Getlink SE

Reference: pages 238-240.

The Board of Directors has 1 executive and 14 non-executive members; 42% are women and 50% are independent (Staff Representative Directors excluded), unchanged from 2024 and 2023 (page 238). The Board's diversity policy maps nine essential skills, and "100% of the Board members are recognised as having strong skills" in Governance and CSR (page 238). A table links each material challenge (adapting to climate change, substances of concern, human rights, customer data and others) to the skills of Board members (pages 238-239).

Oversight of impacts, risks and opportunities: the Ethics and CSR Committee, chaired by the Environment and Climate Lead Director, reviews material sustainability issues, IROs, policies, targets and results. The Audit Committee monitors the reporting process, including the double materiality analysis (page 239). On the Executive Committee, CSR is overseen by the Directrice générale adjointe, to whom the CSR department reports; environmental committees meet three times a year (page 240).

Reference: page 240.

The Group has "a formal CSR policy that has been approved by the Ethics and CSR Committee and the Board of Directors". The CSR department, which reports to the Directrice générale adjointe, presents IROs and sustainability challenges to the Ethics and CSR Committee, which reports to the Board. The Committee "met three times in 2025 with an attendance rate of 100%" (page 240).

Risks (including non-financial risks), non-financial objectives and their progress are discussed at Board meetings, and "impacts and opportunities are updated and monitored once a year and presented to the Board". For acquisitions, the CSR department analyses European Taxonomy ratios, the decarbonised margin indicator and environmental and social due diligence; these analyses "feed into the annual update of the Group's IROs" (page 240).

Reference: pages 240-241; see also page 266.

The share of chief executive officers' variable remuneration dependent on sustainability objectives is shown as 15% in 2025, 20% in 2024 and 15% in 2023 (page 240). "15% of the 2025 variable remuneration of executive officers depends mainly on the achievement of the greenhouse gas reduction target in line with the Group's trajectory for Scopes 1 and 2 i.e. a 30% reduction in 2025 compared to 2019" (page 241).

CSR has been a criterion in annual variable remuneration since 2012. Long-term incentive share plans allocated to senior managers since 2021 include one climate-trajectory criterion, 15% of the 2025 plan (page 241). The E1 chapter table gives different percentages for the same years (CEO 15, 10, 10; LTI 25, 15, 15; page 266), so the two tables do not agree.

Reference: page 241.

A table maps the key elements of due diligence to the paragraphs of the statement: integrating due diligence into governance, strategy and business model (GOV-2, SBM-3); engaging stakeholders at all stages (IRO-1(g), SBM-2); identifying and assessing adverse impacts (IRO-1(b,c,j)); and taking measures and monitoring their effectiveness through "paragraphs and indicators relating to actions in specific ESRS" (page 241).

A second table lists due diligence channels by process area. The channels named include CSR governance, CSR due diligence for acquisitions, the Group risk management process, supplier selection and evaluation with sustainable purchasing procedures, health and safety operating procedures and prevention plans for employees and on-site contractors, discussions with employee representatives and a commitment survey, and data protection procedures (page 241).

Reference: page 242.

The statement names the main risks in its reporting process: "the risk of errors in manual data entry and the incompleteness of the data reporting scope". Controls described: a data owner and a validator are stated for each sustainability data item, and methodologies setting out the calculation method and checks for each indicator are updated annually and reviewed in external audits (page 242).

A new centralised digital tool for collecting sustainability data adds traceability of entries and a simpler workflow between contributor and checker. Some data also feed regulatory declarations (ICPE declarations, quarterly carbon assessments, the AGEFIPH disability declaration). The systems and processes are presented to the Audit Committee at least once a year before the statement is validated (page 242).

Reference: pages 250-253.

Getlink describes itself as "a facilitator in the movement of people, goods, data and energy". Revenue split for 2025: Eurotunnel cross-Channel services 75%, Europorte rail freight 11%, Eleclink electricity interconnector (1 GW, commercial operation since 25 May 2022) 14% (page 251). Rail transport through the Tunnel is stated to be around 20 times less carbon emissive than ferry transport on the Calais-Dover route (page 251).

The value chain relies on more than 1,900 suppliers, of which 180 represent 80% of purchasing expenditure; more than 99% of top-tier suppliers are in Europe, 69% in France and 23% in the UK (page 253). Main purchasing categories include rolling stock, fixed railway equipment, energy and utilities, roadworks, rail services, safety and IT (page 253). A value chain diagram positions the material challenges (pages 251-252).

Reference: pages 253-255.

A table lists stakeholder categories, how Getlink engages with them and what the engagement achieved: financial community and rating agencies, governmental and regulatory bodies, B2B and B2C customers, suppliers and subcontractors, employees and trade unions, schools and universities, media, NGOs, local authorities, residents, economic actors and local associations (pages 253-255). Examples of channels: Board and committees about 12 times a year, annual employee engagement survey, an ethics whistleblowing system open to employees, suppliers and other external collaborators, and CSR assessment charters and questionnaires, "several dozens per year" (page 254).

Stakeholder expectations "are progressively relayed to the highest levels of the Group through project steering committees, environment committees, CSR working groups and ultimately the Board's Ethics and CSR Committee" (page 253).

Reference: pages 247-250, 255-256.

A table summarises IROs by sustainability challenge with value chain position and time horizon, with non-material rows shaded grey; the analysis identifies "24 challenges, including 18 material challenges, 30 impacts, 58 risks and two opportunities" (pages 247-250). The two opportunities are modal shift in E1 and local stakeholder dialogue in S3 (page 246).

The main elements of the business model "have not been called into question" by the material challenges. The environmental trajectory involves "around €76 million over the period 2019-2025" across climate, natural environments and waste (page 255). Financial effects are expected as reduced revenue, extra operating costs, extra investment costs and revenue growth from air-to-rail modal shift (page 256). The Group states it has had no formal notices from DREAL in five years, no environmental offence finding and no environmental provision, and holds cover for environmental risks up to €75 million (page 256).

Reference: pages 242-247.

The 2024 double materiality analysis, updated in 2025, drew on EFRAG guidance, the French accounting standards body's guidebook, a consultancy firm and internal teams. It started from challenges identified in earlier analyses (2015, 2019, 2022) plus ESRS 1 AR 16 and peer comparison, arriving at "24 challenges retained in the analysis" (page 242). Impacts are scored on six probability levels and five severity levels (scale, scope, irremediable nature); risks use the risk register on a residual basis, with a sensitivity check on gross criticality (pages 243-244).

Each challenge gets an impact criticality (1 to 18) and a financial criticality (1 to 12); the thresholds are 10 for impact materiality and 7.5 for financial materiality, agreed by the Executive Committee and the Board (page 244). About 10 stakeholder representatives were surveyed (page 245). The time horizon is five years (page 245). The material standards are E1, E2, E5, S1, S2, S3, S4 and G1 (page 247).

Reference: pages 232-233, 250.

IRO-2 point (a) states that "A summary table listing the disclosure requirements included in this sustainability statement and the relevant pages is presented at the beginning of the sustainability statement in section 6.1" (page 250). That table is on pages 232-233. Point (b), the cross-references to other European and international standards, sits in the appendix to the statement (page 250 cites section 6.1.15; the contents list on page 231 puts the appendix at section 6.1.16, page 380).

Getlink also states that it "has chosen not to apply the 'Quick Fix' amendments" of 11 July 2025, so as to keep the same transparency as in previous years (page 234). The page numbers in the index run two higher than the folios printed on the pages; for example BP-1 is listed at page 236 and sits on page 234.

Reference: pages 266-270.

Getlink "joined the 'Science-Based Targets' initiative ('SBTi') in 2021". Scope 1 and 2 targets set then were -15% by 2023 and -30% by 2025 against 2019; both were met (down 23.5% in 2023, 32% in 2025). The 2030 target is -54% against 2019 (page 266). 2025 Scope 1 and 2 emissions were 39,031 tCO2eq against 57,372 in the 2019 base year (page 270). A new Scope 3 target cuts intensity by 15% against 2025 for categories 3.1 and 3.2 (page 268). Net zero by 2050 means a 90% cut in Scope 1 and 2 emissions from 2019, "subject to the existence of satisfactory technologies", then absorbing the rest (page 281).

Levers: renewable electricity, a photovoltaic programme at Coquelles, biofuels (Oleo100, HVO), fleet electrification, and replacing halon and refrigerants (page 268). E1 spending is "more than €76 million" for 2019-2025, with "more than €100 million" budgeted for 2026-2030 (page 269). Locked-in emissions are put at "about 480,000 tonnes" over 25 years (page 269). Taxonomy: revenue 97% eligible and 89% aligned; Capex 100% eligible and 92% aligned (page 269).

Back-filled from ESRS 2 IRO-1 for climate (E1 IRO-1), where this content is disclosed in the FY2025 report (pages 271-274). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 271-274.

Getlink separates "physical" from "transition" risks and builds on a TCFD-based study carried out in 2021, reviewed in the 2025 double materiality analysis (page 271). Physical scenarios are RCP2.6 and RCP8.5 (SSP1-2.6 and SSP5-8.5 in the sixth IPCC report) over 2021-2050, 2041-2070 and 2071-2100; RCP8.5 is described as "aligned with global warming of 4°C by 2100" (page 272). The transition scenarios, drawn from IEA publications, "describe a world at 2°C and a world at 4°C"; no 1.5°C scenario is named. They produced 19 transition risks and opportunities (page 273).

Main physical results: flooding of the Coquelles terminal from the catchment basin and heat stress, both at Eurotunnel; Europorte's risks are not material (pages 272-273). Key assumptions: intensity of physical impacts, carbon price, electric mobility, world trade and customer behaviour (page 272).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Back-filled from ESRS 2 SBM-3 for climate and the E1 IRO-1 text, where this content is disclosed in the FY2025 report (pages 270-273). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 270-273, 292-293.

Getlink says its climate resilience "is established first and foremost by its 'low-carbon' business sectors", noting that rail is under 1% of national emissions in France and the UK (page 270). The 2021 Group-wide assessment found "controlled physical risks" focused on Eurotunnel, with an action plan in place; worsening scenarios "only increases the financial severity" (page 271). Temporary risks such as flooding and extreme heat do not call the business model into question, "nor does it require any new skills" (page 271).

Exposure is small: the value exposed to flooding is two buildings worth €0.6 million, under 0.1% of fixed assets, and "no asset can be considered as stranded" (pages 292-293). The report acknowledges "significant underlying uncertainties in the assessment of impacts and occurrences" (page 272).

Climate resilience is also presented under E1-3 (2025 ESRS numbering).

Reference: pages 274-275.

The policies for the material climate IROs are "validated at least at Group Executive Committee level and approved by the Board of Directors" for the 2025 Environment Plan and the 2030 CSR trajectory (page 274). A table links each IRO to its policy. The CSR policy and 2030 trajectory build mitigation and adaptation into infrastructure sizing, investment decisions and operations, for example a heatwave plan and acceptance of new engine types. A sustainability charter with eco-driving initiatives covers energy use at Eurotunnel and Europorte. A dedicated energy decarbonisation policy sets targets and tools: guarantees of origin, PPAs and an on-site solar plant. Responsible purchasing, sustainable events and sustainable construction policies address the value chain. Modal shift is backed by the commercial and development policy for new rail routes and traffic. For the positive impact "Optimising trade in decarbonised energy" (Eleclink) there is "No specific policy" (page 274).

Reference: pages 275-280.

Mitigation actions are ranked by emissions. Electricity (Scope 2): 469 GWh used in 2025; 207 GWh of guarantees of origin bought, so 54% of Group electricity is decarbonised counting the UK nuclear supply; 25 GWh from a solar PPA; a programme of 80,000 ground-mounted panels over nearly 55 hectares at Coquelles should cover 10% to 20% of Eurotunnel's electricity, with first works at the end of 2026 (page 275). Vehicles (Scope 1): Oleo100 biofuel replaced 1,755,000 litres of diesel and avoided 4,510 tonnes of CO2; hybrid or electric vehicles are 41% of the light fleet (page 276). Halon emissions rose to 5,651 tCO2eq after a Shuttle fire (page 276). Scope 3: a responsible purchasing procedure covers purchases above €150,000 (page 277).

Adaptation: flood plan, two of four basins cleaned in 2025, heatwave plan (page 279). Resources: climate risk actions cost about €2.8 million in 2025 (page 280); abatement costs run "between €65 and €210 per ton" (page 278).

Reference: pages 280-281.

The 2025 targets were -30% for Scopes 1 and 2 and -7.5% for Scope 3 purchases against 2019, "approved by the SBTi initiative in 2021", which "considered the 2025 target for Scopes 1 and 2 to be compatible with the trajectory aimed at limiting global warming to 1.5°C" (page 280). For 2030: -54% for Scopes 1 and 2 against 2019 (about 4.9% a year under the SBTi method); a new Scope 3 target of -15% intensity against a 2025 base of 164 tCO2eq/€m for categories 3.1 and 3.2, which "account for more than two-thirds of Scope 3 emissions"; and 10% self-generated electricity (pages 280-281). 2050: Scope 1 and 2 residual emissions 90% below 2019, then absorption of the remainder (page 281). "No carbon credits are taken into account" (page 280). Adaptation targets: confirm acceptability of new engine types in the Tunnel and install charging stations by 2030, and finish cleaning the buffer basins (page 281).

Reference: pages 281-283.

Total energy consumption was 572,936 MWh in 2025 (573,338 in 2024; 592,541 in 2023). Fossil sources were 99,223 MWh (17%, down from 20%): 79,093 MWh of crude oil and petroleum products, 8,401 MWh of natural gas and 11,729 MWh of purchased fossil-sourced electricity. Nuclear was 250,207 MWh (44%, up from 26%). Renewable sources were 223,505 MWh (39%, down from 54%), of which 206,667 MWh was purchased electricity backed by guarantees of origin, 16,771 MWh fuels and 67 MWh self-generated (pages 281-282). The fall in renewable share "is mainly due to the purchase of fewer guarantees of origin (207 GWh vs. 305 GWh)" (page 282).

Biofuel use: 1,754,845 litres of Oleo100 at Europorte and 65,787 litres of HVO (page 282). Energy intensity is 359, against 355 in 2024, on revenue from all reporting activities; traction is "nearly 80%" of electricity use (page 283). The scope is stated as high-climate-impact sectors (NACE F42, H52, H49.20, D35.12) (page 281).

Reference: pages 283-289.

Scope 1 and 2 (market-based) emissions were 39,031 tCO2eq in 2025, against 41,766 in 2024 and 43,901 in 2023; Scope 1 was 33,101 tCO2eq, mainly Europorte's locomotives (page 284). On a location-based basis Scopes 1 and 2 were 55,840 tCO2eq (page 285). Halon rose 172% to 5,651 tCO2eq (page 284). Biogenic emissions were 4,354 tCO2eq, reported separately (page 285).

Scope 3 under the Group's ISO 14064 method was 110,172 tCO2eq (115,231 in 2024), with purchases and fixed assets and energy-related emissions making up 80% (page 287). Total Scope 1, 2 and 3 market-based emissions were 149,203 tCO2eq (page 286); calculated on the GHG Protocol alone the total is 125,522 tCO2eq, because customer travel is excluded and fixed assets are not depreciated (pages 287-288). "46% of Scope 3 emissions" use primary data (page 287). Intensity: 25 tCO2eq/€m for Scopes 1 and 2 and 94 for all three scopes (page 289). "From 2026 onwards, only the GHG Protocol will be used for Scope 3" (page 283).

Reference: pages 289-291.

A nil return: "To date, the Group has not developed any GHG absorption or storage projects, nor has it purchased any carbon credits" (page 289). Residual emissions in 2050 are put at around 6,000 tCO2eq, a 90% cut from 2019, and "no action plan has yet been fully formalised" for the removals needed to reach net zero. A 2023 study reviewed carbon capture, transport and storage options, finding source capture the most relevant for Getlink's small residual volume (page 289).

Outside the inventory, the Group reports avoided emissions, which are not removals: an independent expert's 2025 update puts emissions avoided by its transport activities at 1.9 million tonnes, compared with ferry, air and road alternatives; Eurotunnel accounts for 1,788 kt and Europorte 113 kt (page 290). The report says such avoided emissions are "inherently uncertain" because the baseline scenario is hard to establish (page 236).

Reference: page 291.

Getlink applies an internal carbon price, introduced in September 2020 "for certain investment projects". It works as a shadow price: the less carbon-intensive of two options gets a more favourable virtual cash flow in the net present value calculation. It covers Scopes 1, 2 and 3 and was built into the sustainable purchasing policy introduced in 2021 and updated in 2025. The price was updated to €209 per tCO2eq in 2025 (€205 in 2024, €201 in 2023), based on the US EPA social cost of greenhouse gases study (page 291). Applications cited: valuing the carbon weight of photovoltaic modules for the Eurotunnel solar programme (20,000 to 30,000 tCO2eq over the programme), the decision to buy electric buses, the choice of generators for the 30th anniversary celebrations and preventive maintenance on a transformer to limit SF6 leaks (page 291).

Reference: pages 291-293.

Physical: two acute risks could be material for the Concession, flooding of the Coquelles catchment basin and thermal stress. The value exposed is the two buildings at risk of flooding, "€0.6 million", under 0.1% of the Group's fixed assets (net book value at 31 December 2024); adaptation measures cover 100% of the buildings concerned (page 292). Transition: over five years the Group judges the positive and negative effects of lower passenger mobility and modal shift to "offset one another"; the energy price risk was revised below the materiality threshold in 2025 (page 292). Europorte's mainline rolling stock renewal from 2035 has no validated financial evaluation (page 292).

Real estate by energy class (Eurotunnel, 2024 data): about €39 million of buildings commissioned after the RT2012 regulations and €243 million of older property (page 293). The Group's "decarbonised margin" puts the carbon bill for Scopes 1 to 3 at around 4% of current EBITDA, 3.6% in 2025 (page 293). The report says no provision should be recognised for these risks (page 292).

Reference: pages 299-301.

The pollutants named under the E-PRTR Regulation are NOx, CO and PM10 from motor vehicles, nitrogen, phosphorus, heavy metals and hydrocarbons in discharged water, and halon in Eurotunnel's Passenger Shuttles. Substances of concern, by CLP hazard class, are glyphosate-based phytosanitary products and two PFAS, an AFFF-type foam and the FK-5-1-12 extinguishing agent, which only Eurotunnel uses (page 299). Policies are approved at entity management committee level or at Group level through the 2025 Environment Plan and the 2030 Trajectory (page 299).

They include Europorte's HSQE policy (ISO 9001, MASE and SQAS certifications, Ecovadis Gold), a "move towards zero glyphosate" policy that limits glyphosate to rail safety uses, Eurotunnel's HSQE policy with prevention plans, anti-fuel-leak procedures and a water management plan, the CSR policy renewed in 2025 and the responsible purchasing policy (pages 299-301). Residents' complaints about pollution arrive through a generic email address on the website (page 301).

Reference: pages 301-303.

Air: Europorte's locomotives are the largest source. The levers are alternative fuels (Oleo100, HVO, synthetic fuels) and replacing the oldest rolling stock by 2035, with about a 10% cut in fine particles seen by 2025 (page 301). At the UK terminal NRD has been fully replaced by GTL, which cuts fine particles by 28% to 54% (page 301); filters fitted in 2025 on diesel equipment capture 60% of NOx (page 302). Phytosanitary products: about 15 cattle graze 34 hectares at Coquelles and a sheep eco-grazing trial began near Sète in 2025 (page 302). PFAS: a project is under way to replace AFFF foam (page 302). Water: retention basin membranes are being replaced in 2025 and 2026 (page 302), and no alerts or breaches were reported in five years under the prefectural licence (page 303). Nine significant fuel leaks were reported in 2025 (page 303).

Resources: about 0.9 FTE at Europorte and 0.3 FTE at Eurotunnel; E2 spending was €5.0 million in 2025 and €32.4 million over 2019-2024, with about €30 million budgeted for 2026-2030 (page 303).

Reference: page 304.

"All the targets indicated by the Group set out in the 2030 CSR Trajectory and approved by the Ethics and CSR Committee are voluntary", because the activities "are not bound by any reduction trajectory for these pollutants beyond compliance with regulatory thresholds". No quantitative air emissions target is set because the figures rest on approximations; modal shift is named as the main contribution.

Glyphosate: total elimination or substitution outside railway safety zones by 2025 (completed at the French terminal), and a sustainable reduction of all inputs by 2030. PFAS: replace the last AFFF foams in Passenger Shuttles by 2028. Water: comply with E-PRTR and the prefectural licence limits. Halon: phase-out depends on the Mid-Life programme, before 2040. Eurotunnel limits fuel leaks of more than 50 litres to six per year (five-year average). The 2030 trajectory commits to move towards eliminating substances of very high concern and AFFF foams.

Reference: pages 305-307.

Air emissions in 2025 (tonnes, Group): NOx 607 (628 in 2024), CO 305 (307), unburnt hydrocarbons 43 (44), and 1.4 of FK 5-1-12, a PFAS, from Eurotunnel (page 305). Locomotives contribute "over 90%" in each category. Fine particles, about 15 tonnes a year from Europorte rolling stock, are not reported because the estimate is partial (page 305). Soil: glyphosate 720 litres (666 in 2024) and other plant protection products 2,888 litres (1,801); Europorte's 2023 and 2024 figures were corrected after a tracking software error (page 307).

Water: nitrogen and phosphorus at the treatment plant outlet are "well below the materiality threshold indicated in the standard (c. 1t < 50t for nitrogen and 2t < 5t for phosphorus)", so they are not detailed (page 305). Halon leaks were 785 kg in 2025 against 289 kg in 2024, with ozone-depleting substances to be eliminated by 2037 (page 305). The Group does not use or generate microplastics "in material quantities" (page 305). Calculation methods are on page 306.

Reference: pages 306-307.

Substances of concern, by CLP hazard class, are phytosanitary products including glyphosate (Europorte and Eurotunnel), AFFF foam and FK 5-1-12 (both PFAS) and halon (Eurotunnel) (page 306). Quantities: Eurotunnel used about 1,200 litres of phytosanitary products in 2019 and has cut that by 80% (page 306); Group glyphosate was 720 litres and other plant protection products 2,888 litres in 2025; 0.5 tonnes of AFFF foam is diluted in the fuel tanks of nine Passenger Shuttles, and 1,391 kg of FK 5-1-12 leaked from about 50 tonnes installed (page 307).

Substances of very high concern concern only Eurotunnel (anti-corrosion paint, adhesives and seals, lubricants, anti-freeze). They "are considered to be generated and used during operation and maintenance: no substances are regarded as having left the Group's facilities". The 2025 volumes by ECHA category, as printed, are 7 L toxic to reproduction, 367 L PBT or vPBT and 3,134 L others. Data rest on container volumes, so uncertainty is high; the aim is to substitute all such products by 2030. Europorte uses and emits none (page 307).

Reference: pages 307-308.

Substances of concern "are emitted or handled as part of railway infrastructure management. They are neither in contact with customers nor included in products sold. No economic impact has been identified for the Group" (page 308). Around €350,000 was spent over 2019-2025 on initiatives to reduce phytosanitary products and improve air quality in the Tunnel. No expenditure was incurred and no provision made for incidents or fines; the E2-6 table shows 0 Opex and 0 Capex for both N-1 and N (page 308). A hydraulic study is planned for the UK terminal to define mitigation for polluted discharge water in an electric vehicle fire (page 307). Costs to 2030/2035 are alternative weed treatment, strengthened emission measures at Samphire Hoe and engine renewals already counted in the decarbonisation trajectory. Getlink says it will work to establish the share of revenue involving these substances (page 308).

Reference: pages 308-309.

The Group "only undertakes maintenance activities not manufacturing", and about 95% of its waste comes from Eurotunnel (page 308). The strategy "gives priority to reuse followed by recycling and energy recovery" and is part of the Group's waste management policy, supported by Eurotunnel's HSQE department (pages 308-309). Waste is tracked with waste transfer notes, covering all hazardous waste and, voluntarily, non-hazardous waste, plus a consolidated treatment and recovery certificate from the main French waste manager (page 309). Most orders under the responsible purchasing procedure updated in 2025 carry waste management and treatment monitoring requirements (page 309). An internal sustainable construction note applies to all new Eurotunnel construction and is built into the project execution procedure (page 309). A network of local donation and recycling partners supports circular initiatives (page 309).

Reference: pages 309-311.

Each Eurotunnel terminal has its own waste depot; in France about 30% of recovered waste becomes briquettes for industrial boilers (page 309). More than 96.5% of the weight of the Breda Shuttles was recycled after dismantling in 2021-2024, almost 7,400 tonnes (page 309). Refractory ceramic fibres from the Mid-Life programme will be vitrified and recycled as road underlay rather than landfilled, at nearly 20 times the cost of landfill (page 309). Hazardous waste has been tracked on Trackdéchets since 2023 (page 310). The Mid-Life programme gives the Shuttles' structural components another 20 years, and 95% of 2,300 tonnes of rail from the last renewal was recovered (page 310). Eurotunnel made more than seven tonnes of furniture available for reuse in 2025 (page 310).

Resources: about 1.2 FTE; Capex plus Opex of €766,000 over 2019-2024 and €308,000 in 2025, with none expected from 2026 (page 311). Resale of sorted materials offsets about 30% of Eurotunnel's waste treatment cost (page 311).

Reference: page 311.

"From 2019 to 2025, the Group's objective was to recover 80% of waste; this has been achieved." By 2030 the target is 90% recovery across the Group, covering hazardous and non-hazardous waste, with waste counted as recovered "when it is recycled or reused as material or energy". Recycling follows the R and D codification used in CSRD reporting: waste is recycled if it is not stored, landfilled or incinerated without producing energy.

Sustainable construction guidelines formalised in 2024 include a target for the share of reused, re-employed or recycled materials in building projects. By 2030 the Group commits to maximising that rate in three flagship Eurotunnel property projects: the maintenance building, the relocation of CIFFCO and the operational headquarters.

Reference: page 311.

The index lists E5-4 with a page reference, but the section reports no quantities. It states that "the Group does not consolidate the quantities of materials used for its services". The only resources close to raw materials are the rails used to renew track, "the quantities of which depend on the annual programmes of this work". For other purchases, supply is attached to the installation and the equipment is complex and built from sub-equipment and raw materials "very far up the value chain", which makes it hard to identify the natural resources involved in consistent reporting.

In the long term the Group will try to improve its view of critical resources in its purchasing as Tier 1 suppliers and its "Buy-Pay" monitoring software mature. The E5 table at the start of the chapter lists the exploitation of natural resources for business purposes as a material negative impact on incoming resources (page 308).

Reference: pages 311-313.

The section on outgoing resources reports waste only. Total waste produced was 4,006 tonnes in 2025 (4,209 in 2024; 5,141 in 2023), down 5% on the preceding year and 3% above 2019; Eurotunnel's waste intensity per unit of investment fell 13% between 2019 and 2025 (page 311). Of the total, 3,211 tonnes were recovered and 795 tonnes eliminated, so 20% of waste is not recycled (page 312). The Group recovery rate is 80%, and 96% on the French side; the UK terminal's higher waste weight pulled the Group figure down (page 312). Non-hazardous waste is mainly steel, scrap metal, concrete, rubble, wood and soiled fabrics, all reprocessed and recycled (page 311).

No data on products, materials or recycled content of outflows other than waste is given. Radioactive waste is reported as zero (page 312).

Reference: page 313.

The report states that "No significant financial impact is expected at Group level". In the medium to long term, better knowledge of the resources in purchased products and services will help qualify dependencies and risks. The renewal of Eurotunnel's major equipment in this decade is expected to proceed without essential materials, "in particular iron, aluminium and copper", being considered critical in that timeframe. Profits from reselling sorted materials "cover almost 50% of the costs of waste treatment at the French terminal" (page 313).

Reference: pages 311-312.

Hazardous waste was 335 tonnes in 2025 (240 in 2024; 346 in 2023), up 40% on 2024 "as a result of increased maintenance" but 30% below 2019. Of this, 73 tonnes were recycled, 170 tonnes recovered by other means including energy-producing incineration, 18 tonnes incinerated without energy recovery and 75 tonnes sent to other disposal; none went to landfill (page 312). Non-hazardous waste was 3,671 tonnes (3,969 in 2024; 4,795 in 2023), with 48 tonnes landfilled and 655 tonnes in other disposal (page 312). France produced 256 tonnes of hazardous and 2,111 tonnes of non-hazardous waste, the UK 79 and 1,560 (page 312).

Eurotunnel accounts for 95% of the Group's waste and Europorte about 1% (pages 308, 310). Quantities come from waste transfer notes covering the whole Group, with volumes converted at 1 L = 1 kg where weights are missing (page 312). Waste generated by Europorte at customers' sites is excluded from reporting (page 236).

Reference: pages 322-324, 342.

Getlink "employed 3,892 people at 31 December 2025" (page 322). The policies named are the Ethics Charter, a human rights policy and the Code of Ethics and Conduct, covering employees against forced labour, child labour and breaches of freedom of association; the Board of Directors is responsible for the human rights policy and the Code (page 322). The human rights policy is aligned with the UN Guiding Principles, OECD Guidelines, Universal Declaration of Human Rights and ILO core conventions, and Getlink has signed the UN Global Compact since 2013 (page 323). Diversity: an equal treatment policy for recruitment, training, pay and promotion, with the Ethics and CSR Committee reviewing diversity indicators each year (page 322), plus disability charters at Eurotunnel France and Europorte and an internal harassment procedure (page 323).

Gap stated by the company: Getlink "has not formally drawn up Group-wide policies" on career management, training and talent development, social dialogue, and quality of life at work and well-being; policies and actions exist at entity level (page 324).

Health and safety: the HSQE policy has four pillars (protecting people, protecting workplaces, working safely, deciding safely); the Board's Safety and Security Committee validates it and the Group health and safety officer sits on the Executive Committee (page 342).

Reference: pages 326-331, 344-347.

Social dialogue: 92% of employees are covered by employee representatives (page 326). Equality and inclusion: charters and agreements renewed yearly on four topics, a women's talent network, a paternity leave supplement at Eurotunnel UK and a disability action plan for 2022-2025 with a disability charter in 2024 and policy in 2025 (page 327). Well-being: remote working, a psychosocial risk procedure at Eurotunnel, a 4-day week trial that was positive for a small team but "not conclusive for the majority", and a harassment prevention programme (page 328). The financial resources for these actions "are not separated" in HR financial monitoring (page 329).

Careers and training: critical skills analysis and succession planning, with 30% of the workforce due to retire within 10 years at Eurotunnel (page 331); 283 permanent and 112 fixed-term recruitments in 2025; more than 800 managers through the Leadership Model; and 104,116 training hours, 25.4% on safety (page 330). The analysis "did not identified any significant opportunities" for the own workforce (page 331).

Health and safety actions follow the Get Safer plan built on an external audit: Eurotunnel's maintenance and infrastructure team marked 1,000 days without a lost-time accident, and Europorte tested more than 600 employees for psychoactive substances (pages 345-346).

Reference: pages 331-333, 347-349.

Each year the Group sets HR/CSR trajectory objectives, presented to and validated by the Ethics and CSR Committee; targets "aim for continuous improvement based on previous years' results and/or regulatory obligations" (page 331). Values and targets for 2025 (pages 331-333):

• Women on the Executive Committee: 44% against a target above 40%.
• Getlink Voices engagement rate: 73% against a target above 65%.
• Survey participation: 68%, with a target of at least the previous year's rate.
• Training: 4 days per employee, against a target above 3 days.
• Staff turnover 5.5%; absenteeism 5.3% (target: maintain).
• Occupational illness cases: 3 (target: monitor).
• 2030 targets include 30% women in the Group workforce, more than 30% women in the "top 3" and at least one initiative a year to promote the rail sector to female candidates.

Where a trend turns negative, "management analyses the situation and implements an action plan" (page 333). On safety, management chose "means-based targets" over simple numerical ones; the zero deaths objective is renewed for 2026 (pages 347-348).

Reference: pages 333-336.

At 31 December 2025 the Group had 3,892 employees (977 women, 2,915 men), against 3,641 in 2024 and 3,467 in 2023. By entity: Eurotunnel 2,824, Europorte 945, Getlink Customs Services 48, Eleclink 38, Getlink SE 25 and CIFFCO 12 (page 334). By country: France 2,858 and the UK 1,034 (page 334). Contract type: 3,769 permanent and 123 temporary employees, with no employees on non-guaranteed hours (page 334). Full-time employees number 3,626 and part-time 199 (page 335).

Departures totalled 274 in 2025 and the turnover rate was 5.5%, or 4.1% excluding retirements (page 335). There were 395 recruitments, 283 permanent and 112 fixed-term (page 335). Training costs were €6,113 thousand, 3% of payroll (page 336). The workforce of ASA, BIMS, Customs 4 All and Electrofer, under 70 FTE, is excluded because those companies were acquired in 2025 with incomplete data (page 333).

Reference: pages 320, 336.

The only non-salaried staff reported are temporary workers: "270 on average per month over 2025" (page 320), shown in the table as 270 FTE in 2025 against 244 and 258 for the two earlier years (page 336). Hours worked by temporary staff are collected monthly from the temporary employment agencies by each entity and consolidated annually, so the figure is an average annual FTE (page 336). One FTE is hours worked per month divided by 151.67 in France and 160.33 in the UK (page 336).

Self-employed and freelance workers are not included, "since they represent less than 1% of the Group's workforce and because of their profile have very little exposure to the social IROs" (page 320). The index lists both S1-7 and S1-8 under the title "Characteristics of non-employees in the undertaking's own workforce", both on the same page.

Reference: pages 336-337.

92% of employees were covered by collective agreements in 2025 (94% in 2024). In the EEA country with significant employment, France, coverage is 100%; outside the EEA, in the UK, it is 72% (78% in 2024). 99% of EEA employees are covered by employee representatives (100% in 2024) (page 337). The report states "100% of employees are covered by policies and 92% of employees are covered by collective agreements" (page 337).

Exclusions: in the UK certain groups such as executives, and small entities (Eleclink and Getlink Customs Services) whose size does not require representation, are outside representation (page 324). The report points to the European company committee and the French Group works council for dialogue at Group level (page 337).

Reference: pages 337-338.

Women are 25% of the total workforce (25% in 2024; 24% in 2023). The Executive Committee has 4 women and 5 men, so 44% women (46% in 2024; 50% in 2023); the report says this exceeds the 30% average for NEXT80 and SBF120 companies in 2024 per an AFEP study. In the top three hierarchical levels, 25% are women (26% in 2024; 28% in 2023) (page 337).

Age profile at the end of 2025: 491 employees under 30, 1,795 aged 30 to 50 and 1,606 over 50; the average age is 44 (page 337). Top management is defined as the Executive Committee (page 337). The Group also employed 102 work-study students and 51 interns in 2025 (page 338).

Reference: page 338.

"The Group operates in the European context, where regulations impose a minimum remuneration that guarantees an adequate wage for 100% of its workforce (see regulations in the UK and France)." The table shows 0% of employees earning less than the adequate base salary in France and in the UK, in both 2025 and 2024 (page 338).

The remuneration policy aims to reward performance, encourage skills development and mobility and foster long-term commitment. It is reviewed each year in the annual negotiations in the entities and presented to the Nomination and Remuneration Committee. Collective measures include profit-sharing, employee savings plans in France and a share incentive plan in the UK, and free shares; individual measures include raises and bonuses. In 2025 the Group added supplements in France to recognise collective team performance (page 338).

Reference: page 338.

All employees in France and the UK are covered by public social security programmes and can join the health insurance and provident schemes offered by each entity, with partial employer coverage (S1-11_01). All Group employees benefit from public unemployment insurance programmes in both countries (S1-11_02). Occupational accidents and disabilities are dealt with through public programmes and the entity schemes (S1-11_03). Employees can take parental leave under the rules of each country and their own business agreement (S1-11_04). They benefit from national pension schemes, supplemented by supplementary and funded plans, for example Perco in France and the pension fund in the UK (S1-11_05).

The section describes coverage in qualitative terms by datapoint and gives no percentage table by risk event.

Reference: page 339.

The share of disabled employees is 3.3% in 2025 (3.1% in 2024; 2.8% in 2023): 3.0% of men and 4.2% of women. It is calculated on the French headcount only: UK entities "are excluded from the calculation of this indicator since they are not subject to the same regulatory monitoring obligations as in France". The percentage has been published since 2024 to comply with CSRD (page 339). The Group declares its rate of employment of people with disabilities each April for each entity; for Eurotunnel France the rate for the 2024 financial year was 5.32% (page 339). Disability charters and ambassadors are described under S1-1 and S1-4 (pages 323, 327).

Reference: page 339.

77% of employees took part in regular performance and career development reviews in 2025 (59% in 2024): 77% of men and 76% of women; 79% of managers, 78% of technical staff and 72% of manual and clerical workers. Average training was 25 hours per employee (28 in 2024; 24 in 2023): 26 hours for men and 25 for women (page 339). The indicator counts all courses, in-house or external, including e-learning, with 7 hours converted to 1 day (page 339).

Elsewhere the report gives 104,116 training hours in 2025, 25.4% on safety, equal to 4 days per employee against a target above 3 days (pages 330, 333).

Reference: pages 339-340.

100% of employees are covered by a health and safety management system based on legal requirements or recognised standards. The lost-time accident frequency rate for employees was 5.6 in 2025 (6.8 in 2024 and 2023), with 31 lost-time accidents (35 in 2024). Among temporary workers there were 4 and among subcontractors 24 (20 in 2024). There were no deaths among employees, temporary workers or subcontractors in any of the three years. Three cases of occupational illness were recorded (4 in 2024). Days lost were 1,597 for employees and temporary workers (2,987 in 2024) and 1,765 for subcontractors; the severity rate for employees and temporary workers was 0.3 (page 340).

The subcontractor lost-time frequency rate was 12.5 (9.1 in 2024, restated after a refusal by the CPAM to cover a workplace accident) (pages 339-340). UK entities are excluded from the occupational illness indicator (page 340).

Reference: page 340.

100% of employees are entitled to family leave (page 340). 12% of eligible employees took family leave in 2025, against 14% in 2024 (page 340). The family leaves counted are those authorised by the entities: maternity, adoption, paternity and parental leave, absence for medically assisted procreation or termination of pregnancy, sick child days and family events such as marriage or death. In some cases a length of service condition applies, depending on the collective agreements (page 340). The Group also monitors this under its HR/CSR trajectory: 100% of employees authorised to take family leave and 12% having benefited, with the target "Monitor" (page 332).

Reference: page 341.

The gender pay gap is 5% in 2025 and the equity ratio, highest-paid employee's total remuneration over the median, is 42 (36 in 2024; 31 in 2023) (page 341). The gap is calculated on total permanent and fixed-term workforce, using annual remuneration "including basic remuneration, paid leave, benefits in kind, bonuses and exceptional bonuses and profit-sharing", recomposed to full-time for part-time or part-year employees. A Group-scope gap aligned with CSRD was first calculated for 2024 (page 341).

The Group still publishes UK gender pay gap indicators and the French professional equality index on its website. The equity ratio here differs in method from the one in chapter 5, which follows AFEP/Medef rules and covers employees present throughout the year (page 341). A package to reduce pay gaps between men and women is negotiated each year (pages 330-331).

Reference: page 341.

In 2025 the Group recorded 10 incidents of discrimination and harassment (2 in 2024) and 21 complaints through channels for staff to raise concerns (2 in 2024). There were no complaints to OECD National Contact Points, no fines, penalties or damages for discrimination or harassment, and no serious human rights incidents involving own staff, in either year. The report states "no serious human rights incidents were recorded in 2025" and that no provision was made in the accounts. The 10 incidents "were handled according to the relevant internal procedure" (page 341).

The company attributes the increase to "increased internal communication about the whistleblowing system" and greater awareness of social ethics. Figures for 2022 and 2023 were not consolidated or audited, but the Group confirms that no complaints, serious breaches, fines or penalties were recorded in those years (page 341).

Reference: pages 351-354.

Value chain workers covered are temporary staff, on-site subcontractors (about 1,100 FTE a year at Eurotunnel and about 25 at Europorte), suppliers' workers, retail sub-concession staff (about 150 people) and control authorities (page 351). The health and safety policy "applies equally to its direct workforce and to the staff of external businesses working on its sites"; it is endorsed by the CEO and reviewed annually at entity level, and Eurotunnel has a dedicated procedure for external businesses (page 353). Suppliers' safety policies are required before contracting, and general purchasing conditions require compliance with the Code of Ethics and Conduct, with verification audits possible (page 354).

The human rights policy covers all workers, including those in the value chain (page 354). Skills management for key external skills "is not formalised in a Group-wide policy" (page 354). The report says no cases of non-compliance with the UN Guiding Principles, ILO Declaration or OECD Guidelines involving value chain workers occurred "In 2024" (page 354).

Reference: pages 357-361.

Actions include safety event monitoring, a safety facilitator or coordinator from each main subcontractor on Group sites, a project management manual and training for project managers (2025-2026), equipment to reduce physical strain, market checks every 3 to 5 years to limit supplier dependence, and mapping of critical IT applications (2025-2030) (page 357). Improvements in 2025 include new changing rooms and better security control facilities at Eurotunnel's French terminal (page 357), and a safety data sheet platform at Europorte (page 358). Europorte tested more than 600 employees for psychoactive substances (page 358).

Human rights: first-tier suppliers commit at selection and contract review, and an alert can lead to additional diligence and penalties up to termination (page 358). "No human rights incidents in Getlink's value chain were reported in 2025" (page 360). Resources "are not isolated in a specific budget" (page 357); an exceptional budget is used if negative impacts occur (page 360).

Reference: pages 361-362.

"There are no Group-wide targets, with the exception of the key objective of zero fatal incidents." Entities monitor frequency rate, severity rate and days lost for subcontractors (page 361). At Eurotunnel the lost-time frequency rate for subcontractors was 12 in 2025 (9.6 in 2024), with 22 accidents (20); no numerical target was set and the aim of a downward trend "was not achieved". The severity rate was 0.96 (0.80), with 1,750 days lost (1,665). Trips and falls from low heights caused 47% of accidents and handling and movements 29% (page 361). For 2026 senior management aims to start improving subcontractor indicators without specific targets (page 361).

Europorte says the "multitude and diversity of interventions by external businesses" makes it impossible to set objectives for this perimeter; it instead assesses subcontractors yearly and does not renew contracts where performance is poor (pages 361-362).

Reference: pages 362-363.

The material issue is migrants trying to cross into the UK through the Coquelles terminal; 1,518 individuals were intercepted in 2025 (page 362). The human rights policy "relates all persons who may be affected by the organisation's activities", and the Group cites the UN Global Compact, signed in 2013 (page 363). Until recently the policy did not explicitly cover irregular migrants; a new version including them was approved at the March 2025 Board meeting and posted online (page 363).

Operating policies: a dedicated site security team and a team of around 300 people in the "First Line of Response" (FLOR) role. Intercepted people wait for the police in a reception area split between men and women and children, with water, sanitary facilities and a heated or air-conditioned area, checked by the government-appointed rights defender. The Group keeps no weapons on site (page 363). No human rights complaints were filed in 2025 (page 363).

Reference: pages 365-366.

Actions: securing the infrastructure to limit trespass, a psychological unit for staff after serious incidents, support for the Kent Refugee Action Network with office furniture and apprenticeship funding, and joint safety training with French and British security forces, including a full-scale exercise in January 2024 (page 365). Eurotunnel funds fire management training for its FLOR teams (page 365).

Effectiveness indicators: every intrusion into the terminal intercepted within 30 minutes, 0 intrusions into the Tunnel, 0 cancellations caused by such incidents, and 90% of people found in trucks found by Eurotunnel teams rather than the authorities (page 365). "Since 2016 no fatal accidents have been recorded among the migrant population present on the site without authorisation" (page 366). The Group has invested "a significant Opex and Capex budget every year since 2015", with "several million euros" of Opex (page 366).

Reference: page 366.

"The Group maintains the objective of zero deaths and zero serious accidents involving injuries for all people present on site each year", including migrants. The involvement of the migrants themselves in setting the target is "not applicable in this context", and no assumptions are made (page 366). Safety indicators are monitored weekly by operational teams and monthly by management teams; they are those listed under S3-4 (every terminal intrusion intercepted within 30 minutes, no intrusions into the Tunnel, no cancellations, 90% of people in trucks found by Eurotunnel teams) (page 366). Feedback and analysis follow each incident and near miss under the safety system management procedure (page 366).

Reference: pages 367, 372.

Safety: the Group's safety policy "covers all customers and end-users, as well as all the infrastructure and services offered". The CEO expresses the commitment to comply with national and international regulations and the duty of care, and the policy is presented to the Board's safety and security committee. Safety rules for the Fixed Link are monitored with the Channel Tunnel Safety Authority and the Intergovernmental Commission; the EPSF has covered the French side since 1 January 2021 (page 367). The human rights policy also applies to customers and end-users, and in 2025 the Group was not reported for non-compliance with the UN Global Compact, ILO Declaration or OECD Guidelines (page 367).

Data protection: policies cover all consumers and end-users under EU and UK law, alongside a cybersecurity policy. The main risk named is a regulator's financial penalty and reputational harm. The data protection documents are "fully reviewed and amended as necessary every two years" (page 372).

Reference: pages 369-371, 373.

Safety actions: safety culture and management commitment, safety training, tighter monitoring and selection of subcontractors, change management, and risk analyses for serious accidents. Specific processes cover hazardous goods handling, collision and derailment (drivers' training, audits, a rail-wheel interface risk committee) and fire (detectors, automatic extinguishing, evacuation to refuge areas); a committee with railway companies and infrastructure managers was created in 2025 (pages 369-370). "In 2025, the Group did not record any major accidents involving one or more customers" (page 370). Eurotunnel finances first response (FLOR) team fire training (page 371). No serious human rights incidents involving users were reported (page 371).

Data protection: a DPO, 42 data protection representatives trained each year, a data processing register, a violation reporting tool with mandatory refresher training, and internal audit checks (page 373). Resources for safety "mainly cover renovation projects and work to maintain infrastructure in good condition", external on-site safety resources and the safety teams' payroll (page 371).

Reference: pages 371, 374.

Safety: "the aim of safety policy is to achieve zero incidents (whether fire, collision or derailment)". Until 2024 a system safety severity rate was used, with annual objectives; under it the 2025 objectives were met, with 43 for collective risk against a target of 65 and 154 for individual risk against a target of 220. The roadmap now uses leading and lagging indicators and tracks trends rather than absolute values, monitored monthly and shared with the Safety and Security Committee and the Executive Committee (page 371). No consultation of customers is needed because the objective is "absolute and immediate" (page 371).

Data protection: the DPO and the legal department set annual targets for training and policy development; customers are not involved. Achieved in 2025: training for data protection staff, border-fluidity policies for the UK API and French EES systems, and a revised data protection policy with an AI policy in the second half of 2025 (page 374).

Reference: pages 375-376.

Getlink's culture rests on "rigour, integrity and responsibility", set out in charters and policies. The Code of Ethics and Conduct and the main policies are presented to staff representative bodies and examined by the Board's Ethics and CSR Committee; the Ethics Officer, who is the Human Resources Director, updates that Committee on use of the whistleblowing procedure (page 375). A policy to prevent conflicts of interest was formalised and examined by the Committee in 2025. Suppliers must adhere to a compliance certificate before signing, and suppliers with contracts of €5,000 or more in France must supply documents against illegal employment (page 375). The Group has qualified for Global Compact Advanced since 2016 (page 375).

Whistleblowing allows anonymous reports, guarantees confidentiality and is investigated by a committee of the ethics officer and the head of internal audit (page 376). The 2025 survey: 70% say the information is easy to find (67% in 2024) and 19% cannot rule out reprisals (14% in 2024) (page 376).

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

Reference: pages 296-297, 376, 378.

The CSR trajectory table sets business conduct indicators. Awareness: measure how well employees know the whistleblowing, harassment and discrimination processes and fear of reprisals, with a 2026 target of a "Growing level of information" (page 376). Training: refresher campaigns for anti-corruption, with the target population extended to Getlink Customs Services and Eleclink and, from 2026, to purchasing-related roles; 2025 completion was 86% (page 378). Supplier ethics: the share of priority-category purchases assessed with the new anti-corruption questionnaire is set at 90% by 2030, "Subject to the implementation of a new purchasing portal-type tool before 2030" (page 297).

These are mostly process and coverage targets, not outcome targets such as a number of incidents.

Reference: pages 377-378.

The table shows no fines (EUR 0) and no convictions for violation of anti-corruption and anti-bribery laws in 2025 or 2024. The report states: "No convictions or fines for breaches of legislation on combatting corruption and bribery were imposed on the Group in the 2025 financial year" (page 377). "No cases of corruption were reported in 2025" (page 376). In 2025 eight communications reached the ethics reporting email address; they "consisted of advertising communications" (page 377). The measures to prevent and detect corruption and bribery are described in section 3.4.1 of the Universal Registration Document (page 377).

The CSR trajectory also tracks anti-corruption training: 100% of the 48 executive officer team in 2023, 98% of sales and human resources teams in 2024 and 86% in 2025 (page 378).

Reference: pages 378-379.

Lobbying covers relations with public authorities, excluding those under the Concession Agreement. A responsible lobbying charter was approved by the Board in March 2025, and the public affairs officer on the Executive Committee is responsible (page 378). The Group states it "does not provide any form of financial political contribution", nor in-kind contributions such as facilities, printing or employment for politicians (page 378). No Board member has held a comparable position in public administration in the last five years (page 379).

Issues lobbied include keeping the exemption for the Shuttle activity in the EU rail capacity regulation, entry into service of the EES, enforcement of maritime social dumping rules, biofuel in rail and opposition to "mega trucks" (page 378). Getlink is on the EU Transparency Register and declares the amount spent on representing interests to the HATVP in France; there is no UK equivalent (page 379). It joined the College of Sustainable Development Directors in 2025 (page 379).

Reference: page 379.

"The Group's average payment term in 2025 is 40 days, up one day on 2024." Payment terms are contractual: the standard is 30 days net, ranging from 15 to 60 days; suppliers paid by direct debit, mainly in energy and rental, account for 22% of invoices. These conditions are met in 85% of cases (85% in 2024). No legal proceedings for late payment are in progress, and no financial impact is expected. The indicator covers all external purchases of the Fixed Link entities, Europorte, Getlink, CIFFCO and Getlink Customs Services, excluding Eleclink and internal re-invoicing.

The action plan covers awareness for technical specifiers, easier registration in the management software, system reminders as due dates approach and a simplified payment method for low-value purchases. Late payment of suppliers weakens SME ecosystems and is listed among the material G1 risks (page 374).