Fugro

Governance roles

Reference: pages 118-120, 123. Incorporated by reference to Leadership & governance (page 97).

Fugro N.V. has a two-tier board structure: a Board of Management (CEO and CFO) and an independent Supervisory Board of five members with four permanent committees. The Board of Management is supported by seven senior executives forming the Executive Leadership Team (ELT), established in 2019, each dedicated to a region or key business area. "These governing bodies do not include employee representatives." GOV-1 21a,b,22a (page 118).

The Board of Management is tasked with "developing a strategy aimed at realising sustainable long term value creation taking into account risks and opportunities for the company and the impact of the Group's business activities on its stakeholders and the environment" (page 118). The Supervisory Board "oversees the allocation of responsibilities within the Board of Management and ELT, including those in respect of the environmental, social and governance aspects of Fugro's operations".

The Supervisory Board composition "is balanced and in compliance with the requirement of at least one-third of each gender in accordance with the Dutch Gender Diversity Act" (page 123). Board gender diversity (21(d)) is signposted to page 123 and independence (21(e)) to page 121 (page 101).

Information provided to and matters addressed by the governing bodies

Reference: pages 121, 138.

ELT (page 121). In 2025 the ELT held 22 meetings, including 5 multi-day in-person sessions. It reviews performance monthly, with risks, opportunities and impacts "assessed from multiple perspectives, such as finance, HSSE, commercial excellence, operational excellence, and human resources". Sustainability items included "Fugro's net zero roadmap, science-based emission reduction targets and CSRD reporting", where "The feasibility of Fugro's sustainability targets and net zero roadmap was discussed, balancing the defined timeline, required investments, technological maturity, regulatory developments and the need for operational continuity". The ELT also implemented workforce reductions in all regions and discussed the eNPS decline and the annual fair pay and living wage analyses. GOV-2 26a,b,c

Supervisory Board (page 138). It discussed the net zero roadmap "with internal and external experts" GOV-1 23a; GOV-2 26 a,b,c, and received in-depth sessions on "operational excellence, human capital development, sustainability, cybersecurity, AI and specific Fugro technologies".

Sustainability performance in incentive schemes

Reference: pages 147-148 (Remuneration report), per the ESRS reference table (page 97).

Short-term incentive (page 147). "Under the remuneration policy, 30% of the STI targets is related to non-financial metrics including ESG related topics". For 2025 the three measures for both CEO and CFO were USV utilisation (10% weight, paid at 10%), women in senior management (10%, not achieved, 0%) and voluntary turnover rate (10%, 4%). The committee "concluded that this leads to a pay-out on non-financial metrics of 14% of fixed base salary (10% for climate related ESG targets and 4% for other ESG targets)." GOV-3

All financial metrics fell below threshold and "the Board of Management proposed that no STI should be awarded to the members of the Board of Management and Executive Leadership Team in line with the decision not to grant a bonus across the Fugro organisation". Actual 2025 STI payout was 0.

Long-term incentive (page 148). "25% of the vesting of the performance shares depends on the ESG and strategic targets set in 2023. This percentage is divided over the following targets: vessel CO2 intensity reduction (8.33% at target), revenue in renewable energy market (8.33% at target), and women in senior management target (8.33% at target)." Those measures scored 16.7%, producing 4.2% vesting, against 0% for both TSR and ROCE. GOV-3

Statement on due diligence

Reference: page 49.

Fugro presents GOV-4 as a cross-referencing table mapping the core elements of due diligence to the chapters carrying each:

• Embedding due diligence in governance, strategy and business model - Own workforce (policies); Responsible supply chain (policies on workers in the value chain).
• Engaging with affected stakeholders - General disclosures (Interests and views of stakeholders); Own workforce (engagement processes); Business conduct (Speak Up procedure).
• Identifying and assessing adverse impacts - General disclosures (Materiality assessment process); Climate change (GHG emission profile); Biodiversity and ecosystems; Responsible supply chain (Potential impacts on workers in the value chain).
• Taking actions to address adverse impacts - Climate change (Transition plan); Own workforce (Health, safety and security); Biodiversity (Underwater noise pollution; Invasive species); Responsible supply chain; Business conduct (Prevention and detection of corruption or bribery; Compliance monitoring).
• Tracking effectiveness and communicating - Climate change (GHG emission profile); Own workforce (safety performance, engagement survey, living wage assessment, gender pay gap); Responsible supply chain (Supplier due diligence process).

The EU-legislation datapoint table records GOV-4 (paragraph 30, SFDR) as material, page 44 (page 101).

Risk management and internal controls over sustainability reporting

Reference: pages 86-87 (ESG accounting disclosures).

"The Board of Management is responsible for the contents of the annual report. Group Sustainability coordinates the sustainability reporting content and maintains ESRS-based reporting manuals for GHG emissions, HSSE, HR, and Compliance" (page 86). It "assesses the inherent risks of potential errors in different types of environmental, social and governance data, and the residual risk after applying internal controls".

Three main inherent risks are named:

• Incomplete reporting of GHG emissions - monthly Fleet Services checks on all vessels over 24 metres. "It was noted that chartered support vessels were not always registered in the operational management system. Therefore, an additional manual control was implemented to collect fuel data for this specific group of vessels, to be replaced by an automated control in 2026." Residual risk low.
• Incomplete reporting of HSSE incidents - residual risk low (page 87).
• Incomplete information on ESG impacts in the value chain - "Fugro applies the transitional provision for value chain information" (page 87).

"Internal Audit reports their ESG-related findings to the Board of Management, the Executive Leadership Team and the Audit Committee" (page 87).

Strategy, business model and value chain

Reference: pages 10-13, 45, 48. Incorporated by reference to the Profile and Strategy chapters (page 98).

Fugro is "the world's leading Geo-data specialist. Through our unique map, model and monitor solutions, we deliver critical insights into both built and natural environments" supporting "energy security and the energy transition, large-scale infrastructure development and climate change adaptation" (page 10). It had 10,227 employees at 31 December 2025 (page 70).

Business lines (page 11): site characterisation (marine 51% of revenue; land) and asset integrity (marine 27%; land), spanning geophysical survey, geotechnical investigation, geoconsulting, metocean monitoring, satellite positioning, and inspection and monitoring.

Value chain (page 45). Upstream: equipment suppliers, third party vessel owners, shipyards, fuel suppliers, data and cloud services, IT, crewing agencies and subcontractors. Own operations run owned and leased vessels (traditional and uncrewed), jack-up platforms, drill rigs, USVs, ROVs and CPT trucks. The workforce is 89% own employees and 11% contingent workers.

Fossil fuel involvement (page 51): "While Fugro provides services in support of oil and gas and mining activities, Fugro is not itself involved in exploration, mining extraction, distribution, refining or manufacturing of fuels or materials."

Interests and views of stakeholders

Reference: pages 42-43.

"Stakeholders who are most relevant to our success, and most likely to be impacted by our activities, are clients, employees, shareholders and lenders, suppliers, local communities, governments, regulatory authorities, non-governmental organisations, universities, and industry organisations" (page 42). "The key topics of the engagement with our stakeholders are reported by the responsible managers and discussed within the Executive Leadership Team and Supervisory Board." A Public Affairs Committee including the CEO, Public Affairs Manager, General Counsel and Director Brand & Communications meets periodically.

Page 43 tabulates how Fugro engaged in 2025 and the effect on strategy:

• Clients - key account management, surveys, innovation co-development. Topics included "slowing down of investments in offshore renewables and an increased emphasis on gas-related projects as a transitional energy source". Client views feed "its net-zero programme... and shared biodiversity ambitions".
• Employees - twice-yearly surveys, town halls, works councils. Topics: "Impact of the restructuring programme", rewards, culture, Speak Up, training.
• Investors - "ESG performance and progress on implementing relevant roadmaps".
• Suppliers - "ESG due diligence and EU's Corporate Sustainability Due Diligence Directive".

Material impacts, risks and opportunities

Reference: pages 45-47, with per-topic IRO tables on pages 52, 63, 69, 77 and 81 (page 98).

Fugro presents 20 numbered material IROs, each linked to a position on the value chain diagram (page 45) and repeated at the head of every topical chapter.

As printed: IRO 1 "Fugro's activities cause GHG emissions from own operations (scope 1 & 2), of which 90% from vessels, and from suppliers (scope 3)"; IRO 5 "Fugro provides services to clients operating in oil and gas industry, which negatively impacts the environment", flagged as an impact over S/M/L and a risk over the long term; IRO 14 "Several employees have lost their jobs because of the economic downturn in the offshore wind market" (pages 46-47, 52, 69).

Change versus 2024 (page 44): "the topic 'affected communities' was discontinued as a material topic because Fugro's position early on the value chain limits its ability to have knowledge of, let alone influence on, community impacts of client projects."

Limitation: anticipated financial effects (paragraph 48(e)) are not reported, under an ESRS 1 Appendix C phase-in (page 86).

Process to identify and assess material impacts, risks and opportunities

Reference: page 44, with topic-specific processes on pages 51-53 (climate) and 63 (biodiversity).

"In 2025, Fugro reviewed its material impacts, risks and opportunities to identify any changes compared to 2024." The assessment included (page 44):

• "Confirming that no material changes in the organisational structure or operations occurred in 2025."
• "A thorough climate risk and opportunity assessment including climate scenario analysis, which was supported by external experts."
• "Employee engagement survey results and supplier due diligence outcomes."
• "Visualising Fugro's value chain and clearly linking material impacts, risks and opportunities to own operations, upstream suppliers and downstream clients and projects."
• "Aligning impacts, risks and opportunities with ESG risk prioritisation in Fugro's overall risk management framework relying on annual scoring of impact and likelihood."

"The outcomes were validated by Fugro's ESG reporting steering committee consisting of representatives from the sustainability, finance, legal/compliance and investor relations departments, and thereafter presented to the audit committee of the Supervisory Board."

Disclosure requirements covered by the sustainability statement

Reference: pages 97-100 (ESRS disclosure requirements reference table), with the EU-legislation datapoint index on pages 101-103.

Fugro prints a full ESRS disclosure requirements reference table over four pages, listing each disclosure requirement against the annual report chapter and the named paragraph carrying it. Governance requirements are tagged inline in the text (for example GOV-1 21a,b,22a on page 118 and GOV-2 26a,b,c on page 121).

Standards covered are ESRS 2, E1, E4, S1, S2 and G1. E2, E3, E5, S3 and S4 do not appear, consistent with the DMA outcome on page 44.

Requirements the table itself marks as not covered: E1-7 and E1-8 ("N/A"), S1-11, S1-12 and S1-15 ("N/A (not disclosed)"), and S2-2 and S2-5 ("N/A"). E1-9 and E4-6 are marked "Fugro applies phase-in option".

Page 86 lists the phase-in provisions used under Appendix C of ESRS 1 and Commission Delegated Regulation (EU) 2025/1416: SBM-3 paragraph 48(e), E1-9, E4-6, S1-11, S1-12, "S1-14 The data points on cases of work-related ill health", S1-15, and the "Transitional provision related to the value chain".

Pages 101-103 carry the separate index of datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law), each marked Material or Not material with a page number.

Transition plan for climate change mitigation

Reference: pages 58-61 ("Transition plan - Fugro's roadmap towards net-zero emissions").

"Fugro reviewed its decarbonisation pathway and decided to fully focus on its net zero target validated by the Science Based Targets initiative (SBTi) long-term target: a 90% absolute reduction in emissions by 2050 from the 2022 base year" (page 58).

Seven decarbonisation levers (page 58): uncrewed surface vessels and remote operations; efficiency measures; alternative fuels; third-party chartered vessels; vehicles and equipment; renewable electricity; scope 3 supplier engagement. A waterfall chart (page 59) models scope 1 and 2 from 218 ktCO2eq in 2022 to residual emissions of at most 10% of the baseline by 2050.

Status (page 58): "Currently, we are in early phases of the execution of our transition plan... we annually review the feasibility of the implementation of actions planned. Oversight of this roadmap rests with the Board of Management."

Resources (page 61): "In 2025, EUR 172 million was considered Taxonomy-eligible capex, covering general vessel investments and specific expenditures related to improving efficiency and reducing the carbon footprint of our fleet."

Locked-in emissions (page 61): "None of Fugro's current large assets... have a planned operating lifespan beyond 2050, as such there are no locked-in emissions for the net-zero target year."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 "Climate-related risks and opportunities" section, disclosed in the FY2025 report on pages 51-53. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Identification (page 51). "In 2025, Fugro conducted a climate risk and opportunity assessment... Building on 2020 and 2024 analyses, the assessment followed two structured steps: 1. identification and prioritisation of relevant physical and transition climate risks and opportunities 2. scenario analysis." Fugro "assessed the relevance of 28 climate hazards defined in ESRS E1 Appendix A and the EU Taxonomy".

Physical scenarios (page 53). "The analysis covered 25 strategically selected locations (land, offshore, ports)... Two Intergovernmental Panel on Climate Change (IPCC) climate scenarios, SSP1-2.6 (low emissions) and SSP3-7.0 (high emissions), were chosen."

Transition scenarios (page 53). "two climate scenarios, Net Zero 2050 (low emissions) and Current Policies (high emissions), were applied across the same time horizons", using NGFS data.

Gap: no global average temperature projection is stated per scenario, and both assessments "reflect the inherent risk for the company, without accounting for existing or planned adaptation measures".

Resilience in relation to climate change

Back-filled from the E1 "Climate change resilience & governance" section and ESRS 2 SBM-3, disclosed in the FY2025 report on pages 54, 61 and 87. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Capacity to adapt (page 54). "Fugro's high-value assets, particularly its vessels, can be repositioned or rerouted to minimise exposure to storms and other acute hazards... Long-term physical changes, such as coastal erosion and sea level rise, also create opportunities for Fugro to apply its Geo-data expertise in coastal resilience and adaptation projects." On transition risk, "The phased implementation of fleet upgrades and fuel transition allows Fugro to align its operational capacity with technological and market readiness."

Uncertainty (pages 61, 87). "uncertainties such as regulatory changes, market developments including client acceptance, and availability and affordability of alternative fuels, may influence the actual reduction path." A dedicated paragraph, "External dependencies affecting transition plan outcomes", adds that "Capital allocation requirements, potential changes in operating expenditures, availability of financing, and the economic viability of emerging technologies may impact the financial performance and feasibility of planned actions".

Gap: no quantified resilience analysis of the strategy and business model under the scenarios used.

Policies related to climate change mitigation and adaptation

Reference: pages 52, 58-61. The ESRS reference table maps E1-2 to the "Transition plan - Fugro's roadmap towards net zero emissions" paragraph (page 98).

Fugro presents no separate named climate policy document. The IRO table (page 52) lists "Transition plan" as the policy for the material topic Greenhouse gas emissions, and "Part of strategy Towards Full Potential" for Climate change mitigation & adaptation solutions.

The transition plan carries the commitments (pages 57-58): a validated SBTi pathway to cut absolute scope 1 and 2 GHG emissions 54.6% by 2033 against a 2022 base year and absolute scope 1, 2 and 3 emissions by at least 90% by 2050, with renewable electricity rising to 100% by 2030. "Fugro has elected to forgo its 2035 net-zero ambition in favour of concentrating entirely on its SBTi-validated near- and long-term targets for 2033 and 2050" (page 57).

Adaptation sits inside operational planning rather than a standalone policy: "Fugro monitors physical climate risks as part of its global risk management framework, which integrates climate hazards across its land and marine operations" (page 54).

Scope and accountability: the plan covers own operations and the upstream value chain through supplier engagement; "Oversight of this roadmap rests with the Board of Management" (pages 58, 60).

Actions and resources in relation to climate change policies

Reference: pages 58-61.

Uncrewed surface vessels (page 58). USVs and Remote Operations Centres lower "carbon intensity by approximately 90% compared to traditional vessels". "In 2025, Fugro expanded its fleet to ten USVs with seven commercially operational."

Efficiency measures (page 58). SEEMP plans per vessel, reviewed annually, aiming "to reduce emissions up to 10%". "In 2025, a new propulsion system has been completed on a geotechnical vessel, leading to up to 20% CO2 savings. A second geotechnical vessel received a propulsion retrofit."

Alternative fuels (page 59). "In 2025, Fugro Pioneer was equipped with a methanol capable engine following its first conversion phase in 2024, and engineering work for a second vessel commenced", part-funded by a Netherlands Enterprise Agency grant. "The vessel is methanol-ready but not sailing on methanol yet." Green methanol "can deliver up to 95% GHG reduction compared to MGO"; certified HVO "at least 80%".

Renewable electricity (page 60). 42% bundled RECs, 35% unbundled EACs and 3% self-generated solar gave 80% renewable electricity (2024: 46%).

Supplier engagement (page 60). "As of December 2025 around 8% of suppliers by spend have formally committed to or have validated science-based emission reduction targets", against 60% by 2028.

Targets related to climate change mitigation and adaptation

Reference: pages 56-57.

"Fugro's near- and long-term science-based emissions reduction targets have been validated by the Science Based Targets initiative (SBTi) since 2024... aligned with the latest scientific consensus to limit global warming to 1.5C above pre-industrial levels" (page 57). Base year 2022.

Validated commitments (page 57):

• Absolute scope 1 and 2 GHG emissions -54.6% by 2033 vs 2022, to 99 ktCO2eq.
• Renewable electricity from 47% in 2022 to 80% by 2025 and 100% by 2030.
• Absolute scope 3 from fuel- and energy-related activities -54.6% by 2033 to 25 ktCO2eq.
• "60% of its suppliers by spend... having science-based methodology aligned emission reduction targets by 2028."
• Absolute scope 1, 2 and 3 at least -90% by 2050 vs 2022 market-based, to 45 ktCO2eq, with the remainder offset "by carbon removals in accordance with SBTi guidance".

Explicit deviation: "Fugro focuses on its validated science-based targets and therefore did not set an additional target for 2030 as prescribed by ESRS E1-4 34d".

Vessel intensity targets (page 57). 20% intensity reduction for owned and chartered vessels by 2025 vs 2020, and 25% for owned vessels by 2027. Outcome: intensity "decreased by 8% compared to the 2020 baseline which is not enough to meet the 20% reduction target"; owned vessels decreased 3%.

Energy consumption and mix

Reference: page 62.

"In 2025, the total energy consumption from Fugro's own operations was 808,062 MWh, of which 97% from fossil sources... Approximately 86% of fossil energy consumption is from marine gas oil (MGO) consumed by owned and chartered vessels, jack-up platforms, geotechnical drill rigs and other nearshore assets."

Table as printed (2024 -> 2025):

• Crude oil and petroleum products: 773,930 -> 737,541 MWh
• Natural gas: 4,842 -> 4,045 MWh
• Purchased electricity, heat, steam and cooling from fossil sources: 38,426 -> 40,603 MWh
• Total fossil energy consumption: 817,198 -> 782,189 MWh (98% -> 97%)
• Nuclear sources: 1,628 -> 1,666 MWh (0.2%)
• Fuel from renewable sources including biomass: 4,825 -> 10,492 MWh
• Purchased renewable electricity, heat, steam and cooling: 13,810 -> 12,925 MWh
• Self-generated non-fuel renewable energy: 586 -> 790 MWh
• Total renewable energy consumption: 19,221 -> 24,207 MWh (2% -> 3%)
• Total energy consumption: 838,047 -> 808,062 MWh

Coal and other fossil sources are nil. Fossil energy disaggregation by source (paragraph 38) and energy intensity in high climate impact sectors (paragraphs 40-43) are both marked Not material (page 101).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 54-56.

"In 2025, 90% of Fugro's combined scope 1 and 2 emissions (46% of total GHG emissions) originates from its vessels" (page 54).

Table as printed, ktCO2eq (2022 base / 2024 / 2025), page 56:

• Owned vessels 102 / 109 / 112; chartered vessels 82 / 81 / 72; other assets 25 / 20 / 16
• Gross Scope 1 (consolidated group) 209 / 210 / 200, plus 1 from joint ventures; "Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) 0%"
• Location-based Scope 2 12 / 13 / 12; market-based Scope 2 8 / 9 / 3
• Gross Scope 3 236 / 265 / 240: purchased goods and services 95, capital goods 47, fuel and energy-related 49, upstream transport 13, waste 1, business travel 20, commuting 10, investments 5; categories 8-14 nil
• Total (location-based) 458 / 489 / 453; total (market-based) 454 / 485 / 444

Intensity (page 55). Scope 1, 2 and 3 intensity rose to 0.24 tCO2e per EUR 1,000 revenue (2024: 0.21), "mainly driven by a reduction in operational days, while Fugro's asset base and associated emissions remained in place".

Restatements. Purchased goods and services, capital goods and business travel "were found to be overstated for 2024 and have been corrected" (page 86). 37% of 2025 scope 3 used primary data (2024: 33%) (page 87).

Biodiversity in strategy and business model

Reference: pages 63-66 (page 99).

Downstream value chain (page 65). "Fugro recognises potential biodiversity impacts of client projects, and aims to raise awareness among commercial teams to identify risks related to conversion or degradation of protected areas and critical habitats at project acceptance." A named exclusion: "Fugro does not engage in deep sea mining services until the impacts on the environment and ecosystems are thoroughly assessed by independent research organisations and clear regulation is approved by the UN International Seabed Authority."

Client solutions (page 65). "High-quality data underpins the effective application of the mitigation hierarchy, enabling clients to avoid or minimise potential environmental impacts." In 2025 the BeWild project "conducted the world's first fully remote ecology survey of an operational wind farm" at CrossWind's Hollandse Kust Noord, and Fugro acquired EOMAP, a satellite Earth Observation specialist.

Partnerships (page 66). Fugro co-chairs the Corporate Data Group, whose 2025 ocean data sharing recommendation "was adopted by the 33rd session of the IOC Assembly held in Paris", and contributed "an additional 140,000 km2 of in-transit bathymetry data" to Seabed 2030, "with a total of over 3 million km2 data collected since the start of the project".

Policies related to biodiversity and ecosystems

Reference: page 63.

"Fugro's biodiversity policy reflects our commitment to minimise negative impacts on biodiversity from our operations, avoiding adverse effects across the value chain, and maximising positive contributions through client solutions, knowledge sharing and partnerships. Biodiversity considerations are integrated into the environmental management of Fugro's operations" (page 63).

Scope of protection: "Fugro aims to prevent degradation of protected areas and critical habitats which includes UNESCO World Heritage Sites, IUCN (International Union for Conservation of Nature) protected areas, as well as critical habitats that are home to species on the IUCN Red List of Threatened Species."

Development and accountability: "Fugro's biodiversity policy was developed with internal environmental experts and considers insights from industry associations and discussions with clients, and considers evolving standards and legislation. The policy is publicly available and referenced in internal and external communications. Implementation is overseen by the Fleet Global Director and regional Group Directors" (page 63).

Sustainable oceans, land and deforestation practices: the index of datapoints deriving from other EU legislation records "E4-2 Sustainable land / agriculture, oceans / seas and deforestation practices or policies, paragraphs 24(b), (c), (d), SFDR" as Not material, page "N/A" (page 102).

Actions and resources related to biodiversity and ecosystems

Reference: pages 64-65 (page 99).

Underwater noise (page 64). Sources are "shallow seismic surveys, geotechnical drilling to obtain soil samples, vessel engines, jack-up platforms, and unexploded ordnance (UXO) clearance". Mitigation:

• "Fugro employs marine mammal observers (MMOs) and conducts passive acoustic monitoring (PAM) when required by clients or legislation, pausing operations when a marine mammal is detected", following JNCC guidelines.
• "Most of Fugro's vessels have a diesel electric power setup to avoid vibration, as well as vibration dampers and insulation to reduce noise."
• For UXO clearance, "avoidance (leave in place) and lift-and-shift options being preferred", otherwise "low order techniques if feasible, noise forecasts, double bubble curtains and continuous noise monitoring".

Invasive species (page 65). "all Fugro vessels comply with the ballast water standards of the International Maritime Organization", audited internally and externally. "Fugro has implemented ship-specific biofouling management plans in accordance with IMO guidelines... regularly reviewed following dry-docking periods." "Since 2024, Fugro is trialling ultrasound transmitters to prevent growth on ships' hulls... on eight vessels across all operating regions", with effectiveness to be evaluated at 2026 dry dockings.

Targets related to biodiversity and ecosystems

Reference: pages 63, 65. The ESRS reference table maps E4-4 to the "Invasive species" paragraph (page 99).

Fugro discloses one biodiversity target, presented as the key performance indicator against the Biodiversity IRO table: "Owned vessels with biofouling management plan (in %)", with a target of 100% and a result of 93% in 2025 (2024: 93%) (page 63). The target is not dated in the table.

The underlying commitment is set out on page 65: "Fugro has implemented ship-specific biofouling management plans in accordance with IMO guidelines, designed to minimise biological growths on the hull thereby minimising the likelihood of transporting invasive species."

Explicit absence of other targets (page 65): "No metrics or targets have been set for underwater noise pollution due to insufficient data on underwater noise levels and their potential impacts on marine species."

Fugro does not set targets for its downstream biodiversity impacts or for its positive-contribution IROs, and does not state whether the biofouling target is ecological-threshold based or derived from a biodiversity framework. Its alignment reference is directional only: minimising alien species introduction "contributes to the 2030 target six of the Kunming-Montreal Global Biodiversity Framework, as well as the EU Biodiversity Strategy for 2030" (page 65).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 63-64 (page 99).

The single quantified impact metric is "Owned vessels with biofouling management plan (in %): 93" (2024: 93), target 100% (page 63), used as the proxy for the risk of transferring invasive species between marine ecosystems.

Sites in or near biodiversity-sensitive areas (page 64). "A representative sample of 25 locations across Fugro's operations were analysed against publicly available data on protected areas and critical habitat locations from the Key Biodiversity Area Programme, developed and overseen by leading nature conservation organisations, including the IUCN, the Rainforest Trust and WWF. Two locations were identified within key biodiversity areas: one location was a port in Port Fourchon, LA, USA; the other was an office location in Perth, Australia."

Not quantified. No land-use change, ecosystem extent or condition, or species population metrics are disclosed, and there is no noise metric: "No metrics or targets have been set for underwater noise pollution due to insufficient data on underwater noise levels and their potential impacts on marine species" (page 65).

Policies related to own workforce

Reference: pages 70-71.

Human rights policy (page 70). "Fugro recognises its responsibility under the UN Guiding Principles on Business and Human Rights... Fugro's policy on human rights encompasses the rights of its own workforce, workers in the value chain, suppliers, business relationships and affected communities. Fugro's commitments include the Core Conventions of the International Labour Organization (ILO), outlining no forced labour, no child labour, freedom of association and collective bargaining, equal pay and freedom from discrimination. The policy also refers to the ILO standards for fair working hours and fair wages and specifically the Maritime Labour Convention." Executive responsibility "lies with the General Counsel and the Chief Human Resources Officer".

Culture of Belonging policy (page 70). "To further substantiate its commitment to the rights of equal treatment and freedom from discrimination for its own workforce, Fugro has a Culture of Belonging policy. The Chief Human Resources Officer is responsible for implementation."

HSSE policy (page 71). "The scope of this policy is Fugro's own workforce and contractors working at project sites under Fugro's operational responsibility." Practices are certified to ISO 9001, ISO 45001, ISO 14001 and the ISM Code or equivalent.

"Processes and measures for preventing trafficking in human beings" (paragraph 22) is marked Not material (page 102).

Processes for engaging with own workforce and workers' representatives

Reference: page 76.

"Fugro engages with its workforce through bi-annual company-wide engagement surveys. In addition, there is regular interaction with works councils in countries where these are present."

2025 results. "In 2025, two surveys were conducted. The April survey showed an eNPS of 34, followed by a decline to 26 in October, which still is one point above external benchmarking. This decline reflects the impact of market volatility on Fugro's business and financial performance, and resulting required cost reductions including workforce reductions." Response rates were 74% (Q2) and 62% (Q4), against 70% in both 2024 quarters.

Follow-up. "Regional Group Directors are accountable for engagement outcomes and follow-through in their areas. Seafarers are also included in the engagement process, with follow-up coordinated by the global fleet crewing manager through vessel visits and annual crew seminars."

Representation. Works councils operate in the Netherlands, the UK, Germany, Austria and France, and health and safety committees in Norway and Chile; "The coverage rate of workers' representation is 41% (2024: 39%)" (page 73).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 83 (Speak Up programme, in the Business conduct chapter, per the reference table on page 99).

"Concerns can be reported directly to colleagues, management, or HR, or through Fugro's confidential Speak Up procedure, which is available to employees, contingent workers, suppliers, customers, value chain workers, and community members."

Channel design: "Speak Up is a core element of Fugro's compliance programme and is accessible via multiple channels, including an independent external reporting line available 24/7 in more than 50 languages, with the option to report anonymously. Fugro applies strict non-retaliation and confidentiality protections and handles all reports through a structured and fair investigation process aligned with the European Whistleblower Protection Directive."

Oversight: "The Corporate Integrity Committee, consisting of the Group Director Human Resources, Director Internal Audit, and General Counsel, oversees investigations, reports significant matters to executive management, and ensures appropriate remedial actions are implemented and monitored." It meets every four to six weeks, with investigations "conducted outside the direct management chain of the individuals involved" (page 81).

Stated limitation: "Awareness and accessibility of the Speak Up procedure among value chain workers and community members have not been formally assessed."

Taking action on material impacts on own workforce

Reference: pages 70-75 (page 99).

Health and safety (pages 71-72). A dual approach: the 3S Framework (Think Safe, Work Safe, Stay Safe) as "our operational backbone" and the Care4You Strategy as "our transformation engine". In 2025 HSSE and Quality teams were consolidated under Operational Excellence. Critical Risk Management analysed data on activities linked to critical risks, with "practical toolkits and workshops in 2026".

Responsible workforce transformation (page 70). "Fugro prioritises voluntary solutions wherever possible, including natural attrition, early retirement, and part-time work arrangements. Investment in internal mobility and reskilling, helps employees find new opportunities within or outside Fugro. Where forced lay-offs are inevitable, we consistently provide tailored redundancy packages, which vary by country."

Adequate wages (page 73). The 2025 living wage assessment "identified a few employees... earning less than the living wage threshold in Albania, Hong-Kong and Singapore. These nine cases (1% of total employees in these countries) will be corrected."

Culture and talent (pages 74-75). Fugro Academy delivered 102,887 completed training courses (2024: 119,912), and the GREAT leadership model launched with "569 leaders participated in a formal leadership programme".

Targets related to own workforce

Reference: page 69, with results on pages 72-76.

The KPI column of the Own workforce IRO table (page 69) carries the targets, each with 2025 and 2024 results:

• Lost time injury frequency (per mln. hours) - 0.46 (2024: 0.20). No numeric target printed.
• Female employees (in %) - 24 (2024: 23). No numeric target printed.
• Women in senior management (in %) - 23 (2024: 24), target "25% by 2025 and 25%-30% by 2027". Not achieved: female representation "stands at 23%, marking a decrease from 24% in 2024 and below the 25% target for 2025... Our ambition of 30% by 2027 remains firmly in place" (page 74).
• Employee net promoter score (eNPS) - 26 (2024: 36), target "> 30 by 2027" (page 76).
• Voluntary employee turnover rate (in %) - 9 (2024: 9), target "< 8 by 2027" (page 76).

Target setting is described centrally: "Targets have been developed by internal experts and are approved by the Board of Management. External stakeholders have not been involved in target setting. Progress on targets is evaluated periodically... employee statistics are monitored on a monthly basis whereas the living wage and gender pay gap assessment are performed twice a year" (page 48).

Three measures also carry remuneration weight: women in senior management and voluntary turnover in the 2025 STI, and women in senior management in the 2023 LTI grant (pages 147-148).

Characteristics of the undertaking's employees

Reference: page 70.

By gender (headcount at 31 December 2025, 2024 comparative):

• Female 2,450 (2,622)
• Male 7,771 (8,589)
• Other 3 (2)
• Not reported 3 (6)
• Total employees 10,227 (11,219)

"The related number of FTEs is reported in note 12 of the consolidated financial statements."

By country representing at least 10% of total employees: United Kingdom 1,805 (1,900); Netherlands 1,640 (1,672); United States of America shown as less than 10% in 2025, having been 1,190 in 2024.

Turnover (page 76). Leavers 2,290 (2024: 1,980); employee turnover rate 21% (18%); voluntary turnover rate 9% (9%). "The increase in employee turnover can be explained by the restructuring that was needed to adapt to the challenging conditions in Fugro's energy markets."

By age group (page 74): under 30 1,666 (1,969); 30-50 6,162 (6,620); over 50 2,399 (2,630).

Definitions (page 89): employees are "Individuals who are in an employment relationship with Fugro according to national law or practice", with gender recorded "based on the employee's choice in the global HR system". No breakdown by employment contract type or by full-time and part-time is given.

Characteristics of non-employee workers

Reference: page 70.

Fugro reports non-employees in its own workforce as "contingent workers", in three categories (headcount at 31 December 2025, 2024 comparative):

• Vessel crew employed via crewing agencies: 512 (519)
• Contingent workers - project: 569 (732)
• Contingent workers - office: 141 (293)
• Total contingent workers: 1,222 (1,544)

The value chain diagram gives the proportion: "Fugro's workforce consists of 89% own employees and 11% contingent workers on owned vessels, projects and in offices" (page 45).

Definition (page 89): "Contingent workers - Individuals who work for Fugro on a non-permanent basis to fulfil a specific task, project or assignment under Fugro's supervision and who are paid an hourly or daily rate for their work. These include self-employed workers and agency workers."

Seafarers span both categories: "a distinct group being marine crew on its owned vessels ('seafarers'), who may work under Fugro employment contracts as Fugro's employees or through crewing agencies as 'non-employees'" (page 69). Crew agencies are audited annually "to ensure compliance with labour rights in accordance with the Maritime Labour Convention of the ILO. (Note: crew hired via agencies are non-employees in the workforce and are therefore included in chapter Own workforce.)" (page 78).

Collective bargaining coverage and social dialogue

Reference: page 73.

"Collective or individual labour relations are ruled by local applicable law, collective agreements, Fugro's Code of Conduct and its underlying policies. Various collective bargaining agreements are in place within several of Fugro's entities. These cover topics such as remuneration, working conditions, health and safety, equal opportunity and training" (page 73).

Coverage:

• "15% (2024: 14%) of Fugro's employees are covered by collective labour agreements."
• "The coverage rate of workers' representation is 41% (2024: 39%) for Fugro groupwide."

Seafarers. "Whilst not all vessels, and therefore not all seafarers, are officially governed by the International Transport Workers' Federation (ITF) and the International Bargaining Forum (IBF) collective bargaining agreement (CBA), Fugro's employment terms meet or exceed these standards."

Representation bodies. "In the Netherlands, the UK, Germany, Austria and France, employees are represented by works councils. In Norway and Chile, employees are represented by health and safety committees."

Contract security. "Per year-end 2025, 93% (2024: 91%) of female employees and 88% (2024: 85%) of male employees had a permanent employment contract."

Coverage is not disaggregated by country or by EEA and non-EEA region.

Diversity metrics

Reference: page 74.

Gender diversity in senior management (page 74), 31 December 2025 with 2024 comparatives:

• Female 23% (2024: 24%)
• Male 77% (2024: 75%)
• Female headcount 39 (2024: 41)
• Male headcount 131 (2024: 127)
• Other headcount 0 (2024: 0)
• Not reported headcount 1 (2024: 2)
• Total number of employees in senior management (headcount) 171 (2024: 170)

Distribution of employees by age group (headcount, page 74):

• Under 30 years old 1,666 (2024: 1,969)
• 30-50 years old 6,162 (2024: 6,620)
• Over 50 years old 2,399 (2024: 2,630)

Definition (page 89): "Percentage of women in senior management - Number of women in defined senior management positions as share of total number of defined senior management positions, based on headcount as at the end of the reporting period. Senior management positions include the Board of Management, the Executive Leadership Team and key management positions."

Commentary (page 74): "In 2025, female representation in senior management stands at 23%, marking a decrease from 24% in 2024 and below the 25% target for 2025. This reflects a combination of factors, including changes in organisational structure."

Board-level gender diversity is disclosed separately under GOV-1 and signposted to page 123 in the EU-legislation datapoint table (page 101).

Adequate wages

Reference: page 73.

"Fugro is committed to living wages for all its employees and seafarers in the workforce. Fugro adheres to national statutory minimum wage laws and commits to payment of a living wage when it exceeds the statutory minimum" (page 73).

Definition used. "Living wage, in line with the ILO definition, is a wage that provides employees with the necessary income to maintain a decent standard of living for themselves and their dependents, based on local cost of living and calculated for the work performed during the normal hours of work excluding overtime."

Method and frequency. "Fugro's 2025 living wage assessment, conducted twice a year after the compensation review cycle and at year-end, compared data from its global human resource system with benchmark data provided by 'WageIndicator', a well-known labour market database." The twice-yearly frequency is confirmed on page 48.

Result and remediation. "In the most recent living wage assessment, a few employees were identified as earning less than the living wage threshold in Albania, Hong-Kong and Singapore. These nine cases (1% of total employees in these countries) will be corrected."

Fugro does not disclose the percentage of employees paid at or above an adequate wage benchmark by country or region, and does not state whether the nine cases were corrected within the reporting period.

Training and skills development metrics

Reference: page 75 (page 100).

Metrics disclosed:

• "In 2025, 102,887 training courses were completed through the academy (2024: 119,912)."
• "The average number of formal internal training hours per employee was 17."
• "In 2025, 96% (2024: 97%) of eligible employees participated in [performance and career development] reviews (women 97%; men 96%)."
• "In 2025, 569 leaders participated in a formal leadership programme, and 2,081 participants attended manager masterclasses."
• "over 981 business training enrolments were supported via live facilitated sessions, with a further 12,241 enrolled on self-directed digital courses."

Definition (page 89). Eligible employees for performance reviews "at the review closing date of the reporting year (14 February) were hired on or before 1 September of the prior year, and not on long term leave when the performance review was launched".

A 2025 milestone was "the recognition of our new programme Generic Maritime Autonomous Surface Ships (MASS) Remote Operator Training by the British Maritime and Coastguard Agency".

Training hours are not split by gender, and the review percentage covers employees only.

Health and safety metrics

Reference: page 72.

"% of people in the workforce who are covered by the Fugro health and safety management system: 100%" in both 2025 and 2024.

2025 (employees / contingent workers / total workforce), with the 2024 column figure:

• Lost time injuries - 10 / 4 / 14 (2024: 7)
• Lost time injury frequency - 0.37 / 1.03 / 0.46 (2024: 0.20)
• Days lost due to work-related injury or illness - 85 / 146 / 231 (2024: 68)
• Total recordable cases - 36 / 7 / 43 (2024: 40)
• Total recordable case frequency - 1.35 / 1.81 / 1.41 (2024: 1.12)
• Fatalities - 0 employees, 0 contingent workers, 0 subcontractors (2024: 1 employee)
• Life Saving Rules e-learning completed: 97% (2024: 94%)

The Five-year historical review gives the combined workforce-and-subcontractor basis: LTIF 0.42 in 2025 (2024: 0.20) and TRCF 1.28 (2024: 1.12) (page 230).

Comparability break. "From 2025, safety performance metrics are reported for employees and contingent workers. In prior years, safety metrics were reported for employees, contingent workers and subcontractors combined. Comparative numbers cannot be reliably split" (page 86).

Partial phase-in. Fugro applies a phase-in for "S1-14 The data points on cases of work-related ill health" (page 86).

Compensation metrics (pay gap and total compensation)

Reference: pages 73-75.

Gender pay gap (pages 74-75). "The calculation based on base salary only for all employees globally shows no gender pay gap, although pay gaps differ per country. The gender pay gap analysis based on total remuneration (fixed salaries as well as variable allowances such as bonus payment, LTI grant, time related offshore allowances and field allowances), on all employees showed a pay gap of 8.7% in favour of male employees (2024, for countries with more than 250 employees: 10%)."

Causes stated: "the relative underrepresentation of women in middle management and subject matter expert roles... Another cause is the relative underrepresentation of women in field or offshore functions, where allowances are paid to compensate the employee for inconveniences around field and offshore work." A fair pay analysis is run twice a year.

Remuneration ratio (page 73). "The annual total remuneration ratio of the highest paid individual to the median annual total remuneration amounts to 55 (2024: 58)." A second ratio on the Dutch Corporate Governance Code basis gives 12 (2024: 31).

The 2024 pay gap comparative is drawn from a narrower population (countries with more than 250 employees), so the two years are not directly comparable.

Incidents, complaints and severe human rights impacts

Reference: page 83 (page 100).

"In 2025, Fugro received 64 reports through its Speak Up procedure relating to potential breaches of the Code of Conduct or underlying policies. These reports covered a range of topics, including (perceived) discrimination or harassment, conflicts of interest, safety-related issues and broader employee relations matters."

Speak Up reports (2025 / 2024): investigated and (partially) substantiated 24 / 20; investigated and unsubstantiated 11 / 16; undetermined 0 / 6; not investigated 25 / N/A; in review 4 / 2; total 64 / 44.

Outcomes. "As of the end of 2025, 4 cases remained under review or investigation. No cases resulted in fines, monetary penalties or compensation payments."

Severe human rights impacts. "Based on the matters reported and assessed in 2025, Fugro did not identify any severe human rights impacts... No complaints were submitted to National Contact Points under the OECD Guidelines for Multinational Enterprises during the reporting period."

"Approximately 42% of Speak Up reports were submitted anonymously", so the 64 reports are not split between own workforce and other stakeholders.

Policies related to value chain workers

Reference: page 77.

Three policies are named:

• The Supplier and Partner Code of Business Principles "builds on the Code of Conduct by providing specific guidance to suppliers and partners, including health, safety, security and environment, labour practices and human rights, and anti-bribery and corruption."
• The Policy on Human Rights "sets out leading human rights principles based on the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, including freely chosen employment (i.e. no forced labour), no child labour, diversity and non-discrimination, no harassment, freedom of association and collective bargaining, fair working hours, fair wages, protection of health and safety, respect for local communities, and adequate grievance procedures."
• The Supplier Due Diligence policy "is aligned with key internationally recognised standards, namely UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and OECD Guidelines for Multinational Enterprises."

Accountability. Implementation runs "through the Procurement function, under responsibility of the Global Director Operational Excellence. Global Compliance manages the framework and escalation process for risks associated with bribery, human rights, and sanctions."

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

Reference: pages 77, 83 (page 100).

"Fugro's Speak Up procedure is open to value chain workers to raise concerns about human rights violations and thereby provides an accessible grievance mechanism" (page 77).

The channel (page 83) is "available to employees, contingent workers, suppliers, customers, value chain workers, and community members" and is "accessible via multiple channels, including an independent external reporting line available 24/7 in more than 50 languages, with the option to report anonymously", with "strict non-retaliation and confidentiality protections" and a process "aligned with the European Whistleblower Protection Directive".

Stated limitation (page 83): "Awareness and accessibility of the Speak Up procedure among value chain workers and community members have not been formally assessed." No separate count of value chain worker reports is given within the 64 received in 2025.

Supplier-side remediation: where "insufficient ESG management practices are uncovered, Fugro may choose to continue the business relationship and work with the supplier on an improvement plan, with periodic follow up assessments. As a last resort, Fugro may choose not to contract a new supplier or terminate an existing business relationship" (page 78).

Taking action on material impacts on value chain workers

Reference: pages 78-79.

Sanction screening (page 78). "In 2025, one subcontractor was flagged due to a past civil settlement for alleged fraudulent billing practices, leading to termination of future engagement. No other sanctions-related issues were identified in relation to suppliers during the reporting period."

Higher-risk categories (page 78). Third-party vessel owners - "Fugro uses BIMCO charter agreements, which include requirements for HSSE management for crew safety and compliance with the Maritime Labour Convention of the ILO". Vessel crew agencies - "Fugro conducts annual audits of crew agencies to ensure compliance with labour rights".

2025 progress (page 79). Rollout completed in Norway and ongoing in "the US, Germany, Saudi Arabia, the UAE, and the UK". "In total, 616 questionnaires have been sent out in 2025... The overall response rate was 46%." "the inherent ESG risk profiles of more than 5,500 suppliers globally were screened... This initial screening confirmed that health and safety of workers in Fugro's supply chain is a priority topic." Assessment of "a key fuel supplier... revealed critical gaps in environmental management and supply chain due diligence", triggering "a collaborative improvement plan".

Fugro notes it "applies the transitional provision for value chain information" (page 78).

Business conduct policies and corporate culture

Reference: pages 81-82.

"As a signatory to the United Nations Global Compact and a supporter of the OECD Guidelines for Multinational Enterprises, Fugro actively contributes to global efforts on sustainability, human rights, and anti-corruption."

Code of Conduct. It "addresses topics such as bribery and corruption, conflict of interest, principles of fair competition, responsible taxation, sanctions & export control, data protection, human rights, and equal opportunity... Executive responsibility for the implementation of these policies lies with the General Counsel. Accountability for implementation of the Code of Conduct and related policies lies with the Board of Management."

Governance of the compliance function. "The General Counsel is a member of Fugro's Executive Leadership Team... The General Counsel chairs the Corporate Integrity Committee (CIC), which oversees all reported incidents of misconduct... The CIC meets every four to six weeks... investigations are conducted outside the direct management chain of the individuals involved."

Culture and training (page 82). All new employees and contingent workers complete Code of Conduct e-learning covering workplace conduct, business integrity, regulatory compliance and raising concerns. "In 2025, Fugro achieved a 98% completion rate" against a 100% target (2024: 94%).

Management of relationships with suppliers

Reference: pages 78-79 (page 100).

Standard due diligence (page 78). "Fugro's standard supplier due diligence process includes a detailed self-assessment questionnaire that covers their approach to health and safety, labour practices, environmental protection, and anti-corruption measures, and the contractual obligation to adhere to Fugro's Supplier and Partner Code of Business Principles."

Risk-based programme (page 78). "Suppliers are categorised based on the inherent ESG risk profile related to their country of operation and industry which dictates the required level of scrutiny. High-risk suppliers undergo more intensive review, while lower-risk suppliers receive standard monitoring... In addition, adverse media is screened."

ESG criteria in sourcing (page 79). "Category managers have started actively using ESG risk assessment tools in their vendor selection processes, embedding ESG risk factors as a key criterion for critical suppliers, such as new fuel providers and shipyards", and "all new vendors, regardless of size or risk level, will be required to complete a basic ESG questionnaire covering health and safety, as well as carbon footprint."

Systems (page 79). "From 2026, Fugro entities utilising the main ERP system will transition to the new supplier management process", with a manual interim process elsewhere.

Prevention and detection of corruption and bribery

Reference: page 82.

"Fugro maintains a zero-tolerance approach to bribery and corruption. All employees, including the Executive Leadership Team, and the members of the Supervisory Board, are considered at-risk functions and must complete the mandatory anti-bribery training. In high-risk jurisdictions, Fugro proactively mitigates exposure, particularly in government and port interactions, for example, by transitioning to a single global port agent. Contracts are structured with robust anti-bribery clauses."

Investigation independence (page 81). The Corporate Integrity Committee, chaired by the General Counsel, "oversees all reported incidents of misconduct, including corruption and bribery... investigations are conducted outside the direct management chain of the individuals involved."

Compliance monitoring (page 82). "Fugro requires annual compliance declarations from key employees globally. In 2025, 97% of key employee submitted their declarations... The internal audit department... conducts regular audits and reviews."

Third parties. "At the end of 2025, Fugro had 22 active joint ventures and partnerships", and "Fugro engaged 5 commercial agents... Agent contracts include compliance obligations, audit rights and annual certification requirements."

The percentage of at-risk functions covered by anti-corruption training is not reported separately.

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 Targets became a standalone DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS, whose G1-3 is "Prevention and detection of corruption and bribery".

A stated target exists. The Business conduct IRO table carries one KPI with a target: "Code of conduct training coverage (in %): 98 in 2025, 94 in 2024, target 100%" (page 81). "In 2025, Fugro achieved a 98% completion rate for mandatory Code of Conduct training modules" (page 82).

Effectiveness tracking in the absence of further targets, MDR-T's second limb, is also disclosed:

• "Fugro requires annual compliance declarations from key employees globally. In 2025, 97% of key employee submitted their declarations... The internal audit department... conducts regular audits and reviews to monitor compliance" (page 82).
• Speak Up outcomes are tracked year on year: 64 reports in 2025 against 44 in 2024 (page 83).

"Targets have been developed by internal experts and are approved by the Board of Management. External stakeholders have not been involved in target setting" (page 48). No target is set for corruption incidents, supplier ESG coverage or payment days.

Incidents of corruption or bribery

Reference: page 83.

"In 2025, there were no convictions or legal cases for violations of anti-corruption and anti-bribery laws, therefore no fines resulted from violations. Additionally, there were no incidents or violations of our anti-corruption policy that resulted in the termination or non-renewal of contracts. No further measures were deemed necessary due to breaches in procedures and standards related to anti-corruption and anti-bribery" (page 83).

That is a complete nil return against the three G1-4 limbs: convictions and fines, contract terminations or non-renewals, and actions taken to address breaches.

Context: 64 Speak Up reports were received in 2025 covering "(perceived) discrimination or harassment, conflicts of interest, safety-related issues and broader employee relations matters", of which 24 were investigated and (partially) substantiated and 4 remained under review at year end; "No cases resulted in fines, monetary penalties or compensation payments" (page 83). Separately, "In 2025, one subcontractor was flagged due to a past civil settlement for alleged fraudulent billing practices, leading to termination of future engagement" - a sanctions and integrity screening outcome rather than a corruption incident at Fugro (page 78).

The 64 reports are not broken down by category, so the number relating specifically to bribery or corruption is not disclosed.

Political influence and lobbying activities

Reference: pages 84-85.

"In accordance with Fugro's Code of Conduct, Fugro has not made any financial or in-kind political contributions. Fugro's limited lobbying activities are aligned with its purpose and client solutions in support of the energy transition, infrastructure investments and climate change adaptation, and are overseen by the CEO and General Counsel" (page 84).

Quantified spend (page 84). "In the US, Fugro hired professional lobby advice... Federally, EUR 90,000 was spent on advocacy (2024: EUR 188,000), primarily focused on legislation and policies pertaining to energy development, energy permitting, and mapping... Additionally, EUR 47,000 was spent on advocacy in the state of Florida (2024: EUR 0), primarily related to coastal resilience and mapping."

Main engagements in 2025. Feedback to the European Commission "on the EU Monitoring, Reporting and Verification (MRV) regulation of ships' emissions", followed by an invitation to a Commission workstream on MRV and ETS guidelines for offshore vessels.

Memberships (page 85). Board positions include "the Maritime & Offshore NL (Mark Heine, Fugro's CEO, serves as chairman), National Offshore Industries Association USA (NOIA) and International Marine Contractors Association (IMCA)".

Payment practices

Reference: page 84.

"During 2025, Fugro settled its invoices on average within 57 days (2024: 54 days), calculated on invoice count from the date when the contractual or statutory term of payment starts to be calculated" (page 84).

"The standard payment term for companies and governmental organisations is 60 days unless other arrangements are specified in the contract" (page 84).

"Fugro recognises small and medium enterprises (SMEs), identified according to EU and local legal definitions, as a specific supplier category. Fugro's policy is to pay invoices from SMEs and self-employed professionals in accordance with local legal requirements. On average, Fugro settled invoices from SMEs in 56 days in 2025."

"Per 31 December 2025, no legal proceedings were outstanding for late payments."

The Supplier payment policy is listed as one of the policies in place for the material topic Business ethics & compliance in the G1 IRO table (page 81).

Fugro does not disclose the percentage of payments aligned with standard terms, nor a breakdown of standard terms by main supplier category beyond the single 60-day figure and the SME position.