidated Group, so Fluvius reports them here, while treating them as its own workforce elsewhere in S1 (p.193). "Fluvius has no further employees on its payroll": its HR policy does not permit staff through a management company or as freelancers. Anyone else delivering services works under a purchase or service contract and is employed by a value chain partner, covered under S2 (p.193).

Fluvius OV, 2025 (p.194):

• 549 people (592 in 2024): 102 female, 447 male, none other or not reported; FTE 527.6.
• All permanent; no temporary or non-guaranteed hours workers.
• 465 full-time and 84 part-time.

Collective bargaining coverage and social dialogue

Reference: page 195 (S1-8 listed at page 195 of the content index).

• Fluvius SO: "100% of the own workforce fall under the scope of collective bargaining (within the EU)".
• Fluvius OV: 100% of employees fall under the legal status regulation, according to their statute.
• De Stroomlijn: 100% of employees can benefit from the collective labor agreement provisions.
• Representation: "100% of our own workforce have access to employee representatives".

Fluvius states there are no agreements in place on representation by a European Works Council, an SE works council or an SCE works council (p.195). All employees are in Belgium (p.191).

Diversity metrics

Reference: page 196 (S1-9 listed at page 196 of the content index).

Higher management, gender (p.196):

• Management Committee: 7 members in 2025 (8 in 2024), of whom 1 female and 6 male.
• Senior management: 50 (50 in 2024), of whom 8 female (7 in 2024) and 42 male (43).

Age groups (p.196):

• Under 30: 576 employees (186 female, 390 male); 519 in 2024.
• 30 to 50: 3,549 (1,307 female, 2,242 male); 3,536 in 2024.
• Over 50: 2,238 (535 female, 1,703 male); 2,182 in 2024.

Higher management means the Management Committee plus senior management (heads of department and senior experts) within the own workforce. The page points to the diversity and inclusion policy for the general approach.

Adequate wages

Reference: page 197 (S1-10 listed at page 197 of the content index).

Fluvius states that "the existing pay scales and wage bands in the different statutes at Fluvius comply with all conditions for minimum wages, both at national and sectoral level" (p.197).

At Fluvius SO and Fluvius OV, jobs are classified through a qualification system agreed with the trade unions. Pay scales and wage bands link to those classifications, so each employee receives the wage package that matches the job. De Stroomlijn employees also receive wages matched to their jobs (p.197).

The page states no count of employees paid below an adequate wage benchmark. All employees are in Belgium (p.191).

Social protection

Reference: page 198 (S1-11 listed at page 198 of the content index).

"All Fluvius employees benefit from social protection" against loss of wages from major life events, through public programs and additional employer payments (p.198). Cover named on page 198:

• illness
• unemployment, from the day the employee starts work
• occupational accident and non-congenital disability
• parental leave
• retirement

At and after retirement Fluvius provides a guaranteed income, an invalidity premium, an extralegal pension, death cover and an orphan annuity. Extra insurance exists for hospitalization, ambulant care and accidents in private life. An employer-funded social fund pays allowances for events such as family assistance, disability, orphans and buying glasses (p.198).

Persons with disabilities

Reference: page 199 (S1-12 listed at page 199 of the content index).

Fluvius presents the data "with due regard to the legal limitations on data collection" (p.199).

The total fell by 8 people year on year (p.199).

Training and skills development metrics

Reference: pages 200-201 (S1-13 listed at page 200 of the content index).

Performance reviews (p.200). Fluvius offers a voluntary annual evaluation; executives have a Personal Development Plan updated each performance cycle. 1,734 employees took part in frequent performance and career reviews, or 27.25% (26.82% in 2024): 30.47% of women and 25.74% of men. The figure reflects mainly executives at Fluvius SO and OV and all De Stroomlijn employees. De Stroomlijn customer-facing staff are evaluated each quarter.

Training hours per employee (p.201).

Hours per employee are total training hours divided by all employees, a different basis from the Social Balance Sheet (p.201).

Health and safety metrics

Reference: page 202 (S1-14 listed at page 202 of the content index).

The entire workforce falls under the health and safety management system, built on legal requirements and recognized standards (p.202). In 2025 "the employee fatality rate is 0", in line with the zero fatalities target (p.202).

The rates rest on 9,204,311 hours worked (9,041,015 in 2024) (p.202). Fluvius aims for a severity rate below 0.07 and an upper limit of 4 for the frequency rate. It attributes part of the increase to "a single incident involving a longer period of work stoppage", in which an employee was the victim of road rage (p.202).

The page also reports counts of recordable accidents, ill health cases, work-related illnesses and absenteeism days (p.202).

Work-life balance metrics

Reference: page 203 (S1-15 listed at page 203 of the content index).

Fluvius treats family leave as part of thematic leave and social protection. It aims to support employees during life events such as caring for children or relatives, or illness, and the right applies to permanent and fixed-term employees, including those on time credit (p.203).

All employees have a right to family leave (p.203).

The share of employees who actually took family leave was 11.87% in 2025 (11.05% in 2024). By gender, 9.67% of men (8.67% in 2024) and 16.57% of women (16.08% in 2024) took it (p.203).

Compensation metrics (pay gap and total compensation)

Reference: page 204 (S1-16 listed at page 204 of the content index).

A negative gap means women's average pay is above men's (p.204).

Basis (p.204). The pay gap uses basis-100 pay (gross wage before index adjustment, for a full-time equivalent, excluding overtime) for employees at work for the whole year at Fluvius SO or Fluvius OV. There was no comparable data for De Stroomlijn, where Fluvius says "We estimate that the pay gap at De Stroomlijn does not significantly differ from the Fluvius pay gap". The remuneration ratio uses total taxable reward (wages, premiums, benefits in kind, share options for Fluvius SO executives), less social security contributions, before withholding tax.

Incidents, complaints and severe human rights impacts

Reference: page 205 (S1-17 listed at page 205 of the content index).

Fluvius reports nil figures for both 2025 and 2024 (p.205):

An incident is defined as an admissible complaint with legal consequences at the Deontological Cell, the channel for staff to flag concerns. A complaint is reported only if it is declared admissible (p.205). Discrimination covers gender, race or ethnic origin, nationality, religion, disability, age and sexual orientation, and includes intimidation (p.205).

Policies related to value chain workers

Reference: pages 209-213 (S2-1 listed at page 209 of the content index).

Fluvius says it pays "close attention to respect for human rights, particularly in its supply chain" and expects suppliers, service providers and contractors to respect integrity and social responsibility principles, including ILO labor standards, health and safety, non-discrimination, living wages and collective consultation (p.209). The policy is monitored in the Purchasing department and sits within Socially Responsible Procurement and the purchasing policy (p.209).

• Tender exclusion (p.210): mandatory grounds include criminal organization, bribery, fraud, money laundering, child labor and trafficking; optional grounds include violations of environmental, social and labor law.
• Human rights (p.211): the general policy sits in the EU Taxonomy minimum safeguards. A risk analysis weighs impact and likelihood and now includes a geographic analysis. Main risks are safety and working conditions. "No incidents relating to human rights policy were reported in the 2025 financial year."
• Supplier code of conduct (p.211): approved and published at the end of 2023, tied to the UN Guiding Principles, ILO and OECD instruments. It is mandatory for new contracts only, since current suppliers signed voluntarily.
• Checks (p.212-213): qualification systems, supplier audits and EVA Coaching site evaluations.

Taking action on material impacts on value chain workers

Reference: pages 216-217 (S2-4 listed at page 216 of the content index).

Positive impact (p.216). Measures include site supervisors, safety awareness training at the Fluvius Academy and commitment to cooperation.

Risk of insufficiently suitable contractors and suppliers (p.216). Contracts awarded to additional contractors for grid reinforcement (the main 2025 tender, for digital meters, went to three groups of contractors); qualification systems, with the contractor qualification republished and nine product dossier qualifications updated in 2025; action in critical supplier markets; joint works through Synductis and federal procurement (around 10 federal dossiers in progress); the contractor cooperation pledge; and extra consultations with key suppliers.

Opportunity (p.217). Joint works through Synductis and federal procurement. A "Partnership Pledge" was presented to contractors in December 2024.

Incidents (p.217). "No serious human rights issues or incidents, nor fatal accidents related to the upstream and downstream value chain (contractor fatalities) were reported in the past fiscal year."

Resources "are fully included in the total personnel costs and the operational budget", so no separate budget is given per action (p.217).

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

Reference: page 218 (S2-5 listed at page 218 of the content index).

Fluvius states plainly that it "does not currently set specific targets for managing its material impacts, risks and opportunities with regard to employees in the value chain".

Two partial substitutes are mentioned on page 218:

• Objectives "may be set on a contract basis within the framework of contract management".
• Supplier management monitors indicators "that provide insight into global developments, but no targets are linked to these", for example the number of audits and inspections carried out and the competencies employees in the value chain reach at the Fluvius Academy.

The report presents this as the company's position for 2025 and gives no date for introducing targets.

Policies related to consumers and end-users

Reference: pages 222-225 (S4-1 listed at page 222 of the content index).

Fluvius pursues "a customer-focused and inclusive service policy" aimed at guaranteeing access to basic services for all consumers and end users, with particular attention to vulnerable groups, "regardless of their socio-economic situation or digital skills" (p.222). The Management Committee monitors impacts, risks and opportunities, and the Board keeps ultimate responsibility (p.222).

• Customer promise (p.222): a minimum customer satisfaction score of 79%, and every employee thinking and acting customer centric by 2026.
• Customer-centric approach (p.223): nine rules of thumb, including accessibility, clear information, simple digital solutions, advance information, inclusivity and ecosystem collaboration. All interactions go into a central ticketing system with service level agreements.
• Affordability (p.224): tariffs follow a legal methodology in which the regulator sets permitted income, which limits the risk of unjustified increases.
• Human rights (p.224): based on the UN Guiding Principles, ILO standards and OECD guidelines. "No concessions are made on these human rights principles."
• Public lighting (p.225): a master plan for lighting in all 285 Flemish towns and municipalities, "The right light in the right place at the right time".

Taking action on material impacts on consumers and end-users

Reference: pages 229-230 (S4-4 listed at page 229 of the content index).

Actions taken in 2025 (p.229-230):

• Networks for tomorrow: keeping citizens and local authorities informed about works and possible disruption.
• Contractors' cooperation pledge: built on the pledge launched at the end of 2024, with a customer focus.
• Local government community: an interactive platform for city and municipal staff.
• Complaints redesign: the new process launched in 2024; in 2025 the work was the business case for wider roll-out.
• Site communication: notification letters for planned power cuts are now generated centrally, with a roll-out across the operating area expected by early 2026, and a project started for email and text notices.
• Blocked EANs: an investigation into the backlog caused by the Atrias platform migration, with individual fixes where needed.
• Retroactive subsidies: after a 2025 Energy Decree change, affected customers were contacted on 1 December 2025; work must be completed before the end of March 2026.
• Awareness campaigns on legal obligations, energy saving and scam prevention.

Resources "are fully included in the total personnel costs and the operational budget", so no separate budget is reported (p.230). "No serious human rights incidents involving consumers and end users were reported in 2025."

Effectiveness is monitored using the S4-5 criteria (p.230).

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

Reference: page 231 (S4-5 listed at page 231 of the content index).

Customer satisfaction. Fluvius aims for a score of 79%. The 2025 score was 80.73%, against 79.44% in 2024. De Stroomlijn's CSAT score was 86.37% (84.96% in 2024), from a daily random sample of 600 customers (p.231).

An external agency measures four scores per process and channel: customer satisfaction (CSAT), net promoter score, customer effort score and company effort score (p.231).

Timely execution of core tasks. Monitored through lead times for connection works, payment of premiums, timely installation of digital meters after notification of local production, timely sending of metering data, intervention speeds and performance of customer contacts (p.231). The page gives no numeric lead time targets.

Customer-centric culture. The ambition is for every employee to think and act customer centric. The annual Great Place To Work survey is the lever for checking this perception (p.231).

Business conduct policies and corporate culture

Reference: pages 260-263 (G1-1 listed at page 260 of the content index); governance roles on pages 258-259.

Fluvius has an integrity policy set out in the Ethical Charter, the responsibility of management and applicable to all employees of Fluvius SO and Fluvius OV (p.260). "At present, no specific training courses are provided for employees in this regard" (p.260). The business conduct policy is described as consistent with the UN Convention against Corruption, and "In 2026, further steps will be taken towards formalising an official ABAC policy" (p.260).

Integrity guidelines, drawn up with a working group and employee dialogue, cover dealing with colleagues, being an ambassador for Fluvius, and corruption and conflicts of interest (gifts, events, secondary activities) (p.261). The supplier code of conduct was published at the end of 2023 (p.261).

Whistleblowing (p.262-263). Channels include a dedicated mailbox and an online form, open to employees and external parties. Reports go to a multidisciplinary Ethics Unit led by the legal department; the reporting channel was built with SD Worx under the EU Whistleblower Directive. Reporters may stay anonymous, and can complain to a federal coordinator, with the burden of proof on the entity that took any action.

Governance (p.258). A Code of Conduct for Board members was approved at the General Meetings, and the Audit Committee oversees business conduct matters.

Targets related to business conduct

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

Fluvius states no formal business conduct target, only an ambition. After the incident table it states: "Of course, it remains Fluvius' ambition to maintain all the above numbers at zero" (p.270), meaning zero convictions, zero confirmed incidents of corruption or bribery, zero dismissals or disciplinary actions, and zero terminated contracts (p.270).

The MDR overview lists page 270 as the business conduct effectiveness (MDR-T) reference (p.92). Effectiveness is tracked in the absence of formal targets through:

• the annual incident table, with 2024 comparatives (p.270);
• reports to management on the cases handled by the Ethics Unit (p.268);
• an updated corruption risk profile analysis, to be refined in later years (p.269);
• the Great Place To Work survey, which gauges perceived integrity (p.262).

"Governance" incentive indicators for the Management Committee include managing ESG risks (p.69).

Confirmed incidents of corruption or bribery

Reference: page 270 (G1-4 listed at page 270 of the content index).

Fluvius reports nil figures for 2025 and 2024 (p.270):

Fluvius adds that "There are no public legal proceedings pending or judgments rendered in 2025 relating to incidents of corruption or bribery" against Fluvius, its employees or value chain players in which Fluvius or its employees are directly involved. The figures are "not subject to additional external validation other than by the assurance provider" (p.270).

Political influence and lobbying activities

Reference: pages 271-276 (G1-5 listed at page 271 of the content index).

Political contributions (p.271). "Fluvius does not make political contributions under any circumstances, either in cash or in kind."

Representation (p.271). The Public Affairs department in the Strategy division monitors legislative initiatives at Flemish, federal and European level. Fluvius itself is not registered in the EU Transparency Register. The European federation CEDEC represents it (identification number 54829912208-85) and Synergrid does so nationally (850726637028-25).

Revolving door (p.272-275). Appointments are reviewed for incompatibilities under the Energy Decree, and "no incompatibilities were found" at appointment. A table lists each board member's similar mandates in 2023 and 2024, using the Cumuleo database.

Lobbying (p.276). Themes follow the energy transition and climate adaptation mission. After 2024 elections and 2025 coalition agreements, Fluvius briefed political parties with ten recommendations, including a framework for network congestion, a policy vision on phasing out natural gas networks, resources for heat networks and sewerage, strengthening Fluvius's equity capital, and a market-based tariff framework. It held an "Energy Distribution Master Class" in November 2025.

Payment practices

Reference: page 277 (G1-6 listed at page 277 of the content index).

The standard payment term is 30 days unless the contract says otherwise, and "No distinction is made between payments to small and medium-sized enterprises (SMEs) and other payments to suppliers" (p.277).

Exceptions (p.277): green energy certificates are paid as soon as possible after booking, with a 42-day term used for reporting; cash invoices are not counted as paid on time because approval procedures prevent immediate payment. Fluvius judged a 2024 recalculation unnecessary given the small number of De Stroomlijn invoices. The figures are "not validated externally other than by the assurance provider" (p.277).