Gestamp Automocion

The role of the administrative, management and supervisory bodies

Composition

Gestamp's Board of Directors consists of 12 members:

• 1 executive director
• 3 proprietary directors
• 7 independent directors (58% of total)
• 1 external director

All 11 non-executive directors are independent of management. The Board comprises 4 female members and 8 male members (33% female representation).

Board Members:

There is no workforce representation on the Board of Directors.

Board Committees with Sustainability Oversight

Sustainability Committee

Composition: 4 members (1 proprietary director, 3 independent directors - 75% independent)

Functions:

• Proposing the Strategic ESG Plan to the Board of Directors and monitoring the degree to which its targets are being met
• Periodically assessing and reviewing the corporate governance system and the Group's environmental and social policies
• Monitoring the Group's environmental, social and corporate governance practices to ensure alignment with established strategy and policy
• Overseeing and evaluating stakeholder relationship processes regarding environmental, social and corporate governance matters

Meetings: In 2024, the Sustainability Committee met on 8 occasions with 100% attendance.

Audit Committee

Composition: 3 members (1 proprietary director, 2 independent directors - 66.66% independent)

Functions related to sustainability:

• Supervise and evaluate the process of preparing, the integrity and the presentation of financial and non-financial information
• Periodically review the internal control and risk management systems for financial and non-financial risks, including tax risks
• In respect of risk control and management, submit the risk control and management policy to the Board of Directors, identifying and determining types of financial and non-financial risks (operational, technological, legal, social, environmental, political and reputational risks, including risks of corruption)
• Oversees compliance with the Group's corporate governance rules and internal codes of conduct
• Supervises compliance with the Code of Conduct, the operation of the Group's reporting channel and the Criminal Risk Prevention Model

Meetings: In 2024, the Audit Committee met on 9 occasions with 100% attendance.

Nomination and Compensation Committee

Composition: 3 members (1 external director, 2 independent directors - 66.66% independent)

Functions related to sustainability:

• Formulating the Board of Directors' Selection and Diversity Policy and ensuring board diversity in expertise and experience, including sustainability
• Formulating and submitting Board of Directors' training plans for approval, ensuring they include sessions relating specifically to matters of sustainability
• Preparing the Remuneration Policy applicable to board members and senior managers, covering annual performance-related pay tied to matters of sustainability

Meetings: In 2024, the Nomination and Compensation Committee met on 5 occasions with 100% attendance.

Sustainability-related expertise

According to the Board competency matrix, 6 directors have experience in ESG matters:

• Ms Chisato Eiki
• Ms Loreto Ordóñez Solís
• Ms Marieta del Rivero Bermejo
• Mr Gonzalo Urquijo Fernández de Araoz
• Mr Javier Rodríguez Pellitero
• Mr César Cernuda Rego

5 directors have experience in risk management:

• Mr Francisco José Riberas Mera
• Mr Alberto Rodríguez Fraile Díaz
• Mr Pedro Sainz de Baranda
• Mr Gonzalo Urquijo Fernández de Araoz
• Ms Ana García Fau

Director César Cernuda Rego has experience in cybersecurity.

11 of 12 members have experience working in various geographical locations where the Gestamp Group operates.

Board training

As part of the Board of Directors' annual training plan, at least one session relating specifically to different matters of sustainability is normally scheduled. During the 2024 reporting period, the Board's training plan included a session on taxonomy and ESG ratings.

The 2024 training programme for Board members was aligned with the company's strategic objectives and structured around ESG, Artificial Intelligence, Industry 4.0 and the Innovation and Development strategy. It consisted of 5 online sessions with e-learning content accessible through the Gestamp Global Learning online campus.

Frequency of sustainability discussions

The Sustainability Committee meets at least 8 times per year. In 2024, all 8 Sustainability Committee meetings reviewed the status of the targets set out in the 2025 ESG Plan, outlined the degree to which they are being met, and determined the measures or action plans required to ensure targets will be met.

The Executive Chair, with the assistance and support of the Sustainability Committee members, has briefed every Board of Directors' meeting on the status of the 2025 ESG Plan, presented the company's major improvements in the field of sustainability, and reported noteworthy events from the previous quarters.

The Board of Directors met on 9 occasions in 2024 with 97.32% attendance.

Specific roles assigned

ESG Committee

The Group's key managing directors sit on the ESG Committee, chaired by the Board of Directors' Executive Chair. The ESG Committee is charged with integrating and overseeing sustainability initiatives across the organisation.

Responsibilities:

• Setting out the ESG Strategy
• Monitoring and launching ESG initiatives
• Embedding sustainability into decision-making processes
• ESG risk assessment and management
• Formulating ESG policies and procedures
• Measuring and monitoring ESG performance
• Transparency and communication
• Regulatory compliance and adherence to standards

The ESG Committee, led by the Executive Chairman and with representation from senior management, meets at least twice a year. 2 meetings were held in 2024.

ESG Department

The ESG Department is headed by the Chief Sustainability Officer. It coordinates with all production departments and plants to identify the Gestamp Group's material impacts, risks and opportunities.

Executive Risk Committee

The Executive Risk Committee supports the Board of Directors and Audit Committee in risk control and management functions. It is formed by the Group's Executive Chair and the Managing Director, plus a maximum of four other Management Committee members.

Internal Audit and Risk Management Department

Operates under direct supervision of the Audit Committee with responsibilities including:

• Ensuring risk control and management systems function correctly
• Active contribution to preparation of risk strategy
• Ensuring risk control and management systems mitigate risks effectively
• Coordinating processes for identification and assessment of risks
• Consolidating risk information and preparing risk reports for the Audit Committee

Ethics Committee

A collegiate body with initiative and control powers, supervised by the Audit Committee. Activities include:

• Promoting a culture of ethics and compliance
• Supporting the Audit Committee in duties related to the Compliance System, Code of Conduct and Complaints Channel
• Promoting dissemination and knowledge of the Code of Conduct
• Investigating complaints submitted through the Internal Communications Channel
• Reporting regularly to the Audit Committee on Code of Conduct compliance

Compliance Office

Works alongside the Ethics Committee and Regulatory Compliance Unit to support the Board of Directors and Audit Committee in overseeing the Code of Conduct, Complaints Channel and internal control programmes.

Functions and responsibilities

The Board of Directors is the highest governing body responsible for:

• Approving and monitoring the Group's standard policies and strategies, including:
  • Strategic or business plan, management objectives and annual budgets
  • Defining the Company and group structure
  • Sustainability policies based on Sustainability Committee proposals
  • Policy on control and management of financial and non-financial risks, and acceptable risk level, based on Audit Committee proposals
  • Code of Conduct and related standard policies and the Compliance Model (including Criminal Risk Prevention Model)
  • Policy on remuneration of senior managers and directors, based on Nomination and Compensation Committee proposals
• Preparing and submitting information, including non-financial information, to the General Meeting of Shareholders
• Regularly monitoring internal reporting and control systems, including the Compliance Model, in conjunction with the Audit Committee
• Ensuring Committees function effectively and monitoring performance of Group managers assigned to committees

Independence and effectiveness arrangements

The Board of Directors has a competency matrix that identifies the knowledge, expertise and experience deemed most appropriate for the Board. The matrix is updated regularly in line with potential vacancies and new challenges faced by the Group.

The Nomination and Compensation Committee ensures the Board of Directors has access to sufficient knowledge, expertise and experience to identify, define and monitor the company's material impacts, risks and opportunities.

Board members may request the appointment of consultants or experts to perform their tasks, with costs charged to the Group.

The company has implemented an Integrated Risk Management System (IRMS) based on COSO ERM and ISO 31000 framework standards. The Board of Directors drives the risk management process through the Risk Management Policy.

In 2024, Risk Management and ESG Management updated the matrix that cross-references Gestamp's risks with areas of the ESG Strategic Plan, ensuring the Risk Map is aligned with the company's ESG strategy and understanding how each ESG Plan area contributes to mitigating risks.

A process has been launched to align and add the risks identified in the Group's double materiality assessment to the corporate Risk Map, ensuring required control measures are in place.

Integration of sustainability-related performance in incentive schemes

Coverage and Structure

The degree to which every employee has met their individual goals set at the start of the year by their manager will be reflected in a percentage of the employee's annual variable remuneration.

Short-Term Incentive (STI) Structure

Annual variable remuneration consists of the following elements and relative weightings:

• Financial goals: 50% weighting
• Strategic goals: 25% weighting, including:
  • Goals of the 2023-2025 Strategic ESG Plan: 12.5% weighting
  • These include the 3 climate objectives. Each objective of the plan has the same weight.
• Individual goals: 25% weighting

Governance and Approval Process

The Nomination and Compensation Committee assesses the achievement of goals to determine the variable amounts to be paid to Board Members with executive duties. Once the amount is determined, it is approved by the Board of Directors.

As both the annual variable remuneration and the pluriannual variable remuneration are variable remuneration systems linked to the achievement of quantifiable financial and economic goals that are included in the Group's Consolidated Financial Statements, their consolidation and payment is deferred until the external audit and approval thereof by the General Shareholders' Meeting.

Directors' Remuneration

The Remuneration Policy for the Group's Board Members, approved at the General Shareholders' Meeting held on 9 May 2023, includes the following principle:

Performance: Performance includes a variable component tied to the achievement of specific targets in line with the Group's strategic goals and the creation of value to ensure that the directors' interests are aligned with those of the Group.

Directors' Remuneration Table (thousands of euros)

Strategy, business model and value chain

Description of products/services and key markets

Gestamp's activity falls within the NACE Rev. 2 code 29.32, corresponding to the "Manufacture of other parts and accessories for motor vehicles". The company's primary economic activities - specifically, the design, development and manufacture of innovative metal components for the automotive sector, including technological solutions that improve vehicle safety and efficiency - are qualified under this code.

Gestamp stands out for designing, validating, industrializing and producing a wide variety of automotive components. The majority of them are structural elements in the vehicle which, in the event of a crash, are designed to crumple by converting the maximum amount of kinetic energy into controlled deformation. Similarly, Gestamp designs and manufactures other parts, seeking to achieve sufficient rigidity in order to reduce the level of torsion under stress. This added rigidity also helps to improve the vehicle's dynamic performance. Furthermore, comfort and durability are other important aspects taken into account during product development.

Significant groups of products/services

The products developed by Gestamp can be divided into three broad groups:

1. Body-in-White (BIW) - structural components
2. Chassis - chassis components
3. Mechanisms - mechanism components

Note: The company does not disclose revenue share by product group in the excerpts provided.

Significant markets / geographies

According to IFRS 8 – "Operating Segments", the company operates in the following significant geographical segments:

Segment revenue (thousands of euros) - 2024:

Number of employees by geography

The excerpts reference "more than 43,000 people" and show workforce profile graphics, but do not provide a detailed table of employee numbers by geography in the SBM-1 section. Detailed employee information appears in the S1 section which is outside this disclosure requirement.

Total revenue by significant ESRS sustainability matter

Not disclosed in the SBM-1 section.

Sustainability-related goals embedded in the business model

Gestamp's strategy is based on three key aspects: being an innovative, competitive and sustainable company.

• It aims to strengthen its position as an innovative supplier and move forward together with its customers, by offering them innovative solutions to build more sustainable transport.
• Gestamp prioritises competitiveness based on operational excellence and the extensive use of the latest technology in the area of Industry 4.0 and digitalisation.
• The company is making progress in terms of sustainability in line with the current demands of society.

2025 ESG Plan:

In 2023 Gestamp published its ESG Plan for 2025, which addresses in greater detail the company's strategic ESG priorities. It is made up of eight strategic areas for which quantitative objectives and initiatives have been set for 2025 and which affect all divisions of the company across all regions in which it operates:

1. Climate change
2. Circular economy
3. Environmental targets
4. Responsible supply chain
5. Diversity and equality
6. Health and safety
7. Social action
8. Ethics and transparency

Every area and objective of the plan has been designed to minimise the negative impacts/maximise the positive impacts of the company in these respects, reduce the probability that the risks will occur, and take advantage of any corresponding opportunities.

Product sustainability focus:

Gestamp continuously endeavours to develop lighter vehicles and prioritises weight reduction research. This is one of the most demanded requirements in the automotive industry due to the need to improve fuel efficiency and reduce CO2 emissions. Chassis and bodywork components are essential for achieving emissions targets, as they make up around 70% of total vehicle weight.

As part of the industry's move towards electrification, the extra weight in vehicles from batteries has further increased the importance of lightweighting. Weight affects the range of electric vehicles, and until full decarbonisation of the electricity grid takes place, its consumption will continue to play an important role in the CO2 emissions of vehicles during the use phase.

Gestamp provides innovative solutions to offer the best weight reduction results and meet the most stringent industry requirements. Extensive experience in hot stamping technology and the development of multi-material solutions have given rise to several alternatives for achieving lighter vehicles.

Product life cycle analysis (LCA) is carried out as a strategic part of the design phase. The carbon footprint of each process carried out at Gestamp and the materials used in production are some of the main variables included in the analysis. It has been found that lightweighting and using a smaller amount of raw materials are two of the factors with the biggest influence on reducing the carbon footprint.

Gestamp also works hard on developing increasingly safer vehicles, focusing on identifying formulas that ensure greater safety for both passengers and pedestrians. Gestamp is a pioneer in the manufacture of products by hot stamping, one of the most advanced technologies used to improve performance and passenger safety in the event of a collision.

Description of upstream and downstream value chain

Value chain structure:

Gestamp's value chain comprises:

• Upstream operations: As the supply chains of the automotive sector become more complex, robust internal systems and procedures are needed to correctly manage suppliers of raw materials (steel, aluminium, etc.), services or other products, without which the company would not be able to undertake its activities.

• Own activity: As Gestamp uses advanced engineering techniques to design, develop and manufacture components for the automotive industry, it is a leading supplier of components in the automotive sector.

• Clients (OEMs): The Group aims to become a trusted partner of its clients by satisfying their needs, placing them at the centre of the business, accompanying them into new markets and offering them innovative solutions to tackle the many different challenges of the automotive industry.

Upstream value chain (suppliers):

The manufacture of Gestamp parts requires the use of raw materials (steel, non-ferrous metals) and auxiliary materials (wire, welding gases, oils, etc.). Efficiency in processes, quality, product and tool design are fundamental in order to optimise and reduce raw material consumption.

Gescrap, a recently incorporated group specialising in metal recycling and the comprehensive management of waste in the industry, and the European leader in the management of high-quality scrap metal, is a key player in the development of its activity. Gestamp seeks to develop the circularity of its business model, promoting the use of its scrap as a secondary raw material in the production of low-emission steel, reducing the extraction of raw materials for the production of steel and aluminium and promoting the optimisation of waste management.

Downstream value chain (customers):

Gestamp's products are sold to the final manufacturer (OEMs), which then assembles and sells the vehicles to end users.

Key inputs and outputs

Key inputs:

• Raw materials: steel, aluminium, non-ferrous metals
• Auxiliary materials: wire, welding gases, oils
• Energy: electricity (63% of energy consumption), natural gas (32%), other fuels (5%)
• Water: predominantly for sanitary purposes, with industrial use in plants with surface treatment processes (painting, galvanising), hydroforming processes, or hot stamping

Key outputs:

• Automotive components across three product groups: Body-in-White, Chassis, and Mechanisms
• Technology solutions including hot stamping, cold stamping, high-strength steel stamping, rollforming, hydroforming, welding and assembly, laser welded blanks, laser welding, and Multistep technology

Technologies employed:

Gestamp is a global leader in technology and features a broad range of technology to provide customers with innovative solutions. Specifically, Gestamp is a leader in hot stamping, a technology that makes it possible to manufacture safer, lighter parts. This lightens the total weight of the vehicle, thus reducing energy consumption and, in turn, CO2 emissions.

Technologies include:

• Multistep
• Hot stamping
• Cold stamping
• High-strength steel stamping
• Rollforming
• Hydroforming
• Welding and assembly
• Laser welded blanks
• Laser welding

Flex Manufacturing:

Gestamp's Technology and Innovation Office has developed a new concept of 'flex manufacturing', taking digitalised manufacturing to another level. This new concept of manufacturing ensures maximum efficiency. Its principles govern the way in which manufacturing plants are organised, creating a state-of-the-art, flexible industrial space that gets the maximum potential out of all systems and equipment, without neglecting quality and safety. The advantage of this model is the ability to manufacture different products using the same production resources.

Interests and views of stakeholders

Gestamp aims to create long-term value for its stakeholders by focusing on the way it interacts with society and the environment, seeking to create bonds and prioritising the development of direct lines of dialogue and communication to promote a cooperative space in which it is possible to express concerns.

Identified stakeholder groups and engagement channels

Note: Gestamp can gain an idea of end-users' perspectives through its clients.

In addition to these specific channels, Gestamp also has its own company website: www.gestamp.com

Stakeholder participation in double materiality assessment

As part of the double materiality assessment, Gestamp has involved its key stakeholders (own workforce, workers in the value chain, etc.) in the process of evaluating IROs. To this end, it has employed various methods such as surveys, market research, trend reports, ratings analysis, analysts, etc. Consequently, each of the group's stakeholders has provided explicit feedback which is used in the context of the double materiality assessment. For further information about the double materiality methodology, see disclosure requirement IRO–1.

Integration of stakeholder views into strategy

The consultation methods have not highlighted any aspect that requires an urgent alteration to the company's sustainability strategy. Yet, Gestamp reviews its double materiality assessment on an annual basis to make sure that its strategy is in line with its most recent results. Since 2025 is the final year of the 2023 - 2025 ESG Plan, a more in-depth review of the sustainability strategy will be conducted in 2025.

The ESG strategy, which is woven into the fabric of the company's business strategy, sets out targets and commitments whose purpose is to protect the rights of the Group's employees, workers in the value chain and local communities.

Chapters GOV-1 and GOV-2 outline in detail the process of informing administrative bodies of sustainability matters, including aspects of the double materiality assessment which takes into consideration the opinions and concerns of stakeholders.

Throughout the Sustainability Statement, more in-depth and specific information is provided about reporting channels and results.

ESG ratings as stakeholder communication

ESG ratings allow Gestamp to understand the demands and needs of its stakeholders, specifically investors, being a method of two-way communication as detailed in SBM-2 and subsequent chapters.

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

Phase-in provision

Gestamp has made use of the transitional provisions in accordance with Appendix C of ESRS 1 for ESRS 2 SBM-3 (Material impacts, risks and opportunities and their interaction with strategy and business model).

General approach

In 2023, Gestamp's double materiality assessment related exclusively to the company's own activities. As the 2024 double materiality assessment includes information about the Group's value chain, covering both upstream and downstream operations, the analysis has been updated and a broader set of results has been obtained. As such, since regulatory compliance practices have been undertaken for the first time in this reporting period, Gestamp does not identify any changes in respect of previous periods.

Gestamp's double material assessment is based on the climate scenarios set out under ESRS 1 (short term refers to the financial statement reporting period; medium term refers to a period of up to five years from the end of the short-term period; and long term refers to a period of more than 5 years from the end of the short-term period) except in the case of climate risks for which it uses the following time horizons:

• Short term: present day to 2030
• Medium term: 2030 to 2050
• Long term: 2050 to 2100

This, beyond climate actions and targets, responds to the temporality of expected physical and transition climate impacts according to the selected climate scenarios from the IPCC (Intergovernmental Panel on Climate Change) and the IEA (International Energy Agency). It is the company's view that the medium- and long-term time horizons should be close enough for scenarios to be plausible, but distant enough for significant and potentially business-impacting changes to take place between the scenarios and the present. These time horizons have also been selected by the company in view of investment horizons and the useful life of assets.

Material impacts, risks and opportunities identified

The appendix titled "Material impacts, risks and opportunities identified during the reporting period" identifies the material IROs identified and assessed in 2024. This section describes the way in which people or the environment are impacted. The "Value Chain" column indicates the value chain segment in which the particular IRO (trade relations) is identified or is due to the company's "own activities". All IROs are related to the development of the company's strategy and business model with the exception of those that relate specifically to "Social Action". On the other hand, the reasonably foreseeable time horizons of potential impacts are included (the current ones are deemed to be taking place now) as well as short-, medium- and long-term financial effects.

Material IROs are identified across the following ESRS topics:

• Climate Change (E1)
• Pollution (E2)
• Water and marine resources (E3)
• Biodiversity and ecosystems (E4)
• Resource use and circular economy (E5)
• Own workforce (S1)
• Workers in the value chain (S2)
• Affected communities (S3)
• Consumers and end users (S4)
• Business conduct (G1)

Interaction with strategy and business model

The results of the double materiality assessment, as well as the new requirements of sustainability directives, such as the Corporate Sustainability Due Diligence Directive (CSDDD), are being assessed and considered for the purpose of developing processes to manage impacts, risks and opportunities at every stage of the Group's value chain.

The specific actions to mitigate risks and achieve opportunities, aligned with the double materiality analysis and developed during 2024, are described in the different thematic chapters of the Sustainability Statement:

• E1: Climate Change
• E2: Pollution
• E3: Water and marine resources
• E4: Biodiversity and ecosystems
• E5: Resource use and circular economy
• S1: Own workforce
• S2: Workers in the value chain
• S3: Affected communities
• S4: Consumers and end-users
• G1: Business conduct

Results and performance

The results of the development of these actions, aligned with the sustainability strategy, are considerable. Thus, the perception of the different ESG ratings has continued to improve:

¹ The lower the score, the lower the risk, the better the result. ² This evaluation refers to the climate change questionnaire. Regarding water, Gestamp has obtained an A-.

Furthermore, these ratings allow us to understand the demands and needs of our stakeholders, specifically investors, being a method of two-way communication.

Specific considerations by topic

E1 Climate Change

The Gestamp Group has conducted an exhaustive assessment of identified climate risks and explains how they are managed, while detailing the resilience of its strategy and business model to the effects of climate change.

The company classifies identified risks into two primary categories: physical risks and transition risks. Identified material risks are classified in "E1".

Gestamp's macroeconomic trends, considered in the context of the transition towards a low-carbon economy, will be affected by the sustainable preferences of consumers and climate regulations. The company believes that it needs to adapt its processes and to use sustainable materials, such as green steel, as it adapts to the reality of these changes.

The climate risk analysis conducted by the company in 2023 took account of the IPCC's SSP2-4.5 climate scenario for climate-related risks and the net-zero scenario for climate-related transition risks and opportunities.

In 2024, a climate stress analysis was carried out to evaluate the resilience of the Group's activity against climate change based on the IPCC (Intergovernmental Panel on Climate Change) SSP5-8.5 and IEA (International Energy Agency) NZE scenarios for its entire value chain. In this reporting period, it employed advanced regional climate models to assess the company's vulnerability to a range of climate risks.

As shown by these assessment exercises, the effects related to temperature and water are expected to rise in frequency and intensity and will impact both internal operations and upstream and downstream operations of the value chain. The financial effects and costs of implementing the adaptation plan will determine the degree to which the company is able to rise to these challenges (resilience).

Gestamp is therefore striving to determine the potential financial effects of climate change and to estimate the costs of implementing its adaptation plan. On this basis, it is assessing the monetary amounts, the proportion of affected companies and, therefore, the provisions required to implement adaptation and mitigation measures.

As part of its resilience analysis, no physical or transition risks are being excluded, to the extent that they have a material effect on its activities and value chain. Steps are being taken to cover all relevant aspects that may affect its strategy and decision-making processes, at every stage in its value chain.

Finally, the company will evaluate its capacity to adjust its strategy and business model in order to guarantee short-, medium- and long-term resilience. That includes improving assets, adjusting the product and service offer and organising staff training initiatives. Gestamp is also considering maintaining access to financing at an affordable cost of capital.

E4 Biodiversity and Ecosystems

Analysed in the context of Gestamp's double materiality assessment, the sites are located in urban and industrial areas, some of which lie in close proximity to biodiversity-sensitive areas. In 2024, a geolocation analysis was conducted to determine the proximity of infrastructure to protected areas, in view of the network of protected areas set out in Natura 2000, IUCN, Emerald Network and USA Wetlands.

The research confirmed that 58% of the Group's plants are located near (< 5 km) or adjacent to protected areas. Despite the proximity, and in light of the nature of Gestamp's production processes, there was no material impact on biodiversity or on the status and extent (including land use) of ecosystems located in areas where the Group is active.

In addition, a biodiversity study detected the presence of endangered species in areas close to three of the Group's plants. However, Gestamp's production processes were found to have no material impact on those species.

S1 Own Workforce

Social impacts, risks and opportunities (i.e., those related to own workforce, workers in Gestamp's value chain, affected communities and consumers or end-users) are identified due to the company's business model and its value chain, on the one hand, and the way in which it manages them, on the other. Gestamp's ESG strategy therefore seeks to maximise positive impacts, minimise negative impacts and ensure that risks and opportunities are managed in line with the needs of its employees.

Gestamp classifies its workforce into the following major employment categories: direct workforce, indirect workforce and structural workforce. As part of these employment categories, it also distinguishes between internal and external employees. They are all factored into the double materiality assessment. On this basis, the category of Gestamp's employees most exposed to occupational risks is the direct workforce, as they operate in close proximity to heavy machinery. However, Gestamp's health and safety system is designed to prevent material impacts in this respect.

Therefore, some of the risks described in the annex "Impacts, risks and opportunities of relative importance identified during the year" related to own personnel are closely related to potential impacts that the company could have on its employees (PPR5, PPR6, PPR7, PPR8, PPR9, PPR10).

In the case of impacts:

• Positive: Gestamp is committed to the protection and advancement of its employees and is acutely aware of the major role they play in the development of its business. It has therefore devised training programmes and health and safety courses, and promotes diversity, equality and inclusion throughout the company. This approach clearly has a positive impact which is recognised not only by the company, but also by its employees.
• Negative: In 2024, Gestamp has not identified any material negative impact on its own workforce.

The Group's own workforce has not been affected by any material negative impacts arising from transition plans to reduce negative environmental impacts, or operations involving a material risk in the event of forced or child labour.

S2 Workers in the Value Chain

In terms of the workers in the value chain who may be affected by the positive impact identified by Gestamp's business relations, the impact is not linked to any specific typology or geographical location. The impact in question derives from the management of Gestamp's suppliers in line with the ESG Policy.

S3 Affected Communities

The impacts, risks and opportunities related to affected communities are distinguishable by the section of the value chain from which they originate, although differences between the type of communities exposed to such IROs are not discernible:

• Own activity: Social action is an integral part of Gestamp's ESG strategy. As such, on account of the Gestamp Foundation and the initiatives it pursues, Gestamp can make a considerable positive impact on society and on the communities of areas in which it is active. Moreover, as Gestamp employs such a large workforce, the Group is the beating heart of the economy of many areas in which it is active. The potential impact that the Group's interaction and employee management may have on communities should therefore be taken into consideration (CAF1, CAF2, CAF4 and CAF5).
• Upstream operations of the value chain: Since Gestamp works alongside a large number of suppliers, certain risks may emerge if a dispute arises between a supplier and the communities of areas in which the supplier is active (CAF3).

S4 Consumers and End-Users

Regarding the material IROs related to consumers or end users of the products developed by Gestamp, all are subject to the identified positive impacts (no negative ones have been detected), regardless of typology, as the manufactured parts are integrated into OEM vehicles that are sold indiscriminately to users. It is in the use of the vehicle where the identified impacts appear. These also derive from the high investment that the Group makes in R&D and from being considered a benchmark in terms of safety and quality of its parts.

As for identified risks and opportunities related to consumers and end-users, they give rise to potential impacts. However, in the case of risks, the impact on which they depend is not considered to be material in 2024. Given the type of business activities undertaken by the company in the automotive sector, particular risks or opportunities are generated by its activity, as in the case of those identified for consumers and end-users.

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

Overall Methodology

In 2024, Gestamp has conducted a double materiality assessment on the basis of the Corporate Sustainability Reporting Directive (CSRD) and the reporting standards (ESRS) developed by EFRAG.

The primary aim of this analysis is to identify and assess the main positive and negative environmental and social impacts of the company's activities (impact materiality) and the risks and opportunities that may arise for the company (financial materiality).

The Group identifies and assesses material impacts, risks and opportunities related to the following topics: Climate change, pollution, water and marine resources, biodiversity and ecosystems, resource use and circular economy, own workforce, workers in the value chain, affected communities, users and end customers and business conduct.

By analysing different sources of information, it has identified and conducted a qualitative and quantitative analysis of the Group's Impacts, Risks and Opportunities (IROs) at every stage of its value chain.

Double materiality analysis follows a methodology which identifies, on the one hand, the environmental and social impacts of the company's activities (inside-out perspective) and, on the other, the primary risks and opportunities arising for the company as a result of that interaction (outside-in perspective). On this basis, Gestamp is able to identify the aspects that it should prioritise and those that should serve to underpin its strategy and management model.

The double materiality assessment is conducted at group level and takes into consideration all the geographical locations in which the company and every link in the Group's value chain is active (sites). It also covers both its own activities and its upstream and downstream trade relations (value chain). Moreover, the sites at which material activities take place are analysed to identify the materiality of impacts, as and when it is deemed necessary to do so. This analysis has been outsourced to an external service provider specialising in sustainability matters, particularly with a view to maintaining objectivity.

Step-by-Step Methodology

The analysis has been conducted in 3 phases:

• Phase 1 - Context analysis and understanding of Gestamp's value chain.
• Phase 2 - Preliminary identification of impacts, risks and opportunities.
• Phase 3 - Assessment and weighting of material IROs.

Aware of the high degree of subjectivity that this analysis may entail, the Group has decided to outsource the task to an independent service provider specialising in sustainability matters in order to maintain a suitable level of objectivity.

Phase 1 - Context analysis and understanding of Gestamp's value chain

A context analysis has been conducted to identify and develop a clearer understanding of Gestamp's own activities and those of its value chain, based on internal and external sources:

Internal sources:

• Previous materiality analysis.
• Gestamp's previous annual reports.
• The Group's corporate risk map.
• Analysis of Climate Change Risks and Opportunities.
• Workshops with relevant departments and stakeholders of the value chain.
• Other disclosures identified as relevant according to site and topic (Appendix A of ESRS 1), if available.

External sources:

• Trend reports.
• Reports of sustainability thought leaders.
• Public information of competitors and clients.
• Sustainability requirements of clients (OEMs).
• Standards/recommendations: SASB, GRI, TCFD, WEF, EFRAG, etc.
• ESG Analysts: MSCI, S&P, Sustainalytics, Ecovadis, FTSE, etc.
• Regulations and recommendations of regulators: EU Taxonomy, Spanish National Securities Market Commission (CNMV), etc.

Phase 2 - Preliminary identification of impacts, risks and opportunities

On the basis of the sustainability topics, sub-topics and sub-sub-topics described in "Appendix A" of ESRS 1, and after developing a clear understanding of the context and every stage of the Group's value chain, all impacts, risks and opportunities to which the company may be exposed on account of its activities, business type, value chain and the various stakeholders involved in that chain, have been identified on a preliminary basis. This comprehensive insight has also made it possible to identify matters that are material for the company and not covered by standards currently in force, such as Social Action.

After identifying all the IROs to which the company may be exposed, meetings and workshops are held with the company's departments that interact with the various stakeholders of the group's value chain. This initial filtering step reduces the scope of the IRO assessment and prioritisation process.

Phase 3 - Assessing and prioritising impacts, risks and opportunities

The Group's key stakeholders have been involved in the assessment of IROs. Specifically, they have been consulted to determine the materiality of topics, sub-topics and sub-sub-topics. In addition, Gestamp's key departments have assessed IRO by IRO in an effort to correctly prioritise them. This approach has enabled the company not only to ascertain their views on the management of the various sustainability topics, but also to validate the different IROs identified for every topic.

Time Horizons

The assessment has covered short-, medium- and long-term horizons in accordance with the definitions of ESRS 1: less than 1 year, 1-5 years and more than 5 years, respectively. However, the company has seen fit to extend these scenarios in order to correctly assess climate risks, and therefore to follow the market's baseline scenarios:

• Short term: present day to 2030
• Medium term: 2030 to 2050
• Long term: 2050 to 2100

Scoring Criteria

The IRO assessment has always adhered to the guidelines set out by the various ESRS in force. Moreover, in respect of the assessment of risks and opportunities, that methodology has been aligned with the approach adopted by the risk department. The results can therefore be integrated into the corporate risk map.

These assessments are structured according to the following sections: scale, scope, probability and remediability.

As every variable is analysed separately, they can all be quantified:

Scale: Scale is the result of aggregating information from surveys distributed to various stakeholders, competitor analysis, client information (OEMs), ESG analysts, regulatory developments and any relevant information sourced from different stakeholders and departments of the company. The end result is therefore a composite variable.

[Note: The excerpts were cut off at this point, but this captures the key scoring criteria mentioned]

Thresholds for Materiality

In addition to what is described in the "IRO-1" chapter regarding the methodology used to develop the double materiality analysis, the thresholds that determine the limit from which an impact, risk or opportunity (IRO) is considered material have been defined through a comprehensive analysis and independently for financial materiality and impact materiality.

In the case of impact materiality, the thresholds were established based on the evaluation, aggregation and average of all identified impacts (quantitative assessment).

On the other hand, for financial materiality, these thresholds were determined considering all evaluated risks and opportunities.

Similarly, in order to introduce the qualitative variable in the stipulation of thresholds, an analysis is carried out of those IROs with a lower score that, despite this, should be considered as material given their relevance to the company, thus establishing a minimum required limit for this. Derived from this process and after obtaining a value, a weighting factor is applied that decreases the obtained value to the mentioned minimum value.

Once an impact, risk or opportunity (IRO) reaches the established threshold, either from the perspective of impact materiality or financial materiality, it is classified as material. Consequently, the topic, subtopic or sub-subtopic related to that IRO is also considered material.

Finally, the result of this analysis is contrasted with the corporate risk map to ensure that both results are aligned.

This approach ensures that the identification and evaluation of materiality is carried out rigorously and aligned with the criteria defined in Section 3.2 Material matters and materiality of information of ESRS 1.

Frequency and Review

In 2023, Gestamp analysed its inherent human rights risks based on probability according to the geographical areas in which it is active and severity based on scale, scope and remediability of the different human rights risks in its stakeholders.

In 2024, a review has been conducted and initial steps taken to develop an environmental and human rights due diligence procedure applicable to the Group's value chain and aligned with the requirements of the Corporate Sustainability Reporting Directive (CSRD).

Gestamp reviews its double materiality assessment on an annual basis to make sure that its strategy is in line with its most recent results. Since 2025 is the final year of the 2023 - 2025 ESG Plan, a more in-depth review of the sustainability strategy will be conducted in 2025.

Use of Value Chain Mapping

In 2023, Gestamp's double materiality assessment related exclusively to the company's own activities. As the 2024 double materiality assessment includes information about the Group's value chain, covering both upstream and downstream operations, the analysis has been updated and a broader set of results has been obtained.

The double materiality assessment is conducted at group level and takes into consideration all the geographical locations in which the company and every link in the Group's value chain is active (sites). It also covers both its own activities and its upstream and downstream trade relations (value chain).

The double materiality assessment did not focus exclusively on direct operations. It also covered all other operations of the value chain.

Integration with Risk Management

In 2024, a process has been launched to align and add the risks identified in the Group's double materiality assessment to the corporate Risk Map, in a bid to ensure that the control measures required to manage such risks are in place, and that the methodology followed for the Double Materiality Assessment is included in chapter IRO-1 and aligned with the Group's risk assessment methodology.

Stakeholder Engagement

As part of the double materiality assessment, Gestamp has involved its key stakeholders (own workforce, workers in the value chain, etc.) in the process of evaluating IROs. To this end, it has employed various methods such as surveys, market research, trend reports, ratings analysis, analysts, etc. Consequently, each of the group's stakeholders has provided explicit feedback which is used in the context of the double materiality assessment.

The consultation methods have not highlighted any aspect that requires an urgent alteration to the company's sustainability strategy.

Transition plan for climate change mitigation

Scope of the plan

The transition plan applies to Gestamp Group globally, covering all regions where Gestamp carries out its activity. The plan extends across the entire value chain.

The scope includes:

• All production plants within the environmental scope (90.4% of companies in the Group's Financial Statement perimeter)
• Three decarbonisation stepping stones:
  • What we manufacture: Automotive parts that are lighter, reducing emissions of the final vehicle; business unit dedicated to electric vehicles
  • How we manufacture: Transformation towards sustainable production through electrification of industrial processes, energy efficiency, and renewable energy purchase/self-supply
  • Raw materials used: Circularity focus with >60% of emissions from raw materials; significant stake in Gescrap acquired in 2022; low-emission steel agreements with steelmakers

Target year(s) for net zero / carbon neutral

• 2050: Carbon neutrality target (net zero)
• 2030: Scope 2 neutrality
• 2045: Scope 1 neutrality

Scope 1, 2, 3 reduction milestones with baseline years

¹ (tCO2eq scope 2 year "n" - tCO2eq scope 2 base year) / tCO2eq scope 2 base year) x 100

² Net emissions

³ [((tCO2eq scope 1 year "n" + tCO2eq scope 2 year "n") - (tCO2eq scope 1 base year + tCO2eq scope 2 base year)) / (tCO2eq scope 1 base year + tCO2eq scope 2 base year)] x 100

⁴ (MWh consumed from renewable electricity / Total MWh consumed) x 100

⁵ SBTi target. (tCO2eq scope 3 year "n" - tCO2eq scope 3 base year) / tCO2eq scope 3 base year) x 100

⁶ [((tCO2eq scope 1 year "n" + tCO2eq scope 2 year "n" + tCO2eq scope 3 year "n") - (tCO2eq scope 1 base year + tCO2eq scope 2 base year + tCO2eq scope 3 base year)) / (tCO2eq scope 1 base year + tCO2eq scope 2 base year + tCO2eq scope 3 year "n")] x 100

Alignment with 1.5°C / SBTi validation status

• Current alignment: 2°C scenario
• SBTi validation: Validated in 2020 for 2°C target
  • 30% reduction of Scope 1 and 2 emissions
  • 22% reduction of Scope 3 (base year 2018)
• 1.5°C alignment: Not yet aligned with 1.5°C. The company states: "In the course of 2025, Gestamp will consider updating these targets to limit the temperature increase to 1.5°C." The update will be "consistent with market evolution and trends regarding steel purchasing, and not only with science-based emission projections to achieve the 1.5ºC targets, but also taking into consideration whether the demand and availability of low-emission steel increase to the levels necessary to achieve decarbonization objectives."
• Scope 3 emissions account for more than 90% of the group's emissions, the majority linked to purchase of goods and services

Key levers / decarbonisation pillars

Energy efficiency measures

2024 achievements:

• Energy efficiency initiative in 53+ plants (9% certified to ISO 50001)
• Total energy saving: 46.6 GWh through 114 improvement measures
• Total reduction: 15,378 tonnes of CO2
• ROI: approximately 1.9 years

Key measure categories:

1. Compressed air: 18 measures, 2,249 MWh (12%) saved, 756.8 tonnes CO2 avoided
2. Gas use: 8 initiatives, 3,811 MWh (20%) saved, 908.2 tonnes CO2 avoided
3. New technologies (LED lighting): 22 initiatives, 3,648 MWh (19%) saved, 1,418.2 tonnes CO2 avoided
4. Unnecessary energy consumption: 60 measures, 8,004 MWh (42%) saved, 3,122.4 tonnes CO2 avoided
5. Other technological improvements: 6 initiatives, 1,381 MWh (4.5%) saved, 293.1 tonnes CO2 avoided

2025 target:

• Energy efficiency initiative extended to 56 plants
• Target: 31,533 MWh saving, 12,025 tCO2 avoided emissions

Renewable energy strategy (three-channel approach)

1. Long-term renewable energy supply agreements (PPAs):

   • Solar PPA awarded to Pune plant (India), operational in 2025
   • Wind PPA in Mexico: 49 GWh per year since June 2024
   • Multiple PPAs in various regions

2. Purchase of Renewable Energy Certificates (EACs)

3. Self-supply of energy:

   • Solar panels installed in various plants
   • 26,626.9 MWh self-generated electricity in 2024

Renewable electricity consumption:

• 2024: 50% of total electricity from renewable sources (753,886.5 MWh purchased + 26,626.9 MWh self-generated)
• Total renewable energy consumption 2024: 780,513.4 MWh (41% of total energy)

Process electrification and technology

• Electrification of industrial processes
• Hot stamping technology leadership
• Multi-material solutions for lightweighting
• Business unit dedicated to electric vehicle batteries
• 13 R&D centres working on low-emission materials and co-development
• Technology and Innovation Office driving decarbonisation strategy

Circular economy and materials

• Focus on circularity due to >60% of emissions from raw materials
• Gescrap acquisition (2022) - metal recycling specialist
• Annual low-emission steel agreements with steelmakers
• Reintroduction of scrap as secondary raw material
• Product life cycle analysis (LCA) in design phase

Product-related levers

• Lightweighting of parts (chassis and bodywork components = ~70% of vehicle weight)
• Hot stamping technology reducing vehicle weight and emissions
• Door Rings manufactured through hot stamping for electric vehicles
• Focus on reducing emissions during vehicle use phase

CapEx / investment commitments

• 2024 energy efficiency CapEx: €1.64 million
• Approved CapEx plan for decarbonisation strategy (specific amount not disclosed)
• Debt refinancing linked to specific decarbonisation targets
• EU Taxonomy alignment: 11.8% of CapEx from environmentally sustainable activities (2024)
• EU Taxonomy eligible but not aligned: 9.5% of CapEx (2024)

Locked-in emissions and stranded asset analysis

"Although no locked-in emissions have been identified in 2024, as defined in the EFRAG E1 standard, this particular case of the automotive sector is identified."

The company has not identified any business assets or activities that are incompatible with a transition towards a climate-neutral economy, or for which a substantial effort will be required to guarantee compatibility.

Use of carbon credits / removals

Gestamp's decarbonisation strategy is established without taking into consideration emission compensation tools such as the purchase of carbon credits. However, the company states:

"Considering the trajectory of the sector with respect to electric vehicles, the use of this residual emissions compensation route is being considered as a lever to meet future objectives."

Current and planned activities:

• Working on accounting for and financing climate change mitigation projects
• Generating Energy Saving Certificates (CAES) with external consultant and third-party verification
• Implementing blockchain system for project traceability
• Exploring reforestation projects as nature-based solutions near industrial plants
• No carbon credits used in 2024 emissions calculation

Governance and monitoring

• Multidisciplinary working groups led by ESG Management with Purchasing, Energy Efficiency, Commercial and Operations departments
• Approval: Transition plan approved by Sustainability Committee
• Monitoring: Quarterly monitoring reported to Sustainability Committee, Board of Directors, and ESG Committee
• Policies: ESG Policy (approved 27 February 2024), Energy Policy (approved 18 July 2024), Environmental Policy
• Integration: Plan incorporated in alignment with overall strategy and financial planning

Additional strategic elements

• Analysis of automobile manufacturers' neutrality objectives and requirements
• Monitoring of most intensive emission sources for all production plants
• Global inventory of fossil fuel consuming equipment updated annually
• Shutdown protocols implemented in production plants
• Analysis of market alternatives (e.g., biomethane)
• Renewable electricity purchasing strategy focused on main emission points with polluting energy mix
• Feasibility studies for emission reduction measures across 3 scopes (technical and economic terms)

Timeline and implementation

Actions apply until decarbonisation strategy completion or until zero net emissions achieved in corresponding scope. Actions are group-wide, applying to every region where Gestamp operates.

Policies related to climate change mitigation and adaptation

Gestamp effects its decarbonisation commitments and strategy through 3 policies: the ESG Policy, approved on 27 February 2024; the Energy Policy, approved on 18 July 2024; and the Environmental Policy.

ESG Policy

Approval and oversight:

• Approved on 27 February 2024
• Implementation rests with ESG Management and ultimately with the Sustainability Committee

Scope:

• Global in nature and applies to the entire Group, including all business activities and relations with third parties in all geographical areas where it operates
• Commitments extend across the entire value chain

Key content and principles:

The ESG Policy sets forth the principles on which Gestamp builds its environmental, social and good governance (ESG) strategy and performance, which are aligned with its business objectives, company culture and the United Nations 2030 Agenda. The policy addresses material impacts, risks, and opportunities related to climate change mitigation and adaptation as follows:

1. Climate Change Mitigation: The company contributes to mitigation by reducing its GHG emissions, promoting energy efficiency and using renewable energy. These actions support the aims of the European Green Pact and improved air quality. The company is also working to reduce the carbon footprint of cars during their useful life by making parts lighter.

2. Adaptation to climate change: The ESG policy includes the review and approval of ESG risk rating scales, taking into account impact, likelihood of occurrence and risk velocity, as well as mitigating controls. Assets and activities exposed to impacts from climate risks are also analysed and assessed.

3. Energy Efficiency: The ESG policy promotes energy efficiency measures by identifying and implementing energy saving strategies at plant level. Among other measures, the company focuses on monitoring gas and electricity consumption to create an efficient performance model.

4. Renewable Energy Rollout: The company adopts the use of renewable energy through three main channels: signing long-term renewable energy supply agreements (PPAs), purchasing Renewable Energy Certificates (EACs), and the self-supply of energy.

5. Other Principles of Conduct: The company's ESG policy addresses efficiency in the use of natural resources, promoting the reduction of raw materials used, and ensuring the efficient use and correct treatment of water. A circular economy approach is followed, in order to produce automotive components with a high recycled material content by reintroducing scrap as a secondary raw material. The company is also committed to caring for and protecting natural capital, ecosystems and biodiversity, and to combating deforestation across the value chain.

Link to international standards:

• Aligned with the United Nations 2030 Agenda
• Supports the aims of the European Green Pact

Public availability:

• See: ESG Policy (referenced in document)

Energy Policy

Approval and oversight:

• Approved on 18 July 2024

Key content and principles:

The Energy Policy demonstrates the Group's alignment with the decarbonisation plan objectives and provides the necessary resources for the effective implementation of the energy efficiency programme.

Link to international standards:

• Aligned with international standard ISO 50001

Environmental Policy

Effective date:

• Effective from 2021

Key content and principles:

Gestamp firmly commits to protecting, conserving, and respecting the environment by controlling and minimising potential adverse impacts from its production processes. The policy sets out the Group's commitments regarding the environment, climate change, pollution, biodiversity and ecosystems, as well as the efficient use of natural resources.

Actions and resources in relation to climate change policies

Gestamp has structured its climate action strategy around three fundamental pillars: what it manufactures, how it manufactures, and the raw materials it uses. The company monitors impacts, risks and opportunities across three time horizons: short-term (to 2030), medium-term (2031-2050), and long-term (2050-2100).

What We Manufacture

Lightweight automotive parts production

• Scope: Own operations, downstream value chain
• Description: Manufacturing automotive parts lighter than competitors, reducing final vehicle emissions
• Business unit: Dedicated electric vehicle business unit developing solutions for technical requirements of electric cars
• Outcome: Reduced emissions during vehicle use phase

Battery component manufacturing

• Taxonomy activity: Activity 3.4 - Manufacture of batteries (battery boxes for electric vehicles)
• Scope: Downstream value chain
• Expected outcome: Electric vehicles enabled net reduction of around 80 Mt GHG emissions (2022 baseline)

Door Rings production via hot stamping

• Taxonomy activity: Activity 3.18 - Manufacture of automotive and mobility components
• Description: Hot stamping production process that reduces final vehicle weight
• Scope: Own operations, downstream value chain

How We Manufacture

1. Energy Efficiency Measures

ISO 50001 Energy Management Programme

• Scope: Own operations (53 plants in 2024, expanding to 56 in 2025)
• Time horizon: Short-term (ongoing)
• Resources:
  • CapEx 2024: €1.64M
  • Non-financial: Multidisciplinary working groups led by ESG Management including Purchasing, Energy Efficiency, Commercial and Operations departments
  • 9% of plants ISO 50001 certified
• Expected outcomes:
  • 2024 achieved: 46.6 GWh energy savings, 15,378 tonnes CO2 reduction
  • 2025 target: 31,533 MWh savings, 12,025 tCO2 avoided
• KPIs: Energy consumption monitoring, CO2 Emissions Index (tCO2 Scope 1+2/net income)
• Links to: Energy Policy, Environmental Policy, ESG Policy, ISO 50001 standard

Specific efficiency measures implemented in 2024 (114 total measures, ROI ~1.9 years):

1. Compressed air optimization

   • 18 measures implemented
   • Savings: 2,249 MWh (12%), 756.8 tonnes CO2
   • Example: Gestamp Abrera laser welding cell local blower installation (86 MWh annual saving)

2. Gas use optimization

   • 8 initiatives
   • Savings: 3,811 MWh (20%), 908.2 tonnes CO2
   • Example: Gestamp Bielefeld reduced dryer operating temperature (290 MWh annual saving)

3. LED lighting replacement

   • 22 initiatives
   • Savings: 3,648 MWh (19%), 1,418.2 tonnes CO2

4. Elimination of unnecessary consumption

   • 60 measures
   • Savings: 8,004 MWh (42%), 3,122.4 tonnes CO2
   • Example: Gestamp Aguascalientes intelligent air compressor sequencer (743 MWh annual saving)

5. Heat recovery and technological improvements

   • 6 initiatives
   • Savings: 1,381 MWh (4.5%), 293.1 tonnes CO2
   • Example: Gestamp Metalbages paint line heat recovery (721 MWh annual saving)

Shutdown protocols

• Scope: Own operations (global)
• Description: Standard protocols during production asset inactivity
• Outcome 2024: 4.1 GWh savings in plants outside energy efficiency initiative scope

Energy efficiency assessment programme

• Time horizon: Short-term (2024-2025)
• Scope: 50 plants completed in 2024; expanding to Asia, USA, Germany, Hungary divisions in 2025
• Description: Identify non-standard practices for correction

CO2Tem consumption monitoring system

• Taxonomy activity: Activity 8.2 - Data-driven solutions for GHG emissions reductions
• Description: IoT-based meters collecting and analysing consumption data
• Scope: Own operations (production plants)

2. Renewable Energy Supply Strategy (Three Channels)

Channel 1: Long-term Power Purchase Agreements (PPAs)

• Scope: Own operations
• Time horizon: Long-term contracts
• Resources: OpEx 2024: €48.16M (total renewable energy purchase)
• 2024 actions:
  • Solar PPA awarded: Pune plant, India (operational 2025)
  • Wind PPA operational: Mexico (49 GWh/year from June 2024)
  • 10-year virtual PPA awarded: Portugal, Hungary, Slovakia, Czech Republic (starting 2026)
  • Brazil PPA volume extension signed

Channel 2: Renewable Energy Certificates (EACs)

• Scope: Own operations
• 2024 coverage: UK, Poland, Slovakia, Sweden, Portugal (via marketing company); Germany, Czech Republic, China, India, USA (direct certificates)

Channel 3: Solar self-consumption

• Scope: Own operations
• 2024 outcome: 29 GWh self-consumed from plants in China, India, Spain, Portugal
• 2024 actions:
  • New plants launched: China, Spain
  • New developments awarded: Japan, UK, France
  • Engineering process: Germany installations (for 2025 deployment by EDF)
  • Phase 1 completion: Aveiro, Portugal solar roof

3. Electrification of Industrial Processes

Furnace and cataphoresis line electrification

• Scope: Own operations
• Time horizon: Short to medium-term
• Resources: CapEx 2024: €3.14M
• 2024 projects:
  • Hot stamping furnaces: Bizkaia and Aveiro
  • Cataphoresis line furnaces: Metalbages and Vendas Novas
• Links to: Decarbonisation targets (Scope 2 neutrality by 2030, Scope 1 by 2045)

Raw Materials We Use to Manufacture

1. Collaboration with Customers

• Scope: Downstream value chain
• Description: Develop solutions promoting CO2 reduction throughout vehicle life
• Tool: Product carbon footprint calculation from design phase

2. Supplier Collaboration for Low-Carbon Materials

ThyssenKrupp bluemint steel supply agreement

• Scope: Upstream value chain
• Time horizon: Ongoing
• Description: CO2-reduced steel supply to Gestamp plants
• Links to: Scope 3 reduction targets, circular economy model, customer NetZero-Car requirements

Salzgitter SALCOS® steel agreement

• Scope: Upstream value chain
• Time horizon: From 2026
• Description: CO2-reduced steel supply

3. Gescrap Acquisition and Scrap Management

Gescrap waste management operations

• Taxonomy activity: Activity 5.9 - Material recovery from non-hazardous waste
• Scope: Upstream value chain (circular economy)
• Description: High-quality scrap supply for green steel production
• Resources: CapEx and OpEx detailed in EU Taxonomy disclosure section
• Links to: Circular economy strategy (>60% emissions from raw materials)

4. Product Carbon Footprint Calculation

• Scope: Own operations, value chain
• Description: Strategic tool to evaluate production impact and material selection
• Expected outcome: Identify improvement areas, optimize decision-making, meet customer decarbonisation demands

Cross-Cutting Actions

EU Taxonomy-aligned activities implementation

SBTi target update programme

• Time horizon: 2025
• Description: Update emission reduction targets from 2°C to 1.5°C alignment
• Current targets: 45% Scope 1+2 reduction, 62% renewable electricity by 2025 (base year 2018); Scope 2 neutrality by 2030; Scope 1 neutrality by 2045; overall neutrality by 2050
• Links to: Paris Agreement, SBTi validation (2020 - 2°C)

ESG-linked debt refinancing

• Scope: Corporate finance
• Description: Significant debt portion linked to specific decarbonisation KPIs
• Verification: Third-party verified alongside non-financial information

Supplier ESG risk assessment

• Scope: Upstream value chain
• Description: Supplier approval process evaluating ESG risk including climate change
• Link: See G1-2 for details

Energy Saving Certificates (CAES) generation

• Time horizon: Near future
• Resources: External consultant engagement
• Description: Third-party verified reports for certificate registration and sale
• Innovation: Blockchain system implementation for traceability

Climate scenario analysis

• Scope: Enterprise-wide
• Description: Analysis using IPCC and IEA scenarios across three time horizons
• Purpose: Inform strategy adjustment, asset improvement, product/service offer adaptation, staff training

Financial Summary

Total climate-related investments 2024:

• Energy efficiency CapEx: €1.64M
• Electrification CapEx: €3.14M
• Renewable energy OpEx: €48.16M
• Gescrap CapEx/OpEx: See EU Taxonomy section

Performance outcomes 2024:

• Energy intensity: 158.0 MWh/€M revenue (-1.3% consumption vs 2023)
• GHG intensity: 31.98 tCO2eq/€M revenue (-20.6% vs 2023)
• Renewable energy share: 41% of total consumption (vs 34% in 2023)
• Fossil fuel share: 54% of total consumption (vs 60% in 2023)

In 2020, Gestamp announced emission reduction targets for 2030 validated by SBTi: reduction of 30% of scope 1 and 2 emissions and reduction of 22% of scope 3 emissions (base year 2018). Due to regulatory changes and customer requirements in 2022, Gestamp decided to increase the level of ambition regarding the reduction of scope 1 and 2 emissions in its ESG Plan 2023-2025, setting as goals to reduce scope 1 and 2 emissions by 45%, and ensure that 62% of the electricity consumed comes from renewable sources.

Gestamp Group's Climate Neutrality Objectives: • Will be neutral in scope 2 by 2030. • Will be neutral in scope 1 and scope 2 by 2045. • It will be neutral in scope 1, 2 and 3 by 2050 globally.

Energy consumption and mix

Energy consumption by source and type (MWh)

Scope: 90.4% of the companies in the Group's Financial Statement perimeter.

Methodology: To calculate the energy consumption of the mix, the database published by Ember was used as a source. This is a repository that brings together information from EIA, Eurostat, BP and UN, among others.

Note on renewable fuels: In 2024, the Group did not have direct consumption of renewable fuels such as biomass, hydrogen or biogas. However, this is an aspect that it is currently studying in order to achieve its decarbonisation objectives.

Energy intensity

Scope: 90.4% of the companies in the Group's Financial Statement perimeter.

Note: The company's activity does not fall within any of the industries listed in Annex I, Sections A to H and L of Regulation (EC) No 1893/2006 of the European Parliament and of the Council. However, the Group reports information on total energy consumption by net income.

The reported energy consumption relates to processes under the company's control, in application of the same perimeter for reporting Scope 1 and 2 GHG emissions. In addition, the group is considering disaggregating the information on renewable energy into self-generated energy and purchased electricity to avoid double counting.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1, 2 and 3 emissions (tCO2eq)

Scope 1 breakdown by source (tCO2eq)

Scope 3 emissions breakdown by category (tCO2eq)

Note: Categories 5 (Waste generated in operations), 8 (Upstream leased assets), 9 (Downstream transportation and distribution), 10 (Processing of sold products), 13 (Downstream leased assets), 14 (Franchises), and 15 (Investments) are not disclosed or not material to Gestamp's operations.

GHG intensity

GHG intensity calculated as total GHG emissions (Scope 1 + 2 market-based + 3) divided by net revenue.

Biogenic CO2 emissions

Biogenic CO2 emissions are reported separately from Scope 1 and are not included in the total GHG emissions figures above.

Methodology and scope notes

• Reporting standard: GHG emissions are calculated following the GHG Protocol Corporate Accounting and Reporting Standard.
• Scope: The reporting boundary covers all Gestamp production plants and facilities included in the financial consolidation scope. Gescrap's activity is included in 2024 figures.
• Scope 2 calculation: Location-based uses grid average emission factors; market-based uses contractual instruments (PPAs, certificates) and residual mix factors.
• Scope 3 coverage: Category 1 (Purchased goods and services) represents the largest portion (86.5% of Scope 3). Categories 5, 8, 9, 10, 13, 14, and 15 are not disclosed as they are either not material or not applicable to Gestamp's operations.
• Baseline year: 2018 is used as the baseline for emission reduction targets.
• Conversion factors: Updated annually based on IEA, DEFRA, and regional grid emission factors.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Use of phase-in exemption

Gestamp has made use of the transitional provisions in accordance with Appendix C of ESRS 1 for ESRS E1-9 (Anticipated financial effects from material physical and transition risks and potential climate-related opportunities).

Climate-related risks and opportunities analysis

Gestamp considers climate change risk in the Corporate Risk Map and carries out a specific analysis on Climate Change risks and opportunities affecting business in order to:

• Anticipate and adapt to the climatic risks that affect business, as well as take advantage of the opportunities it may offer.
• Measure the financial impacts of climate change according to different scenarios and possible futures in the short, medium and long term.

The result has been integrated into the dual materiality analysis and risk and opportunity management measures have been identified.

Identified risks and opportunities

Resilience analysis approach

Gestamp is striving to determine the potential financial effects of climate change and to estimate the costs of implementing its adaptation plan. On this basis, it is assessing the monetary amounts, the proportion of affected companies and, therefore, the provisions required to implement adaptation and mitigation measures.

As part of its resilience analysis, no physical or transition risks are being excluded, to the extent that they have a material effect on its activities and value chain. Steps are being taken to cover all relevant aspects that may affect its strategy and decision-making processes, at every stage in its value chain.

The company will evaluate its capacity to adjust its strategy and business model in order to guarantee short-, medium- and long-term resilience. That includes improving assets, adjusting the product and service offer and organising staff training initiatives. Gestamp is also considering maintaining access to financing at an affordable cost of capital.

Policies related to pollution

Gestamp addresses pollution-related impacts, risks, and opportunities through two main policies that extend to its value chain. The company's double materiality analysis determined that pollution within Gestamp's own operations is non-material, with material impacts and risks identified in the upstream value chain (suppliers).

ESG Policy

Approval and oversight:

• Approved on 27 February 2024
• Implementing the commitments set out in this policy rests with ESG Management and ultimately with the Sustainability Committee
• The Board of Directors is responsible for defining and promoting the overall policies and strategies of the Company and its group

Scope:

• Applies in all regions where Gestamp carries out its activity
• Commitments extend across the entire value chain

Key principles: The ESG Policy sets forth the principles on which Gestamp builds its environmental, social and good governance ("ESG") strategy and performance, aligned with business objectives, company culture and the United Nations 2030 Agenda. The policy addresses five principles linked to pollution:

1. Efficient use of natural resources: Contributing to a more rational and efficient use of resources (such as soil, forests, water) in the design, procurement and production phases
2. Focus on circular economy: Working to create circular business models in the industry; focusing on the manufacture of automotive components with a high content of recycled material
3. Biodiversity protection: Nurturing and protecting natural assets, ecosystems and biodiversity throughout the entire value chain
4. Responsible product design, manufacturing and use: Ensuring that all automotive component development phases take into account reduced environmental impact
5. Collaborative value chain: Conveying the highest ESG standards and commitments to suppliers, to achieve a value chain aligned with sustainability principles. Working to create a collaborative ecosystem in the automotive industry, geared towards an industry that is more efficient in the use of resources and waste management, less polluting, more respectful of biodiversity, decarbonisation and the circular economy

Links to international standards:

• Aligned with the United Nations 2030 Agenda

Public availability:

• Available to interested parties on the Group's corporate website
• Available at: ESG Policy

Stakeholder communication:

• Gestamp provides its stakeholders with different communication channels depending on whether they are employees, customers, suppliers, regulatory bodies, the financial community or civil society

ESG Requirements for Suppliers

Scope:

• Must be complied with by all Gestamp Group suppliers and their employees, as well as subcontractors (collectively, the 'suppliers') regardless of the country or territory in which these suppliers and employees perform their services

Key content:

• Gestamp involves its suppliers to ensure that measures are adopted that help towards the protection of the environment, compliance with environmental legislation, and the maintenance of a preventive approach that minimises adverse effects on biodiversity and ecosystems
• Addresses pollution prevention aspects

Public availability:

• Available at: ESG Requirements for Suppliers

Monitoring implementation: Gestamp has corporate supply chain management systems, procedures and standards that apply to the entire Group, which cover aspects of pollution prevention. These systems address specific aspects related to suppliers and pollution, including:

• Environmental policies
• Environmental management systems (and whether these are ISO 14001 certified)
• Monitoring of air emissions, discharges and waste
• Whether the company has received disciplinary sanctions for environmental non-compliance
• Whether it has measures in place to prevent environmental non-compliance

For more information see chapter 'G1-2: Management of relationships with suppliers'.

Disclosure regarding own operations

Double materiality analysis has determined that pollution within Gestamp's own operations is non-material. Both SO2 and NOx emissions come from natural gas, LPG or diesel combustion and will gradually decrease as the Group stops using fossil fuels in accordance with its commitment to decarbonisation. VOC emissions are produced as a result of solvent use.

Note: Gestamp does not provide for or disclose remedial actions or allocated resources related to its suppliers' air or water pollution events.

Actions and resources related to pollution

Measures to prevent, reduce or repair carbon emissions (also includes noise and light pollution)

The document references pollution-related actions on pages 163-166 under the following measures:

• Energy efficiency measures in production plants: Implementation of shutdown protocols to reduce emissions
• Market analysis for decarbonization alternatives: Analysis of new alternatives such as the use of biomethane
• Renewable electricity purchasing strategy: Focused on main emission points with more polluting energy mix
• Feasibility studies for emission reduction measures: Studies covering all 3 scopes over time in both technical and economic terms

Decarbonisation Strategy Framework

Gestamp's decarbonisation strategy is organized around three stepping stones:

1. What we manufacture: Manufacturing lighter automotive parts to reduce final vehicle emissions; dedicated business unit for electric vehicles developing solutions for electric car requirements

2. How we manufacture: Transformation of production toward sustainable model through:

   • Electrification of industrial processes
   • Energy efficiency actions
   • Purchase and self-supply of renewable energy

3. Raw materials we use to manufacture: With more than 60% of emissions from raw materials:

   • Acquisition of significant stake in Gescrap in 2022
   • Annual low-emission steel agreements with steelmakers
   • Circularity focus as key decarbonisation stepping stone

Resources Allocated

Financial resources: CapEx and OpEx for the decarbonisation plan in 2024 are referenced but directed to chapter 'E1-3' for detailed figures.

Approved CapEx plan: An approved CapEx plan exists for carrying out the company's decarbonisation strategy.

Debt refinancing: Gestamp has linked refinancing of a significant part of its debt with banks to specific decarbonisation targets.

Governance and Planning

• Approval: Transition plan approved by the Sustainability Committee
• Integration: Plan incorporated in alignment with company's overall strategy and financial planning
• Monitoring: Progress of implementation is evaluated and reported
• Future targets: In 2025, Gestamp will consider updating targets to limit temperature increase to 1.5°C

Scope Coverage

• Scope 3 emissions: Account for more than 90% of the group's emissions, majority linked to purchase of goods and services
• Own operations: Energy efficiency, renewable energy, process electrification
• Upstream value chain: Raw materials procurement, low-emission steel agreements

Targets related to pollution

Gestamp does not have measurable results-oriented pollution targets. However, the Group is currently devising a new ESG Plan in which all aspects considered material will be reviewed, taking into account the segment of the value chain in which they are deemed material.

Supplier management targets

Since the impact and risk identified are related to the value chain, Gestamp has established specific targets for managing its suppliers to ensure the monitoring of their policies' effectiveness:

Notes:

• The scope of the objectives is Gestamp Group
• ¹ Information obtained from the supplier homologation system
• ² Data compiled by the purchasing department
• ³ Quality audits in which ESG aspects have been reviewed
• ⁴ Gestamp has worked during 2024 on the inclusion of new ESG specifications in its contracts with suppliers

Pollution of air, water and soil

Double materiality analysis has determined that pollution within Gestamp's own operations is non-material. Both SO₂ and NOx emissions come from natural gas, LPG or diesel combustion and will gradually decrease as the Group stops using fossil fuels in accordance with its commitment to decarbonisation. VOC emissions are produced as a result of solvent use.

Emissions to Air

Scope: The scope of the information is 90.4% of the companies in the Group's Financial Statement perimeter.

Emissions to Water

Not disclosed.

Emissions to Soil

Not disclosed.

Regulatory References

The company references European PRTR (Pollutant Release and Transfer Register) requirements in its disclosure framework but notes that E2-4 is "n/a as it is not material for the company's own activity."

Policies related to water and marine resources

Gestamp has stated that specific policies related to water and marine resources (ESRS E3-1) are not material for the company's own activity.

According to the cross-reference table on page 339, the company notes:

"n/a as it is not material for the company's own activity. However, Gestamp's policies are applicable to the entire Group."

The company has also indicated that sustainable management of oceans and seas (paragraph 14) is not material for the company's own activity.

While no specific standalone water and marine resources policy is identified, the company does reference general policies on pages 169-171, 176-178, 184-185, 202-209, 248-252, 259-260, 264-266, 276-277, and 285, though these are listed across all topic standards rather than being water-specific.

Water-related actions

The company does report:

• Water consumption and water supply measures in accordance with local limitations (pages 171-173, related to ESRS E3-4)
• Water consumption data is disclosed as part of operational environmental management

However, no dedicated water and marine resources policy document, framework, or governance structure is disclosed.

Actions and resources related to water

The document references actions and resources related to water across multiple pages but does not provide detailed information in the excerpts provided.

Cross-references provided:

Water consumption and water supply in accordance with local limitations

• Referenced in ESRS disclosure requirement E3-4: Water consumption
• Detailed information located on pages 171-173 of the full report
• Scope: Appears to relate to own operations with consideration of local limitations

General environmental management resources

• Resources are dedicated to the prevention of environmental risks (page 303)
• Environmental assessment or certification procedures are in place
• Application of the precautionary principle
• Provisions and guarantees for environmental risks
• These resources are stated to support disclosure across all environmental standards including E3-1, E3-2

The excerpts indicate that specific actions and resources related to water and sanitation (E3-2) are documented elsewhere in the full sustainability statement, particularly on pages 171-173, but the detailed content of those actions is not included in the provided excerpts.

Water consumption

Water consumption by source

The scope of the information is 90.4% of the companies in the Group's Financial Statement perimeter.

Water consumption intensity

To monitor the evolution of water consumption, the Water Consumption Index (WCI) is used, which measures the m³ of consumed water/€100,000 of added value.

The scope of the information is 90.4% of the companies in the Group's Financial Statement perimeter.

Water discharge

It is estimated that 10% of water consumption evaporates in production processes and other losses, so 90% of water consumption would be considered as discharge. Most of this discharge is carried out in a controlled way into the sewer system where adequate treatment is received through wastewater treatment plants.

Very strict controls are applied to ensure that the quality of the water discharge is sufficient to meet all legal requirements in accordance with the applicable regulatory laws depending on the country and to minimise any possible impact. Specifically, all plants with painting lines have physical-chemical treatment for wastewater.

Water consumption in water stress areas

The scope of the information is 90.4% of the companies in the Group's Financial Statement perimeter.

Water recycling and reuse

Gestamp is implementing water monitoring systems to reduce consumption, and to promote recirculation and recycling in plants with production processes with intensive use of water and in regions with water stress:

• In plants with processes such as hydroforming or painting parts, through closed circuit systems in which water is reused for long periods of time.
• In regions where the risk of water stress is high, through water recycling systems, such as the case of the Chennai plant, India, where they use 41 m³ of treated water per day in the water treatment plant for gardening purposes.

Context

Water consumption at production plants is predominantly for sanitary use. In a minority of plants where surface treatment processes take place, such as painting or galvanising parts, or hydroforming processes, there is an industrial use of water.

The painting of parts involves certain quality requirements that make it essential to frequently change the baths on the cataphoresis lines, resulting in considerable increase in water consumption. Conversely, the baths can be reused in the treatment of structural parts, which entails a low water consumption and a reduction in the WCI.

Policies related to biodiversity and ecosystems

Gestamp Automocion references policies related to biodiversity and ecosystems within its ESRS E4-2 disclosure. The company references pages 176-178 for biodiversity-related policies, specifically in relation to deforestation.

Policies to address deforestation

• Reference: The company indicates it has policies to address deforestation (ESRS E4-2 paragraph 24, point (d)), disclosed on pages 176-178
• Public availability: The disclosure cross-references pages 176-178 for details

Sustainable agricultural or land use practices or policies

• Disclosure status: The company indicates "n/a" for sustainable agricultural or land use practices or policies (ESRS E4-2 paragraph 24, point (b)), suggesting this is not applicable to Gestamp's business model

Sustainable marine or ocean practices or policies

• Disclosure status: The company indicates "n/a" for sustainable marine or ocean practices or policies (ESRS E4-2 paragraph 24, point (c)), suggesting this is not applicable to Gestamp's business model

The excerpts provided indicate that E4-2 is referenced in the company's policy framework (pages 176-178) but do not provide the detailed content of the specific biodiversity and ecosystem policies within these extracted sections.

Actions and resources related to biodiversity

Supplier Approval Process

Description: Strict approval process that checks aspects related to biodiversity including:

• Existence of environmental management system with ISO 14001 certification
• Whether biodiversity conservation measures are in place
• Whether supplier has received administrative sanctions for environmental non-compliance
• If sanctions exist, whether measures are established to prevent such fines

Scope: Upstream (supply chain)

Time horizon: Current/ongoing

Resources: Not quantified

Link to policy/target: Linked to ESG Plan targets for responsible supply chain (detailed in E2-3)

Environmental Audits at High-Impact Facilities

Description: Strict action and control mechanisms established in 8 plants located in Argentina, Brazil, China, Spain, France, Mexico and Portugal where industrial surface treatment processes and water discharges into public watercourses occur. These facilities are subject to comprehensive internal audits to ensure environmental incident prevention plans are in place.

Scope: Own operations

Time horizon: Current/ongoing

Resources: Not quantified

Expected outcomes: Reduce likelihood of adverse events and protect local ecosystems

Participation in EU Business @ Biodiversity Platform (European Commission)

Description: Collaboration with pioneering companies to develop tools that help integrate biodiversity into different business models, focusing on three main areas:

• Natural capital: helping integrate biodiversity into company decisions
• Innovation for Biodiversity and Business: developing tools for assessment, sharing and identifying opportunities and best practices
• Financial Institutions: forum for dialogue to integrate biodiversity and natural capital into financial activities trends

Scope: Own operations and value chain

Time horizon: Multi-year (ongoing for many years)

Resources (non-financial): Partnership with European Commission initiative

Participation in Nature Business Ambition (Forética)

Description: Business leadership initiative launched in 2022 to boost ambition, promote action and build alliances to help towards recovery of nature and biodiversity as key factors in achieving a 'nature positive' planet by 2030. Three pillars:

• Ambition: Boost ambition and enhance commitment of companies involved
• Action: Promote action by identifying business cases, trends and major tools to move towards a "Nature positive" world
• Alliances: Build alliances with main national and international stakeholders to become a leading player

Scope: Own operations and value chain

Time horizon: Through 2030

Resources (non-financial): Partnership with Forética

Link to policy/target: Aligned with 'nature positive' planet goal by 2030

Biodiversity Monitoring and Assessment

Description: Geospatial analysis using geographic information systems (GIS) and nature databases to monitor potential impact on biodiversity near facilities. Includes:

• Identifying protected status of natural areas (national and international) close to Gestamp sites
• Assessing existence of endangered species surrounding facilities
• Detailed biodiversity study combining primary data, secondary data and geospatial models

Scope: Own operations

Time horizon: Current/ongoing (data updated regularly)

Resources: Not quantified

Expected outcomes: 10 plants identified in protected areas (SAC, SPA within Natura 2000 Network); 3 plants in environments with protected species

Future Supply Chain Due Diligence

Description: More detailed assessment of the impact of supply chain activities planned to show compliance with new European directives such as the Corporate Sustainability Due Diligence Directive (CSDDD).

Scope: Upstream (supply chain)

Time horizon: Planned (future)

Resources: Not quantified

Nature-Based Solutions Projects (Under Exploration)

Description: Exploring potential reforestation projects that serve a double purpose:

• Decarbonisation and obtaining carbon credits
• Strengthening social impact in communities where Gestamp is active

Projects such as reforestation stand as nature-based solutions that protect, restore and sustainably manage the ecosystem in the vicinity of industrial plants.

Scope: Own operations and local communities

Time horizon: Under exploration/evaluation

Resources: Not quantified

Expected outcomes: Protect, restore and sustainably manage ecosystems; promote significant social impact

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Note on Compensation Measures: No compensation measures were implemented in 2024, as no direct impacts of Gestamp's own activity on biodiversity and ecosystems were identified that required compensation.

Note on Targets: Company is considering setting targets aligned with the Kunming-Montreal Global Biodiversity Framework under the Convention on Biological Diversity (CBD) and other biodiversity-related strategic frameworks.

Impact metrics related to biodiversity and ecosystems change

Sites in or near protected areas

In 2024, a geolocation analysis was conducted to determine the proximity of infrastructure to protected areas, in view of the network of protected areas set out in Natura 2000, IUCN, Emerald Network and USA Wetlands.

58% of the Group's plants are located near (< 5 km) or adjacent to protected areas.

10 plants are located in protected areas designated as Special Areas of Conservation (SAC) and Special Protection Areas for Birds (SPA) within the Natura 2000 Network, among others.

Protected areas near Gestamp plants

Species impact metrics

A biodiversity study detected the presence of endangered species in areas close to 3 plants.

Impact assessment

Despite the proximity to protected areas, and in light of the nature of Gestamp's production processes, there was no material impact on biodiversity or on the status and extent (including land use) of ecosystems located in areas where the Group is active.

Gestamp's production processes were found to have no material impact on endangered species or on other species not included in recognised threat categories.

Methodology

Metrics are based on a combination of sources: primary data, secondary data and geospatial models built from GIS data. Parameters are identified and updated through geospatial analysis, using geographic information systems (GIS) and nature databases. A detailed biodiversity study has been carried out by Gestamp, and data provided by the plants is gathered.

8 plants located in Argentina, Brazil, China, Spain, France, Mexico and Portugal have strict action and control mechanisms where industrial surface treatment processes and water discharges into public watercourses occur.

Policies related to resource use and circular economy

The document references E5-1 (Policies related to resource use and circular economy) on page 184, but the provided excerpts do not contain the actual content of that page. The excerpts only show:

• A table of contents/index structure indicating that E5-1 policies should be disclosed on page 184
• Cross-references to E5-1 in the context of Law 11/2018 compliance mapping
• References to related disclosure requirements (E5-2, E5-3, E5-4, E5-5) covering actions, targets, resource inflows and outflows

The excerpts mention measures related to circular economy including:

• Prevention, recycling, reuse, other forms of waste recovery and disposal (pages 186-193, 194-199)
• Consumption of raw materials and measures to improve efficiency of use (pages 193-194, 148, 151, 186-190)

However, no specific named policies related to resource use and circular economy are disclosed in the provided excerpts. Without access to page 184 where E5-1 is indicated to be located, the actual policy content cannot be extracted.

Actions and resources related to circular economy

Strategic acquisition and collaboration

Gescrap Group acquisition (2022)

• Action: Acquisition of 33% of the Gescrap Group in 2022
• Scope: Own operations and upstream value chain
• Objective: Strengthen the availability of secondary raw materials and take a significant step towards circularity in the business model
• Outcomes:
  • More efficient control over the management of metals
  • Improved traceability
  • Driving integration of metals into the production of low-emission steel with high content of recycled material
  • Ensures greater availability of high-quality scrap suitable for the automotive sector
  • Through advanced waste management processes, optimises the use of secondary resources
• Current status: Currently, the recycled content used by Gestamp for the manufacture of components is 33%

Development of circular business model

Use of own scrap as secondary raw material

• Action: Prioritising the use of own scrap as a secondary raw material in the production of low-emission steel
• Scope: Own operations
• Objective:
  • Reduce the extraction of raw materials such as steel and aluminium (Gestamp's main resource outlets)
  • Optimize waste management
  • Promote more sustainable practices

Industry 4.0 integration

• Action: Integration of Industry 4.0 model with circularity principles
• Scope: Own operations
• Key features:
  • Digitalisation and data analysis to enable optimisation at every stage of the product life cycle
  • Waste reduction and efficient use of materials in processes such as hot stamping
  • Virtualisation of production lines for accurate simulations to reduce energy consumption and use of raw materials
  • Real-time connection between machines, systems, products and people to improve traceability
  • Foster continuous improvement, promoting reuse and recycling of materials

Material consumption reduction

Identification and implementation of good practices

• Action: Working to reduce consumption of steel, aluminium, and auxiliary materials by identifying and implementing good practices
• Scope: Own operations
• Context:
  • Steel and aluminium are the raw materials most used in production processes, respectively accounting for 96% and 3% by weight of total materials consumed
  • Products such as oil, paint and chemical products represent 2% of total consumables

Strategic alliances for closing the loop

Closing the loop projects

• Action: Strategic alliances that promote closing the loop projects
• Scope: Value chain
• Objective: Increase the use of recycled materials
• Key partner: Gescrap as a key player

Future agreements

Low-emission steel agreements

• Action: Agreements for the future regarding recycled steel or low-emission steel
• Status: A specific amount has not yet been identified
• Time horizon: Future (dates not specified)

Data collection and monitoring

Environmental information tool

• Action: Use of internal tool for collection of environmental information
• Process: Plant environmental managers incorporate information with evidence, supervised and consolidated at corporate level
• Scope: 90.4% of the companies in the Group's Financial Statement perimeter

E5-4: Resource inflows

Gestamp discloses the materials used to manufacture its products in 2024. The company reports the total weight of materials consumed and provides a breakdown by material type.

Materials used to manufacture Gestamp's products

Scope: The scope of the information is 90.4% of the companies in the Group's Financial Statement perimeter.

Recycled content: Currently, the recycled content used by Gestamp for the manufacture of components is 33%.

Methodology and data quality

For the collection of environmental information, an internal tool is used through which the plant's environmental managers incorporate the information with its respective evidence. This is supervised and consolidated at the corporate level.

Note on recycled steel: As regards recycled steel or low-emission steel, Gestamp has agreements for the future and a specific amount has not yet been identified.

Note on biological materials: In 2024, the Group did not have direct consumption of renewable fuels such as biomass, hydrogen or biogas. However, this is an aspect that it is currently studying in order to achieve its decarbonisation objectives.

Resource outflows

Gestamp continuously endeavours to develop lighter vehicles and prioritises weight reduction research. This is one of the most demanded requirements in the automotive industry due to the need to improve fuel efficiency and reduce CO2 emissions. Chassis and bodywork components are essential for achieving emissions targets, as they make up around 70% of total vehicle weight.

As part of the industry's move towards electrification, the extra weight in vehicles from batteries has further increased the importance of lightweighting. Weight affects the range of electric vehicles, and until full decarbonisation of the electricity grid takes place, its consumption will continue to play an important role in the CO2 emissions of vehicles during the use phase.

Gestamp provides innovative solutions to offer the best weight reduction results and meet the most stringent industry requirements. Extensive experience in hot stamping technology and the development of multi-material solutions have given rise to several alternatives for achieving lighter vehicles.

In order to take account of the environmental impact of factors like weight reduction, product life cycle analysis (LCA) is carried out as a strategic part of the design phase. The carbon footprint of each process carried out at Gestamp and the materials used in production are some of the main variables included in the analysis. It has been found that lightweighting and using a smaller amount of raw materials are two of the factors with the biggest influence on reducing the carbon footprint.

Gestamp is developing new hot stamping products, such as extreme size parts, to improve safety performance, include more features and reduce assembly time for customers. The company has developed a wide range of bodywork products to increase BEV safety and protect passengers should a collision occur.

Product durability and performance: Gestamp designs and manufactures parts seeking to achieve sufficient rigidity in order to reduce the level of torsion under stress. Comfort and durability are important aspects taken into account during product development. The company focuses on innovative design approaches to deliver the best high-performance products, including increasing service life by means of design and minimising weight through in-house optimisation tools.

No specific percentages of recyclable components, recycled content percentages, warranty periods, repairability scores, or spare parts availability are disclosed.

Policies related to own workforce

Gestamp has defined six key policies related to its own workforce, all developed in accordance with the Code of Conduct:

Human Rights Policy

IRO coverage: PPR3, PPR4 and PPR9

Scope: All employees of the Gestamp Group, as well as subcontractors, suppliers, partners, and collaborators

Governance:

• Approved by the Group's Board of Directors
• The Sustainability Committee, together with the ESG Department, supervises the functioning of the policy and monitors implementation

Key content/principles: Gestamp is committed to respecting the human rights recognised in international reference frameworks:

• United Nations International Bill of Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work and its fundamental conventions
• OECD Guidelines for Multinational Enterprises
• Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy
• UN Guiding Principles on Business and Human Rights
• UN Global Compact

Basic principles of action include:

• Prohibition of child labour
• Eradication of forced labour, human trafficking, and modern forms of slavery
• Non-discrimination
• Fair wages and benefits
• Respect for working hours
• Respect for the right to union association and collective bargaining
• Protection of migrant workers' rights
• Protection of local communities' rights
• Safety of products and services
• Environmental conservation
• Abstention from purchasing minerals from conflict zones

Public availability: Available on the Group's corporate website

International standards: Explicitly aligned with UN International Bill of Human Rights, ILO fundamental conventions, OECD Guidelines for Multinational Enterprises, Tripartite Declaration, UN Guiding Principles on Business and Human Rights, and UN Global Compact

Due diligence process: Gestamp has established a due diligence mechanism to:

• Define the company's public commitment
• Identify and assess any real or potential risks of human rights violations
• Prevent and mitigate impacts on workers regarding forced labour, child labour, non-discrimination, freedom of association, occupational health and safety, community impact, employment and working conditions, corruption and bribery, company products, and supply chain management
• Establish measures to remedy or compensate for potential violations
• Foster transparency and proper communication
• Ensure proper monitoring and review of risks and measures
• Periodically monitor progress and efficacy of measures

In countries where national laws may conflict with respect for human rights, precise risk control and mitigation measures shall be established without violating the laws in force.

Equality, Diversity and Inclusion Policy

IRO coverage: PPR6 and PPR8

Scope: All organisational areas, all members of the governing bodies and to the workforce who are contractually bound to the companies comprising the Gestamp Group

Governance:

• Approved by the Company's Board of Directors, following a proposal by the Sustainability Committee
• Gestamp Group's Equality, Diversity and Inclusion Committee is responsible for interpreting this Policy
• Each Management Division shall actively foster the dissemination of the Policy and be responsible for creating, implementing and ensuring compliance with Equality Plans

Key content/principles: Achieves a positive environment that facilitates and encourages equal opportunities, non-discrimination, diversity and inclusion for all employees. Aligned with SDG 5 on Gender Equality and SDG 10 on Reduced Inequality.

Public availability: Available on Gestamp's corporate website

International standards: Aligned with UN Sustainable Development Goals (SDG 5 and SDG 10)

Monitoring: Each Management Division ensures long-lasting implementation of the Policy and must ensure compliance with Equality Plans in their scope of action

Hiring Policy

IRO coverage: PPR6, PPR8 and PPR10

Scope: All new hires made at Gestamp for structural and indirect labour positions

Governance: Approved by the Human Resources Department (the body ultimately responsible for the policy)

Key content/principles:

• Standardise the key elements of all hiring processes at Gestamp Group in terms of phases, milestones and responsibilities
• Ensure hiring processes are effective and uniform
• Guarantee each new hire is a perfect fit in the position and in the Organisation
• Avoid discrimination of any kind based on gender, race, nationality or religion during hiring processes

Public availability: Confidential and for the exclusive use of the Human Resources area

Monitoring: KPIs and metrics have been established and are displayed in a dashboard to enable monitoring of quality of hiring processes

Training and Development Policy

IRO coverage: PPR2 and PPR6

Scope: All Gestamp employees (including staff, direct and indirect workforce) and external employees according to the labour legislation of each country

Governance: Approved by the Human Resources Department (the body ultimately responsible for the policy)

Key content/principles:

• Lays the groundwork for all training systems at Gestamp in terms of phases, milestones and responsibilities
• Guarantee a sound, effective process for knowledge acquisition and transfer
• Respond to current and future needs of the business
• Avoid discrimination based on race, religion, sex, age, nationality, sexual orientation, gender identity, marital status or disabilities throughout learning and development processes

Public availability: Available to the training and development area. Specific training on the policy is made available to all Managers through Global Learning

Monitoring: Each year, the Corporate Training and Development area sets a schedule for follow-up meetings with the local Training and Development areas to review and supervise compliance with the policy

Fixed and Variable Remuneration Policy

IRO coverage: PPR8 and PPR10

Scope: All Gestamp employees

Governance: Approved by the Human Resources Department (the body ultimately responsible for the policy)

Key content/principles: Defines the structure, management model and governance of short-term fixed and variable remuneration:

• Fixed pay: comprising basic salary paid for skills, experience and responsibilities, bearing in mind the level and scope of position, including wage supplements
• Variable pay: aimed at rewarding employees' efforts, aligning interests and competitiveness with the market, including:
  • Financial goals (50% weighting)
  • Strategic goals (25% weighting), including goals of the 2023-2025 Strategic ESG Plan (12.5% weighting)
  • Individual goals (25% weighting)

Public availability: Not specified

Monitoring: The Nomination and Compensation Committee assesses achievement of goals to determine variable amounts

Health and Safety Policy

IRO coverage: PPR1, PPR5 and PPR7

Scope: Entire Gestamp Group

Governance:

• Approved by the Board of Directors
• The Sustainability Committee verifies compliance and monitors the Health and Safety Policy
• Corporate Health and Safety Department supervises and supports local H&S teams
• Each plant manager is the highest official responsible for Health and Safety at each production centre

Key content/principles:

• Commitment to the safe behaviour of all Gestamp employees and subcontracted workers
• Continuous improvement of the Health and Safety Management System
• Compliance with legal requirements and other subscribed requirements
• Objectives and targets definition, monitoring and review
• Risk assessment and implementation of preventive and corrective measures
• Training and awareness
• Employee participation and communication
• Integration of new technology to reduce risks
• Emergency preparedness

Public availability: Available on the Group's website

International standards: The policy framework is based on ISO 45001 and OHSAS 18001 standards. In 2024, 99% of plants (34 out of 45) have ISO 45001 certification

Monitoring:

• Corporate Health and Safety Department conducts periodic evaluations
• Internal and external audits verify compliance
• Key performance indicators tracked: Health and Safety Indicator (HISM), Health and Safety Management Index (WC), accident frequency rate reduction target (-5% by 2025 vs 2021 baseline)
• The Sustainability Committee monitors objectives

Taking action on material impacts on own workforce

Gestamp has identified positive material impacts on its own workforce and has not identified any material negative impacts in 2024. The company has devised training programmes, health and safety courses, and promotes diversity, equality and inclusion throughout the company.

Talent Management and Internal Promotion

Action: Talent Pool and Internal Promotion Programme

• What it does: Created a talent pool of highly trained professionals to increase internal promotion rates
• Scope: Own operations (Group-wide)
• Outcomes: Internal promotion rate in 2024 reached 92% for division directors and country managers, and 80% for Plant Managers (4 percentage points higher than 2023)
• KPIs: Internal promotion rates tracked by role level
• Link to policy: Training and Development Policy

Action: GTalent Model - Performance and Potential Assessment

• What it does: Identifies talent through combination of performance and potential assessment, reviewed annually by heads of organization and HR teams
• Scope: Own operations (all employees classified as structure labour and indirect labour with teams under supervision)
• Time horizon: Annual cycle
• Outcomes: 95% success rate achieved in 2024
• Coverage: 20% of men and 27% of women in workforce included in 2024

Performance Appraisal System

Action: Waterfall Goal-Setting Meritocratic Performance System

• What it does: Links employee performance to achievement of Group strategic objectives through individual goals, personal improvement goals, and leadership skills evaluation
• Scope: Own operations
• Time horizon: Annual cycle (goals set at start of year, evaluated at end)
• Expected outcomes: Increased transparency, clearer expectations, alignment of individual work with strategic objectives
• Link to variable remuneration:
  • Financial goals: 50% weighting
  • Strategic goals (including ESG): 25% weighting
  • Individual goals: 25% weighting

Group-Wide Training Programmes

Action: LinkedIn Learning Training Catalogue

• What it does: Online learning platform with over 16,000 courses in 13 languages accessible from any device
• Scope: Own operations (Group-wide)
• Time horizon: Launched after pilot in 2023, ongoing in 2024
• Resources: Partnership with LinkedIn Learning
• Content focus: Generative Artificial Intelligence, agile project management methodologies

Action: Gestamp Talks - Synchronous Virtual Training

• What it does: Webinars bringing together employees worldwide to share knowledge on strategic subjects
• Scope: Own operations (global)
• Time horizon: Ongoing in 2024
• Topics covered: Large Structural Casting, New Hot Stamping Technologies, High Pressure Die Casting, costs linked to lack of quality

Action: New Technologies Knowledge Transfer Model

• What it does: Closes knowledge gap between Innovation and Industry 4.0 teams and the plants
• Scope: Own operations
• Resources: Technological Knowledge Transfer Committee with business representatives, assisted by training and development team
• Focus areas: Electric vehicles, Industry 4.0, Factory 21 concept
• Link to policy: Training and Development Policy

Action: Electric and Hybrid Vehicle Training

• What it does: Training on new structures and platforms for hybrid and electric vehicles
• Scope: Own operations
• Time horizon: First edition implemented in 2024 (25 participants), global deployment planned for 2025
• Resources: Collaboration between training team and Office of Technology and Innovation (TIO)
• Link to targets: ESG Plan target of 5-6 training programmes in digitalisation and EV

Action: Intensive Hot Stamping Training

• What it does: Provides foundation and expanded knowledge on hot-stamping technology, emphasizing large pieces like door rings and one-piece floors
• Scope: Own operations (hot stamping plants)
• Time horizon: Four editions launched in 2024
• Target participants: Process engineers, quality engineers, maintenance managers, tooling managers

Action: Data Engineers Talent Attraction and Development Programme

• What it does: Attracts and develops young professionals as Data Engineers
• Scope: Own operations
• Time horizon: 2024
• Resources: 180 hours total programme duration; external provider delivery with internal monitoring; regular progress meetings
• Design: Created by Information Technology team experts

Action: Plant Director Development Programme (Second Edition)

• What it does: Ensures plant directors have right skill levels, global culture, and shared leadership approach
• Scope: Own operations
• Time horizon: Completed in 2024 (second edition)
• Resources: Partnership with Hult Ashridge business school; 6-month personalised coaching process
• Participants: 26 people
• Link to policy: Training and Development Policy

Action: Leadership Development Programme (First Edition)

• What it does: Develops solid foundation in leadership and strengthens skills for future senior roles; focuses on key leadership skills, strategic thinking, and interpersonal skills
• Scope: Own operations (14 countries)
• Time horizon: Launched in 2024 (first edition)
• Resources: Partnership with Hult Ashridge business school
• Participants: 87 participants with different profiles from 14 countries
• Link to policy: Training and Development Policy
• Link to targets: ESG Plan target of 1 development programme for leaders

Action: Promociona Executive Development Programme

• What it does: Develops female talent through executive development
• Scope: Own operations
• Time horizon: Ongoing participation in 2024
• Resources: Partnership with Spanish Confederation of Business Organisations (CEOE)
• Link to policy: Equality, Diversity and Inclusion Policy

Action: Board of Directors Training Programme

• What it does: Training aligned with company strategic objectives covering ESG, Artificial Intelligence, Industry 4.0, and Innovation and Development strategy
• Scope: Own operations (Board level)
• Time horizon: 2024
• Resources: 5 online sessions with e-learning content; Gestamp Global Learning online campus
• Link to targets: ESG Plan target of 1 ESG training opportunity for Gestamp employees

In-Plant Training

Action: Workplace-Based Practical Training

• What it does: Develops knowledge of Group's industrial processes, adapts to technological innovation and customer requirements (safety, weight reduction, sustainable transport)
• Scope: Own operations (all plants)
• Time horizon: Ongoing
• Resources:
  • 2024: 1,019,853 hours delivered
  • 330,719 employee participants
  • Average 22.84 hours per employee
• Delivery: 30% external training (2% more than 2023)

Overall Training Metrics 2024:

• Total training hours: 1,142,192
• Total participants: 439,783
• Average training per employee: 25.7 hours (25.44 men, 26.82 women)
• Scope: 98.4% of Group companies

Remuneration and Benefits

Action: Corporate Remuneration Policy Implementation

• What it does: Manages employee remuneration to attract, motivate and retain professionals; ensures pay structure linked to mission, vision, values and processes
• Scope: Own operations (all employees with individually negotiated earnings)
• Link to policy: Corporate Remuneration Policy
• Principles: Internal equity, external competitiveness, pay for performance, alignment with institutional investor guidelines

Action: Minimum Benefits Programme (in development)

• What it does: Working on proposal to ensure access to minimum level of benefits in all countries, improving employee value proposition
• Scope: Own operations (global)
• Time horizon: In development in 2024
• Focus: Health and wellbeing resources for employees and families
• Current state: Benefits managed locally and vary by country

Health and Safety

Action: Health and Safety Management Services

• What it does: Provides healthy and safe work environment at Gestamp facilities
• Scope: Own operations
• Link to targets: ESG Plan 2023-2025 targets:
  • Health and Safety Index (WC): 35% achieved vs. <45% target (baseline: n/a)
  • Accident frequency rate reduction: 21.4% achieved vs. -5% target (baseline: 2021)
• Link to policy: Health and Safety management services

ESG Plan 2023-2025 Targets Summary

Well-being:

• Health and Safety Index (WC): 35% (target <45)
• Accident frequency rate reduction: 21.4% (target -5% from 2021)

Talent:

• Training programmes in digitalisation and EV: 5 programmes (target 6)
• Development programmes for leaders: 1 (target 1)
• ESG training opportunities: 1 (target 1)

Equality, Diversity and Inclusion (linked to Hiring Policy):

• New hires that are women: 27% (target 27%)
• D&I Plan development: Done (target Done)
• Individuals with functional diversity: 2% (target 3%)

Characteristics of the undertaking's employees

Total headcount and FTE

As of 31 December 2024, the Gestamp Group's workforce (excluding Gescrap) comprised 43,099 employees (43,426 in 2023).

The headcount of Gestión Global de Matricería, S.L. and subsidiaries incorporated into the Group comprised 245 people (2023).

The headcount of Global Laser Araba, S.L. and subsidiaries incorporated into the Group comprised 52 people (2023).

As of 31 December 2024 and 31 December 2023, the Gestamp Group's workforce (excluding Gescrap) comprised the following headcount based on the equivalence between permanent and temporary employees:

Temporary employees are mainly apprentices and staff on maternity/paternity leave cover in some countries, in addition to reinforcements in plants. The total number of employees in each geographic division at 31 December 2024 and 31 December 2023 is as follows:

Headcount by gender

No explicit breakdown by gender for total headcount is disclosed in the excerpts provided.

Headcount by country or region

See geographic division table above (Western Europe, Eastern Europe, Mercosur, North America/NAFTA, Asia).

Headcount by employment contract type

See table above showing permanent (40,867 in 2024; 40,926 in 2023) and temporary (2,232 in 2024; 2,500 in 2023) employees.

Headcount by employment type (full-time/part-time)

Not disclosed in the excerpts provided.

Employee turnover rate / number of employees who left

Not disclosed in the excerpts provided.

New hires (number / rate)

Not disclosed in the excerpts provided.

Scope and exclusions

• Total headcount figures exclude Gescrap subsidiary.
• ESRS S1 Own workforce (except S1-10, S1-14 and S1-16): 98.4% of Financial Statements scope (same scope excluding Gescrap).
• ESRS S1 Own workforce S1-10 and S1-16: 92.0% scope; Turkey included as estimate; apprentices and interns excluded.
• ESRS S1 Own workforce S1-14: 92.0% scope; excluding some offices, production plants and Gescrap.

Characteristics of non-employees in the undertaking's own workforce

Non-employee workers in own workforce

Gestamp reports non-salaried workers as external employees hired through temporary employment agencies (job agencies) and subcontracted employees from outsourced service companies that support the main business activity (outsourcing). The figures represent the average of external contracts during the year.

The scope of the information is 98.4% of the companies in the Group's Financial Statements.

Methodology

• Counting method: Average number of external contracts during the year
• Types included:
  • Temporary employment agency workers (job agencies)
  • Subcontracted employees from outsourced service companies supporting main business activity (outsourcing)
• Coverage: 98.4% of companies in the Group's Financial Statements perimeter

Year-on-year trend

In December 2024, Gestamp had an average reduction of external contracts of 8% compared to the average of the previous year. This is attributed to greater uncertainty in sector demand and reduced activity, resulting in the termination and reduction of externally contracted services.

Training provision

All workers whose workstations are located within a Gestamp establishment receive occupational risk prevention training, including workers from temporary employment agencies.

Collective bargaining coverage and social dialogue

At Gestamp, labour relations are managed in accordance with union and labour legislation that applies to each geographical area. With union representation in each production plant, all aspects relating to union, labour and employee contractual relations are negotiated.

In 2024, 68% of employees were covered by a collective agreement (66% in 2023).

There are specific Occupational Health and Safety Committees in most production plants. In 2024, 95% of the plants had employee consultation and participation mechanisms in place relating to occupational risk prevention (93% in 2023).

In certain geographical areas, where required due to historical, cultural or legal obligations, we have inter-centre committees that complement the in-plant negotiating framework.

The company has a European Committee that represents all of the countries in its scope, and it organises working groups tasked with combating issues relating to sustainability and risk prevention.

Collective bargaining coverage by region

Collective bargaining coverage by country

The scope of the information is 98.4% of the companies in the Group's Financial Statements.

Diversity metrics

Professional categories

Gestamp has defined the following major professional categories:

• Direct labour: employees of production plants directly involved in the processing of raw materials and components into intermediate or finished products
• Indirect labour: employees of production plants whose job is to provide direct support to the production process
• Office staff: any office employee in production plants or service centres

Workforce by labour type and gender

The scope of the information is 98.4% of the companies in the Group's Financial Statements.

Top management diversity

Directors (one and two levels below the administrative and supervisory bodies)

The scope of the information is 98.4% of the companies in the Group's Financial Statements.

Age band distribution

Total workforce by age band

The scope of the information is 98.4% of the companies in the Group's Financial Statements.

Note: Gestamp is adjusting its systems so that information on the following age ranges: under 30, from 30 to 50 and over 50 can be provided in 2025.

Distribution of employees by country, gender and age (2023-2024)

Adequate wages

Benchmark Used

Gestamp conducted an analysis in 2024 to verify that all Group employees receive a salary higher than the legal minimum wage or applicable collective agreement minimum wage.

No living wage benchmark (such as Fair Wage Network, WageIndicator, Anker Methodology, or similar) is disclosed.

Coverage

The analysis covers 92.0% of the consolidation perimeter of the financial statements:

• Turkey is included as an estimate
• Apprentices and interns are excluded
• Excludes some offices, production plants and Gescrap
• Following the methodology defined, the analysis does not include interns, expatriate workers, cases of long-term leave, partial retirement and companies that do not use the SAP HCM system

Geographic Scope

Global scope covering Gestamp Group operations, with specific exclusions noted above.

Finding

After conducting the analysis, Gestamp states that it "ensures fair remuneration as it is above the aforementioned references in every market" (i.e., above minimum wage or collective agreement minimum wage in every market where it operates).

Targets / Commitments

No forward-looking targets or commitments disclosed.

Methodology Details

No methodology for assessing living wage is disclosed. The company confirms compliance with legal minimum wage and collective bargaining agreement floors, but does not describe how these compare to living wage benchmarks or basic living needs in local contexts.

Persons with disabilities

Gestamp is making significant efforts to promote the inclusion of individuals with functional diversity, a particularly relevant challenge in the automotive industry, given its high technical and operational requirements.

The company not only directly hires people with functional diversity, welcoming them into its teams, but also outsources products and services to special employment centres, thus fostering a more inclusive workplace setting. Gestamp also works with local engineers to ensure that its facilities meet accessibility requirements, ensuring adapted workspaces.

Number of employees with functional diversity

Scope: 98.4% of the companies in the Group's Financial Statements.

Multi-year comparison:

• 2024: 832 employees with functional diversity
• 2023: 952 employees with functional diversity
• 2022: 941 employees with functional diversity

Note: This figure does not include employees with functional diversity subcontracted through special employment centres, as they are not direct employees. Across the Group, a total of 302 subcontracted individuals with functional diversity were employed.

Training and skills development metrics

At Gestamp, performance appraisals and the professional development of our employees are essential factors in fostering a culture of excellence and continuous growth. Over the past year, 22% of salaried employees participated in periodic performance and professional development evaluations under the GTalent model.

Performance and career development review coverage

Broken down by gender:

• Men: 20%
• Women: 27%

These studies reflect our commitment to equal opportunities and the comprehensive development of all our employees.

Training hours

In 2024, Gestamp carried out a total of 1,142,192 hours of training. The number of participants in training activities was 439,783 and the average training per employee was 25.7 hours (25.44 men and 26.82 women).

Scope: 98.4% of the companies in the Group's Financial Statements.

Average training hours by gender

• Men: 25.44 hours
• Women: 26.82 hours

In-plant employee training

During the 2024 financial year, Gestamp's plants continued to focus on staff training and development, delivering a total of 1,019,853 hours of training. A total of 330,719 employees took part in this training, with each employee completing an average of 22.84 hours of in-plant training.

Scope: 98.4% of the companies in the Group's Financial Statements.

Note: 30% of training hours in 2024 were external (2% more than in 2023).

Professional category abbreviations:

• MOD: Direct labour
• MOI: Indirect labour
• MOE: Regular Labour

Total investment in training: Not disclosed.

Health and safety metrics

Coverage of health and safety management system

The Gestamp Health and Safety System (GHSS) management system is integrated at all organisational levels and implemented in 100% of the production plants under Gestamp's management, which represents 100% of Gestamp's total workforce.

Fatalities

Zero fatal accidents have been recorded at Gestamp facilities since 2017. For another consecutive year, there have been no fatal accidents or deaths related to occupational diseases within the Gestamp Group in 2024.

Work-related accidents and injury rates

By gender (2024):

Days lost to work-related injuries

Scope: The scope of the health and safety information is 92% of the companies in the Group's Financial Statements.

Methodology notes:

• Frequency Rate = Number of occupational accidents with sick leave and diseases per 1,000,000 hours worked (including own employees and subcontracted workers). Also known as the rate of recordable accidents at work.
• Severity Rate = Number of work days (M-F) lost due to occupational accidents or diseases per 1,000 hours worked (including own employees and subcontracted workers).
• Accidents recorded include those with sick leave. Does not include commuting accidents.
• Occupational disease: contracted as a result of exposure to risk factors inherent to work activity and reported by a doctor.

Work-life balance metrics

Flexibility and work-life balance measures

Given the nature of the business, at Gestamp's production plants, groups classified as Direct and Indirect Labour have to work in shifts. However, Gestamp promotes shift rotation with the aim of facilitating the adjustment of working hours to workers' specific needs.

For office-based workers in many regions, remote work measures have continued to be employed, in addition to other measures that promote flexibility and a good work-life balance, such as flexible working hours.

Transitional provision applies

The company's disclosure reference table indicates that transitional provision applies to S1-15 Work-life balance metrics. Quantitative metrics for:

• Percentage of employees entitled to family-related leave (by gender)
• Percentage of entitled employees who took family-related leave (by gender)
• Return-to-work rates after parental leave (by gender)

are not disclosed in the extracted excerpts.

Compensation metrics (ESRS S1-16)

Pay gap

The gender pay gap is the clearest indicator in terms of methodology when analysing the difference in salary between men and women. This is calculated by subtracting the average gross hourly pay level of male employees from the average gross hourly pay level of female employees, divided by the average gross hourly pay level of male employees; the result of the formula is multiplied by 100 to determine the percentage.

The average hourly pay level takes into account the concepts of fixed salary plus variable remuneration raised to full-time and annualised. The calculation per country takes into consideration the relative size of each country by dividing it among all eligible employees. This allows us to achieve a reliable global indicator of the difference in salary between men and women.

The result of the pay gap calculation is 6.23% for total remuneration (fixed remuneration plus variable remuneration) for 2024.

If we exclude the effect of Turkey's considerations, the Gestamp Global Gap is:

• 2024: 6.08%
• 2023: 6.66%

Remuneration ratio

The ratio between the total annual remuneration of the person with the highest salary and the average total annual employee remuneration is 37.

Methodology and scope

To calculate the salary references indicated in this report, the active workforce as of December 31, 2024 corresponding to 21 countries (Argentina, Germany, Brazil, China, Korea, Slovakia, Spain, United States of America, France, Hungary, India, Italy, Japan, Mexico, Poland, Portugal, Czech Republic, Russia, Sweden, Taiwan and the United Kingdom) has been used as a basis. Additionally, the country of Turkey has been included based on an estimate of the 2023 pay gap data (most up-to-date information) provided by the official body Turkstat and weighted by the number of Gestamp employees for the geography. In this way, 92% of Gestamp's workforce (excluding apprentices and trainees) would be covered by the analysis.

The calculation is made using the theoretical annual remuneration, extrapolated to full-time hours. This information is automatically extracted from the SAP HCM system. To reaffirm the quality of the data and review of eligible employees, all information has been validated with the local HR teams.

The calculation methodology has been revised based on the update of the applicable regulations; consequently, the 2023 gap data has been updated based on this new methodology.

The method compares employees in positions with the same level of remuneration according to the Gestamp classification system (G3S). The levels of remuneration are used to define the salary bands. This allows the policy to be linked to objective criteria and guarantees there is no discrimination of any kind.

Average remuneration by professional category and gender (including Turkey estimates)

Average remuneration by professional category and gender (excluding Turkey)

Scope: 84% of the Gestamp Group workforce (excluding Turkey). In order to compare remunerations, the exchange rate at the end of the year has been applied. The differences between the salaries of men and women are due to the distribution by country and its differences in local markets, cost of living and exchange rates.

Incidents, complaints and severe human rights impacts

Gestamp maintains channels for reporting incidents and complaints. The Speak Up Line channel is available to employees and other individuals related to the Group, who are informed about how to use it in mandatory training sessions. Reports are investigated promptly, applying the principles of confidentiality, non-retaliation and protection of personal data. If a violation is confirmed, the competent internal bodies impose penalties.

Communications and reports received (2024)

Status of communications

At 31 December, 83% of the received communications had been closed.

Actions taken as a result of investigations

As a result of the investigations carried out in response to the reports, appropriate measures have been taken when deemed necessary, including:

Human rights due diligence

In 2024, Gestamp strengthened its commitment to human rights by undertaking a comprehensive review of its due diligence procedure in line with the standards set in the Corporate Sustainability Due Diligence Directive (CSDDD). The review represents the first step in an ongoing process that will continue in the coming years, with a focus on identifying critical points in the value chain where significant risks could arise related to child labour, forced labour, gender equality, fair labour conditions and access to health and safety.

Policies related to value chain workers

Gestamp has implemented diverse policies and requirements applicable to all of the company's suppliers to guarantee optimal working conditions and quality of life for workers in the value chain.

ESG Requirements for Suppliers

Scope:

• All suppliers must accept these requirements
• Applies to workers in the value chain

Key content:

• Ethics standards
• Human rights standards
• Environmental protection standards
• Ensures suppliers meet Gestamp's standards in these areas

Monitoring and implementation:

• Automatic ESG risk assessment of all suppliers based on international standards set by benchmark organisations, aligned with sector and geographic scope
• Supplier self-assessment questionnaire for certain suppliers covering ethical, social and environmental issues
• Suppliers must respond and upload proof to enable risk classification
• Specific questions on diversity and inclusion
• Specific questions on conflict minerals for suppliers in relevant regions or sectors
• Digital platforms for supplier relations: Ariba, GoSupply, and Fullstep QA
• Supplier management system that analyses and identifies risk variables with monitored mitigation and contingency plans

Code of Conduct

Scope:

• Applies to suppliers and their employees, contractors and assignees

Key content:

• Ethical standards that must be complied with by suppliers
• Referenced in general conditions for hiring

Monitoring:

• Whistleblowing Channel allows workers in the value chain to report concerns regarding possible breaches of the Code of Conduct and other internal regulations or applicable legislation (including social or human rights aspects)

General Conditions for Hiring

Scope:

• All suppliers must accept before entering into any commercial relationship
• Applies to supplier employees, contractors and assignees

Key content:

• Suppliers must comply with applicable legislation in tax, employment, social security, health and safety in the workplace, and environment
• Suppliers performing activities at Gestamp installations must comply with Gestamp's policies on Health and Safety in the Workplace and the Environment
• Suppliers must comply with the Gestamp Group Code of Conduct
• Suppliers must not request or encourage employees to commit illegal acts or violations of the Code of Conduct
• Suppliers must report any reasonable evidence of violations

Occupational Risk Prevention Training

Scope:

• All workers whose workstations are located within a Gestamp establishment
• Includes workers from temporary employment agencies

Key content:

• Mandatory training on occupational risk prevention for all workers at Gestamp sites, including value chain workers

Links to international standards

The policies reference:

• UN Guiding Principles on Business and Human Rights
• OECD Guidelines
• ILO fundamental conventions 1 to 8
• International standards set by benchmark organisations for ESG risk assessment

Taking action on material impacts on value chain workers

Gestamp refers to its supplier management activities as applicable to value chain workers. The disclosure references section S3-4, which states: "As with workers in the value chain, the activities described in S2-4 can also be applied to affected communities."

Supplier Homologation System

Description: Assessment and approval process evaluating ESG risk of suppliers, including aspects related to value chain workers.

Scope: Upstream value chain

Actions and Performance:

• Supplier homologation system implemented with ESG rating criteria
• Percentage of suppliers scored more than 50% in ESG rating: 68% (2023), 70% (2024)
• Training activities provided to suppliers with low ESG rating: 3 (2023), 4 (2024)
• Supplier audits including ESG aspects: 66% (2023), 100% (2024)
• Inclusion of ESG specifications in supplier agreements: Under development (2023), Done (2024)

Resources: Not quantified. Data compiled by purchasing department.

Expected outcomes/KPIs:

• ESG rating scores for suppliers
• Number of training activities delivered
• Percentage of audited suppliers
• Implementation of ESG contract specifications

Policy linkage: ESG Policy, Conflict Minerals Policy, ESG supplier requirements (referenced in water section ARM1)

Quality Audits

Description: Quality audits in which ESG aspects have been reviewed.

Scope: Upstream value chain (suppliers)

Performance: 100% of supplier audits included ESG aspects in 2024.

Note: The company states it has targets aligned with supplier assessment and approval as described in section G1-2, and references the ESG Plan 2023-2025, though specific quantified resources allocated to value chain worker actions are not disclosed.

Targets related to value chain workers

Gestamp does not have measurable results-oriented targets for workers in the value chain. However, the Group is currently devising a new ESG Plan in which all aspects considered material will be reviewed, taking into account the segment of the value chain in which they are deemed material.

On the other hand, Gestamp has established specific targets for managing its suppliers, thus ensuring that the effectiveness of their policies is tracked; these targets are disclosed in Requirement E2-3.

Disclosure Requirement SBM-1 describes the process involved in developing the 2025 ESG Plan and its connection to the different stakeholders.

Policies related to affected communities

Gestamp's sustainability statement references ESRS S3-1 requirements on pages 260 and 202. The company indicates alignment with political commitments on human rights and states that no significant non-compliances have been identified with the UN Guiding Principles on Business and Human Rights, ILO principles, and OECD Guidelines in Gestamp's own activity.

However, the excerpts provided do not contain specific named policies dedicated to affected communities, nor do they detail policy scope, governance, key principles, or public availability specific to this stakeholder group. The statement cross-references general policy information across pages 202-209, 248-252, 259-260, 264-266, and 276-277, but these specific sections are not included in the excerpts.

Compliance and Standards

• The company references compliance with the UN Guiding Principles on Business and Human Rights, ILO principles, and OECD Guidelines
• No significant non-compliances have been identified in Gestamp's own activity
• No significant negative impacts on affected communities have been identified (referenced under ESRS S3-4)

Taking action on material impacts on affected communities

No specific actions, programmes, projects or initiatives are disclosed in the provided excerpts.

The excerpts contain only cross-reference table entries indicating:

• Page reference to ESRS S3-4 (page not specified in excerpts)
• Statement that "No significant negative impacts have been identified" in relation to human rights issues and incidents (ESRS S3-4 paragraph 36)

No information is provided regarding:

• Named actions or programmes
• Scope of interventions
• Time horizons
• Resources allocated (financial or non-financial)
• Expected outcomes or KPIs
• Links to policies or targets

Policies related to consumers and end-users

Gestamp has disclosed policies related to consumers and end-users as part of its ESRS S4-1 reporting. The company references this disclosure requirement on page 276 of its sustainability statement.

Data Protection Policy

Key content and principles:

• Aligned with the General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)
• Sets out guarantees and principles, as well as the main obligations and rights in terms of personal data protection at Gestamp Group companies
• Core of Gestamp Group's commitment to the protection of the fundamental rights and freedoms of natural persons and, in particular, their right to personal data protection
• Adapted to local laws in regions beyond the scope of application of the GDPR

Scope:

• Applied across all regions in which Gestamp operates, is present and/or conducts personal data processing activities
• Standards based on GDPR are stricter than national regulations in several regions

Link to international standards:

• Aligned with the General Data Protection Regulation 2016/679 (GDPR)

Implementation and monitoring:

• Risk assessment of corporate applications that process personal data to evaluate security measures
• Privacy impact assessments (PIA) procedure to determine risk level and establish appropriate control measures
• Face-to-face training sessions for corporate services employees who regularly work with personal data
• Online data protection training course available to all employees free of charge and accessible at any time
• Continual implementation of mechanisms to ensure personal data remain secure and prevent tampering, loss, or unauthorised processing or access

General Information Security Policy

This policy is referenced in the list of corporate policies but no detailed content is provided in the excerpts related to consumers and end-users.

Cybersecurity governance programme

While not explicitly named as a standalone policy, Gestamp describes a comprehensive cybersecurity governance programme:

Key content and principles:

• Built on the need to protect company data and safeguard the supply chain and business continuity processes
• Mission to protect the group's reputation and be a trusted partner for customers
• Ensure governance and secure practices across the entire group
• Strategic Cybersecurity Plan built on risk management with periodic updates, based on international standards and best practices

Scope:

• All plants worldwide (physical and logical security)

Governance:

• Policies and strategy set out by the IT department in cooperation with business units
• Aligning the programme with business objectives

Link to international standards:

• Based on international standards and best practices
• Body of cybersecurity designed according to best practices, standards and regulations

Implementation and monitoring:

• 24/7 incident response support and monitoring services
• Qualified staff overseeing execution of tasks and initiatives
• Specialist technical teams, tools and processes for both physical and logical security
• Joint efforts with major suppliers and relevant companies experienced in cybersecurity

Business conduct policies and corporate culture

Gestamp has implemented a comprehensive governance and business conduct framework aligned with international standards including the UN Global Compact, UN Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises.

Code of Conduct

Policy name: Code of Conduct

Scope: All organizational areas, all members of governing bodies, and all employees contractually bound to Gestamp Group companies (Gestamp Automoción, S.A. and subsidiaries where it holds controlling interest). Also applicable to suppliers and third parties.

Approval and oversight:

• Approved by the Board of Directors (current version approved 7 May 2018)
• Ethics Committee oversees implementation and compliance
• Audit Committee supervises the Code, operation of the reporting channel, and Criminal Risk Prevention Model

Key content/principles:

• Based on Corporate Principles and the Ten Principles of the UN Global Compact relating to human rights, labour standards, environmental standards and fight against corruption
• Rules of Conduct covering integrity in the workplace (health and safety, discrimination, harassment, respectful working environment, equal opportunities, freedom of association)
• Integrity in supply chain (conflicts of interest, supplier practices, corruption prohibition, political activity restrictions)
• Integrity regarding shareholders and business partners (data handling, privacy, asset protection)
• Environment and community commitment
• All interactions with suppliers must meet ethical standards

Public availability: Available on Gestamp's corporate website (www.gestamp.com) and intranet in 18 languages

Link to international standards:

• UN Global Compact Ten Principles
• UN Guiding Principles on Business and Human Rights
• UN International Bill of Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Monitoring implementation:

• 100% of employees receive mandatory training (online via Gestamp Corporate University or face-to-face)
• All employees affirm awareness of the Code during training
• Ethics Committee ensures implementation
• Whistleblowing channel (SpeakUp Line) available 24/7 in all Group languages
• Regular reporting to Audit Committee
• In 2024, 189 communications received via SpeakUp Line (breakdown by category provided)
• 83% of communications closed by year-end
• Disciplinary measures taken when violations confirmed (8 dismissals, 6 suspensions, 17 written cautions in 2024)

Human Rights Policy

Policy name: Human Rights Policy

Scope: All Gestamp Group employees, subcontractors, suppliers, partners and associates

Approval and oversight:

• Approved by the Board of Directors
• Sustainability Committee and ESG Department supervise functioning and monitor implementation

Key content/principles:

• Prohibition of child labour
• Eradication of forced labour, human trafficking, and modern slavery
• Non-discrimination
• Fair wages and benefits
• Respect for working hours
• Respect for right to union association and collective bargaining
• Protection of migrant workers' rights
• Protection of local communities' rights
• Safety of products and services
• Environmental conservation
• Abstention from purchasing minerals from conflict zones
• Due diligence mechanism to prevent, mitigate and remedy negative human rights impacts

Public availability: Available on Gestamp's corporate website

Link to international standards:

• United Nations International Bill of Human Rights (Universal Declaration, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights)
• ILO Declaration on Fundamental Principles and Rights at Work and fundamental conventions
• OECD Guidelines for Multinational Enterprises
• Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy
• UN Guiding Principles on Business and Human Rights
• UN Global Compact

Monitoring implementation:

• Due diligence process identifies real or potential human rights violations
• Risk assessment based on geographical areas and severity
• In 2024, comprehensive review conducted to align with Corporate Sustainability Due Diligence Directive (CSDDD)
• Ongoing process to expand scope to entire value chain
• No significant human rights impacts on Gestamp employees identified
• Whistleblowing channel available

ESG Policy

Policy name: ESG Policy

Scope: Global scope encompassing all geographical regions where the Group operates; extends to entire Gestamp value chain

Approval and oversight:

• Approved by Board of Directors
• Sustainability Department responsible for application, supervised by Sustainability Committee

Key content/principles:

• Principles aligned with business objectives, corporate culture, and UN 2030 Agenda
• Rational and efficient management of natural resources
• Promotion of circular business models prioritizing reuse, recycling and sustainability
• Efficiency in use of resources and low-emission materials
• Use of steel and aluminium with high recycled content
• Development of circular business models
• Appropriate waste management and recovery
• Collaborative value chain with ESG standards
• Promotion of waste hierarchy (prevention, reuse, recycling, recovery, disposal)

Public availability: Available on Gestamp's corporate website

Link to international standards: Aligned with UN 2030 Agenda

Monitoring implementation: Sustainability Department supervised by Sustainability Committee

Environmental Policy

Policy name: Environmental Policy

Scope: Global scope encompassing all geographical regions where the Group operates

Approval and oversight:

• Sustainability Department responsible for application of commitments

Key content/principles:

• Responsible consumption of natural resources, chemicals, raw materials, and water
• Sustainable management and preservation of water quality and natural environments
• Reduction of waste generated in production
• Implementation and maintenance of circular economy model

Public availability: Available on Gestamp's corporate website

Monitoring implementation: Sustainability Department

Equality, Diversity and Inclusion Policy

Policy name: Equality, Diversity and Inclusion Policy

Scope: All organizational areas, all members of governing bodies, and workforce contractually bound to Gestamp Group companies

Approval and oversight:

• Approved by Board of Directors following proposal by Sustainability Committee
• Equality, Diversity and Inclusion Committee responsible for interpretation
• Each Management Division responsible for creating, implementing and ensuring compliance with Equality Plans

Key content/principles:

• Achieve positive environment facilitating equal opportunities, non-discrimination, diversity and inclusion
• People management model committed to professional excellence and quality of life
• Aligned with SDG 5 (Gender Equality) and SDG 10 (Reduced Inequality)

Public availability: Available on Gestamp's corporate website

Link to international standards: UN Sustainable Development Goals (SDG 5 and SDG 10)

Monitoring implementation: Equality, Diversity and Inclusion Committee; Management Divisions ensure long-lasting implementation

Compliance Policy

Policy name: Compliance Policy

Scope: All companies belonging to the Group (majority owned directly or indirectly by Gestamp)

Approval and oversight:

• Approved by Board of Directors
• Board of Directors as ultimate responsible body
• Audit Committee supervises with support from Ethics Committee, Compliance Office, and Regulatory Compliance Unit

Key content/principles:

• Establishes general principles governing Group's Compliance System
• Defines main elements of compliance system
• Regulates composition, powers and responsibilities of bodies involved
• Based on three-lines protocol
• Includes risk assessment, internal policies, communication channels, investigation procedures

Public availability: Referred to in public documents

Monitoring implementation:

• Ethics Committee, Compliance Office and Regulatory Compliance Unit support Audit Committee
• Regular reporting to Audit Committee
• Compliance Office reports to Audit Committee twice yearly on Code of Conduct compliance and effectiveness of Complaints Channel
• Regulatory Compliance Unit reports three times yearly on regulatory compliance initiatives and Criminal Risk Prevention Model

Anti-Corruption and Anti-Fraud Policy

Policy name: Anti-Corruption and Anti-Fraud Policy

Scope: Directors, managers, employees contractually linked to Group companies, and third parties that relate to the Group

Approval and oversight:

• Approved by Board of Directors (17 December 2018)
• Compliance role (Ethics Committee, Compliance Office, Regulatory Compliance Unit) responsible for prevention, detection and management

Key content/principles:

• Strong message of opposition to corruption, fraud and bribery
• Guidelines for action regarding corruption, fraud and bribery, gifts and tokens, donations/aid, political activity
• Develops internal regulations from Code of Conduct
• No political activity or financial donations to political parties

Public availability: Available on Gestamp's corporate website in "Corporate Policies" section

Link to international standards:

• UN Global Compact Tenth Principle
• OECD recommendations
• US Foreign Corrupt Practices Act
• UK Bribery Act

Monitoring implementation:

• Criminal Risk Prevention training included in Board training plan since 2022
• Specific whistleblowing channel category for corruption and bribery
• Regular reporting to governing bodies
• No confirmed corruption or bribery cases in 2024

Third Party Due Diligence Policy

Policy name: Third Party Due Diligence Policy

Scope: Group-wide

Approval and oversight:

• Approved by Board of Directors
• Regulatory Compliance Unit manages implementation

Key content/principles:

• Establishes principles and mechanisms for adequate management of integrity risks
• Compliance with international sanctions regulations
• Due diligence measures for partners, customers and suppliers
• Third-party evaluation procedure

Public availability: Referenced in documentation

Monitoring implementation:

• Third-party evaluation and risk assessment process
• Regular review and updates
• 62.5% of countries have implemented the policy as of 2024 (target: 60% by 2025)

Conflict of Interest Policy

Policy name: Conflict of Interest Policy

Scope: Group-wide

Approval and oversight:

• Approved by Board of Directors
• Develops provisions from Code of Conduct

Key content/principles:

• Mechanisms to prevent and manage possible conflicts of interest
• Identifying, reporting and handling conflicts of interest

Public availability: Referenced in documentation

Monitoring implementation:

• Training course on identifying, reporting and handling conflicts of interest announced in 2024

Internal Information System (IIS) Policy

Policy name: Corporate Internal Information System (IIS) Policy / Internal Information System Policy

Scope: Employees and third parties (suppliers, clients, local communities, etc.) related to the Group

Approval and oversight:

• Approved by Ethics Committee, Audit Committee and Board of Directors
• Board of Directors ultimately responsible for IIS
• IIS Management Procedure approved by Ethics Committee

Key content/principles:

• Details scope, general principles and guarantees for whistleblower protection
• Incorporates EU Directive 2019/1937 and Spanish Law 2/2023
• Guarantees: anonymity, hearing, promptness, confidentiality, independence and impartiality, legality, presumption of innocence, retaliation prohibited
• Tone from the top commitment
• Transparency in publication of statistical data

Public availability: Available on company website and Group Intranet

Link to international standards: EU Directive (EU) 2019/1937; Spanish Whistleblower Protection Law 2/2023

Monitoring implementation:

• Three reporting channels: Human Resources Delegates, Compliance Office Mailbox, SpeakUp Line (external)
• Acknowledgement of receipt sent to whistleblower
• Defined deadlines for receipt, acknowledgement and investigation
• Reports investigated promptly with confidentiality and non-retaliation protections
• Statistical data published in annual reports

Conflict Minerals Policy

Policy name: Conflict Minerals Policy

Scope: All Gestamp Group companies and suppliers

Approval and oversight:

• Corporate Purchasing Department carries out the policy

Key content/principles:

• Acknowledges importance of responsible sourcing
• Commitment to meet international standards
• Corporate responsibility to prevent financing of armed conflict and avert human rights violations
• Measures to disclose/prevent sourcing minerals that could finance armed groups in Democratic Republic of Congo and neighboring countries
• Expects suppliers to implement similar measures and extend to supply chains
• Conflict-free sourcing of products

Public availability: Available on Gestamp's corporate website

Link to international standards: International responsible sourcing standards (referenced)

Monitoring implementation: Corporate Purchasing Department

ESG Requirements for Suppliers

Policy name: ESG Requirements for Suppliers

Scope: All Gestamp Group suppliers, their employees and subcontractors, regardless of country or territory

Approval and oversight:

• Purchasing Management responsible for application
• Developed according to Gestamp Group needs

Key content/principles:

• Mandatory compliance covering human rights, labour standards, business ethics, environmental protection and safety
• Suppliers must ensure neither they nor business partners/suppliers violate human rights
• Principles of UN Global Compact

Public availability: Available on corporate website

Monitoring implementation:

• Supplier approval process includes ESG assessment
• All suppliers undergo automatic ESG risk assessment based on international standards
• Self-assessment questionnaire for certain suppliers
• Specific questions on diversity, inclusion and conflict minerals for relevant regions/sectors

Corporate Governance Policy

Policy name: Corporate Governance Policy

Scope: Gestamp's governing bodies

Approval and oversight:

• Approved by Board of Directors

Key content/principles:

• Framework and principles governing organization and operation of governing bodies
• Compliance with regulations and recommendations on corporate governance
• Board responsibilities include approving sustainability policies, Code of Conduct, Compliance Model, Criminal Risk Prevention Model
• Board monitors internal reporting and control systems including Compliance Model

Public availability: Referenced in public documents

Monitoring implementation: Board of Directors ensures effective functioning

General Conditions for Purchase of Goods and Contracting of Services

Policy name: General conditions for the purchase of goods and the contracting of services

Scope: All suppliers of goods/services to Gestamp

Approval and oversight:

• Purchasing Director highest responsible for implementation

Key content/principles:

• Section 8: Supplier's Obligations with 5 obligations affecting workers in value chain
• Compliance with Tax, Employment, Social Security, Health and Safety, Environmental legislation
• Compliance with Gestamp Health and Safety and Environmental policies at Gestamp installations
• Compliance with Code of Conduct
• Compliance with Principles of Corporate Social Responsibility
• Compliance with UN Global Compact Principles
• Compliance with other internal policies and principles communicated via Supplier Portal
• Supplier must not request employees to commit illegal acts or violate Code of Conduct
• Reporting obligation if violations of Code of Conduct detected

Public availability: Internal; shared with suppliers prior to acquisition

Link to international standards: UN Global Compact (www.unglobalcompact.org)

Monitoring implementation:

• Integral part of any order/contract
• Acceptance required before commercial relationship

Board of Directors' Selection and Diversity Policy

Policy name: Board of Directors' Selection and Diversity Policy

Scope: Board of Directors composition

Approval and oversight:

• Nomination and Compensation Committee formulates the policy
• Board of Directors approves

Key content/principles:

• Ensures Board diversity in composition, expertise and experience including sustainability
• Competency matrix defines knowledge, expertise, experience for Board
• Includes ESG experience as criterion

Public availability: Referenced in governance documentation

Monitoring implementation:

• Nomination and Compensation Committee ensures robust composition with necessary competencies
• Training plans include sustainability sessions

Criminal Risk Prevention Model

Policy name: Criminal Risk Prevention Model (including Criminal Risk Prevention Manual and Protocol)

Scope: Group organizational units across jurisdictions

Approval and oversight:

• Approved and periodically reviewed by Board of Directors
• Regulatory Compliance Unit manages and coordinates
• Audit Committee receives regular reports

Key content/principles:

• Identifies criminal risks associated with Group activities
• Matrix of criminal risks by jurisdiction and controls to mitigate them
• Oversight and monitoring system
• Covers money laundering and terrorism financing despite no legal obligation
• Specific measures to prevent materialization

Public availability: Referenced in documentation

Monitoring implementation:

• Regulatory Compliance Unit monitors operation, effectiveness and compliance
• Periodic verification and modification when needed
• Regular reporting to Audit Committee on risk areas, assessment results, control measures
• Training program for employees exposed to criminal risks
• At corporate level, training for middle managers and above, plus Purchasing, Sales, Treasury, Accounting units
• Plant managers and key plant personnel receive training
• 100% of risk-prone profiles enrolled in general training and corruption/bribery module

Regulations on Gifts and Hospitality

Policy name: Regulations on gifts and hospitality

Scope: Gestamp employees and third parties with commercial/contractual/professional relationships

Approval and oversight:

• Approved by Board of Directors

Key content/principles:

• Regulates exchange of gifts and hospitality
• Establishes appropriate limits and approval flows

Public availability: Referenced in documentation

Monitoring implementation:

• Communication learning pill launched in 2024

Additional governance and oversight mechanisms

Whistleblowing Hotline (SpeakUp Line):

• Available since December 2016
• Managed by external company
• Available 24/7 via telephone, web form, email in all Group languages
• Open to employees, clients, suppliers, collaborators, partners, shareholders, investors, local communities
• Alternative channels: Human Resources Delegates, Compliance Office Mailbox
• Confidentiality and non-retaliation guaranteed
• Reports investigated promptly with protection of personal data
• Disciplinary measures imposed if violations confirmed
• In 2024: 15 communications via delegates, 47 via Compliance Office email, 128 via SpeakUp Line
• 83% of 2024 communications closed by year-end
• Consequences: 8 dismissals, 6 suspensions without pay, 17 written cautions

Training and communication:

• 100% of employees receive Code of Conduct training (mandatory)
• Training via Gestamp Corporate University (online) or face-to-face
• Criminal risk prevention training for employees exposed to risks based on function/hierarchy
• Training includes general part on Criminal Risk Prevention Model and special section on specific risks
• 100% of participants enrolled in corruption and bribery module
• Conflict of interest training course announced in 2024
• Learning pills distributed via email on Third Party Due Diligence Policy and Regulations on Gifts and Hospitality

Disciplinary measures:

• Any breach of Code of Conduct or internal/external regulations results in disciplinary measures
• Measures comply with local labour legislation and collective agreements
• Culture of compliance and ethical behavior promoted throughout Group

The Group manages and mitigates supply chain commodity price risk through various strategies. Steel, followed by aluminium, is the main commodity used in the business.

In 2024, 61.22% of the steel and 83.68% of the aluminium had been purchased through "re-sale" programs with customers (60.43% of steel and 86.64% of aluminium in 2023), whereby the car manufacturer periodically negotiates with the steel maker the price of the steel and aluminium that the Group uses for the production of automotive components. The selling price of the end product to the customer is directly adjusted by any fluctuations in aluminium and steel prices.

In the case of products that use aluminium and steel purchased outside the "re-sale" method, a part of the customers adjust the prices of Group products, taking as a base the fluctuations in steel prices that the customers agree with the iron and steel industry, others adjust the prices based on public indexes and with others, negotiations are held upon the initiative of the parties. Historically, the Group has negotiated its steel purchase agreements with the iron and steel manufacturers to ensure suitable conditions.

Prevention and detection of corruption and bribery

Anti-fraud and Corruption Policy

Scope:

• Directors, managers, employees contractually linked to the Group's companies
• Third parties that relate to the Group

Key content / principles:

• Establishes general parameters of action to send a strong message of opposition to corruption and fraud in all its manifestations
• Conveys the company's willingness to avoid such conduct within the organization
• Develops the internal regulations concerning corruption and fraud already established in the Code of Conduct

Code of Conduct

Key content / principles:

• Contains internal regulations concerning corruption and fraud
• Establishes provisions regarding competition, including:
  • Avoiding any measure aimed at unlawful limitation of competition
  • Prohibition on secret agreements on price or terms of sale with competitors
  • Prohibition on secret agreements on waiving competition
  • Prohibition on submission of sham bids
  • Prohibition on client sharing or market segmentation
  • Requirement to consult legal department in case of queries about unfair competition

Training and implementation monitoring:

• Mandatory training on the Code of Conduct for all employees
• Whistleblowing channel available to all stakeholders

Scope:

• All employees (mandatory training requirement)
• All stakeholders (whistleblowing channel access)

Incidents of corruption or bribery

Confirmed incidents

Gestamp explicitly states:

"In 2024, there were no confirmed cases of corruption and bribery (G1 - 4: Cases of corruption or bribery)." (Page 300)

Communications received through whistleblowing channels

While no corruption or bribery cases were confirmed, the company tracks communications related to integrity matters through its "Speak Up Line" whistleblowing hotline:

The corruption category specifically relates to: "Corruption or bribery is not accepted. It is forbidden for any Gestamp employee to negotiate with the government or political parties in order to offer or provide a backhander or reward that favours decision-making for their own benefit or that of the Group."

Total communications and actions taken

Across all categories (including health & safety, discrimination, harassment, etc.), Gestamp received:

• 190 total communications in 2024 (128 via Speak Up Line, 47 via Compliance Office email, 15 via delegates)
• 83% of communications were closed by year-end

Actions taken as a result of investigations:

• 8 dismissals of employees
• 6 suspensions from job without pay
• 17 cautions in writing

Investigation and speak-up mechanisms

Gestamp maintains multiple reporting channels:

1. Human Resources Delegates: Employees can file reports through delegates who report to the Compliance Office
2. Compliance Office Mailbox: Corporate email address managed directly by the Compliance Office
3. SpeakUp Line: External company-managed channel available since December 2016, accessible by telephone, online form, or email in all Group languages

The channel is available to all stakeholders including employees, clients, suppliers, collaborators, partners, shareholders, investors, and local communities. Reports are investigated promptly with guarantees of:

• Anonymity
• Confidentiality
• Non-retaliation
• Presumption of innocence
• Protection of personal data

Legal proceedings and fines

As of December 31, 2024:

• No pending legal proceedings for payment delays
• No fines, sanctions, or significant compensation detected as a result of cases or claims related to discrimination or harassment
• No material incidents related to human rights violations involving Gestamp's workforce beyond those indicated in the communications table

Anti-corruption framework

Gestamp has implemented:

• Anti-Corruption and Anti-Fraud Policy (approved December 17, 2018)
• Criminal Risk Prevention Model including corruption and bribery risks
• Third Party Due Diligence Policy for integrity risk management
• Mandatory Code of Conduct training for 100% of employees
• Specific criminal risk prevention training for employees exposed to such risks

The company aligns with international standards including the UN Global Compact Tenth Principle, OECD recommendations, US Foreign Corrupt Practices Act, and UK Bribery Act.

Political influence and lobbying activities

Political engagement approach

Gestamp engages with regulatory bodies through lobbying, national, international and sector-specific association events, as disclosed in its stakeholder engagement mechanisms.

The institutional relations area seeks to dialogue and strengthen ties with institutional audiences to give visibility to Gestamp's contribution to society, and also collaborates in the development of public policies and regulations as a corporate citizen with ethics, transparency, integrity and professionalism.

Gestamp holds the presidency of the Spain-China Council Foundation and the vice-presidency of the main automotive clusters, as well as actively participating in the boards of directors of various bilateral and trade chambers.

Gestamp participates in various associations and forums that support transparency along the sector's value chain, including Catena X.

Ethical standards and guidelines

The Group's Anti-Corruption Policy establishes guidelines for action and rules applicable to the performance of any business-related activity conducted within the Group in relation to:

• Corruption
• Fraud and bribery
• Gifts and tokens of appreciation
• Donations or aid
• Political activity

The Code of Conduct is furnished and must be accepted as part of the induction plan for new employees, and it is also available over the intranet and on the Gestamp corporate website. Online and face-to-face training plans on this topic have also been implemented.

The prevention, detection and management of any cases of bribery and corruption is entrusted to the Group's Compliance role. The Ethics Committee, with the support of the Compliance Office, acts in relation to the Code of Conduct and the Whistleblowing Hotline.

Political contributions

With respect to political activity, the Group does not take part in any activity of this kind, nor does it show support for, make financial contributions or give donations of any kind to political parties or their members.

The Anti-Corruption Policy explicitly states that:

Political activity: Gestamp will neither participate in any political activity nor provide any kind of politically motivated financial donation.

The Code of Conduct states: "Corruption or bribery is not accepted. It is forbidden for any Gestamp employee to negotiate with the government or political parties in order to offer or provide a backhander or reward that favours decision-making for their own benefit or that of the Group."

No incidents reported related to political activity:

• 2024: 0 incidents
• 2023: 0 incidents
• 2022: 0 incidents

EU Transparency Register

Gestamp is registered in the EU Transparency Register and abides by the rules and principles set out in Annex I of the Interinstitutional Agreement.

Trade association memberships

Gestamp maintains memberships in numerous industry, economic, bilateral chambers of commerce, regional clusters, professional, and ESG associations. Key memberships include:

Bilateral Chambers of Commerce:

• German-Spanish Chamber of Commerce (AHK)
• Brazilian-Spanish Chamber of Commerce (CCBE)
• Spain-China Council Foundation (holds presidency)
• China Europe Business Council
• Spain-US Council Foundation
• Spain-Japan Council Foundation
• French Chamber of Commerce in Spain
• Spanish Chamber of Commerce in Japan
• Spain-India Council Foundation
• Polish-Spanish Chamber of Commerce
• Spain-China Business Advisory Council
• Moroccan-Spain Economic Council (CEMAES)
• Tangier Chamber of Commerce
• Chattanooga Chamber of Commerce
• Spanish Chamber of Commerce in Mexico

Spanish regional clusters:

• Basque Automotive Cluster (holds vice-presidency)
• Automotive Cluster of Aragon (CAAR)
• Automotive Cluster of Cantabria (GIRA)
• Automotive Cluster of Navarre (ACAN)
• Automotive Cluster of the Community of Valencia (AVIA)
• Automotive Company Cluster of Galicia (CEAGA)
• Automotive Industry Cluster in Catalonia (CIAC)
• Automotive Forum of Castilla y León (FaCyl)

Industrial associations:

• SERNAUTO (Spanish Association of Automotive Suppliers)
• ASEPA (Spanish Association of Automotive Professionals)
• STA (Association of Automotive Engineers)
• Electric Vehicle Industry Association (AIDIVE)
• INSIA (University Institute of Automobile Research)
• MEMA (Original Equipment Suppliers)
• Metallurgical Employers' Union
• Foment de Treball
• Logistop
• AEC (Spanish Quality Association)
• AIC. Automotive Intelligence Center
• Industry 4.0 Chair of the Comillas Pontifical University
• IndesIA
• Catena X
• CAR (Center for Automotive Research)
• CANACINTRA
• Czech Automotive Industry Association

Economic Associations:

• Círculo de Empresarios (Businesspersons Association)
• Spanish Exporters and Investors Club
• IEF (Family Business Institute)
• CEOE (Spanish Confederation of Business Organisations)
• CCE (Spanish Chamber of Commerce)
• COTEC Foundation for Innovation

Professional associations:

• AED (Spanish Association of Executives)
• APD (Association for Management Progress)
• DIRCOM (Association of Communication Managers)
• CPOnet. Social Network of Purchasing Professionals
• AERCE (Spanish Association of Purchasing, Contracting and Procurement Professionals)
• Tecnalia
• China Society of Automotive Engineers

ESG Associations:

• Forética (Corporate Social Responsibility association for businesses and professionals)
• Spanish Network of the United Nations Global Compact
• Business for Social Impact Steering Committee
• Spanish Business Council for Sustainable Development
• CEO for Diversity (Promoted by the Adecco Foundation and the CEOE)

No monetary amounts for membership fees or contributions were disclosed.

Focus areas

Key advocacy topics include:

• Development of public policies and regulations related to the automotive sector
• Transparency along the sector's value chain
• Sustainable development and ESG matters
• Automotive industry innovation and technology

The Group's Spanish companies have adapted their internal process and payment period policy to Law 15/2010, hence, measures to fight against default in trade operations have been implemented. In this regard, the contracting conditions for commercial suppliers corresponding to the industrial activity of manufacturing parts located in Spanish territory have included payment periods equal to or less than 60 days, both in the 2024 financial year and in the 2023 financial year, as established in the Second Transitional Provision of the aforementioned Law.

2024:

• Average payment period to suppliers: 43 days
• Total payments made: 4,282 million euros
• Total pending payments: 660 million euros

2023:

• Average payment period to suppliers: 42 days
• Total payments made: 4,597 million euros
• Total pending payments: 698 million euros

The monetary volume paid in the 2024 financial year in a period less than the maximum established in the late payment regulations, for companies based in Spain, is 1,083 million euros (1,084 million euros in 2023) corresponding to 63,360 invoices (62,251 invoices in 2023).

For reasons of efficiency and in line with common business uses, the Group's Spanish companies basically have a supplier payment schedule, whereby payments are made on fixed days which, at the main companies, are twice a month.

Generally in 2024 and 2023, the payments made by Spanish companies to suppliers, under agreements entered into following the entry into force of Ley 15/2010, did not exceed the statutory deferral limits. Payments to Spanish suppliers that during the 2024 and 2023 financial years have exceeded the established legal term have been, in quantitative terms, of little relevance and are derived from circumstances or incidents beyond the established payment policy, among which are, mainly, the closing of agreements with suppliers on the delivery of goods or provision of services or specific processing procedures.