Glanbia Plc

Governance roles

Reference: pages 140-141. Directors' Report pages 72-75, 82 and 100 are incorporated by reference for the roles and responsibilities of the Board (page 139).

The Board delegates specific sustainability oversight to its committees. The Sustainability Committee oversees sustainability objectives and performance, including delivery of the sustainability strategy and related IROs, climate included. The Audit Committee oversees the processes and controls used to monitor IROs, the DMA output, the external reporting process and preparation for ESRS compliance. The Remuneration Committee ties the incentive plan to external sustainability targets. The Nomination & Governance Committee oversees that directors get adequate training to oversee sustainability requirements (page 140).

Execution sits with the Group Operating Executive, supported by the Senior Leadership Team at functional level (page 141). The Board has 12 Directors, two executive and 10 non-executive, with a gender ratio of 42% female and 58% male (page 141). A Workforce Engagement Director gives the Board regular feedback on employee engagement (page 141).

"All material IROs were communicated to the Board during the reporting period" (page 140).

Information provided to the administrative, management and supervisory bodies

Reference: page 141.

The Board and its committees received 5 dedicated updates from senior leadership, including the Senior Vice President of Sustainability and the Head of ESG Governance and Reporting, covering climate performance, strategy and the material IROs identified through the DMA (page 141).

The output of the DMA and the climate risk and resilience analysis feeds the Group risk management process. Group Internal Audit includes sustainability processes, controls and reporting in its annual audit planning (page 141).

Topics the Board and committees discussed in 2025 included sustainability performance and targets, climate and environmental risk, the CSRD readiness program, the DMA refresh, food safety and quality, health and safety, whistleblowing and the Code of Conduct, cybersecurity risk and variable remuneration (page 141). Corporate Governance Report pages 79-81 give further detail on Board focus areas (page 141).

Integration of sustainability-related performance in incentive schemes

Reference: page 141.

The Long-Term Incentive Plan (LTIP) for Executive Directors and senior leaders includes sustainability matters with "a weighting of between 10% and 20% of the total outstanding LTIP awards, alongside growth and return measures" (page 141).

Three measures carry the sustainability weighting: progress toward the science-based Scope 1 and 2 emissions targets (E1, pages 157-161), freshwater reduction targets (E3, page 171) and consumer packaging recyclability rates (E5, pages 176-177). The Remuneration Committee oversees the LTIP, sets the targets and reviews performance against them each year. Further LTIP detail is on pages 116-117 of the Annual Report (page 141).

Statement on due diligence

Reference: page 142.

Glanbia maps the core elements of due diligence to sections of the statement in a table (page 142):

• Embedding due diligence in governance, strategy and business model: General Disclosures, pages 140-142.
• Engaging with affected stakeholders: pages 145-146 and 181.
• Identifying and assessing adverse impacts: pages 147-149 (the DMA).
• Taking action on adverse impacts: topic sections, pages 157, 170, 174, 176, 188 and 199.
• Tracking effectiveness and communication: topic sections, pages 158, 171, 174, 176, 190 and 199.

The human rights impact assessment that a third party ran across own operations and the joint venture, plus the EcoVadis and SEDEX processes, are described under S1-1 (pages 185-186).

Risk management and internal controls over sustainability reporting

Reference: page 142.

Glanbia ties the governance of sustainability reporting to its financial reporting and internal control system (page 142). Controls listed: a dedicated ESRS reporting team structure, Basis of Reporting documents in line with ESRS, a sustainability reporting tool, regular review and approval meetings with topic owners on metrics and qualitative disclosures, and pre-audit assessment reviews with third-party advisors on selected data points (page 142).

Sustainability risks run through the Group risk framework: a risk register submitted twice a year, consolidated and presented to the Group Operating Executive and the Board, plus an annual risk review by Group Internal Audit whose findings go to the Audit Committee (page 142). The framework is described further on page 54 of the Annual Report (page 142).

Strategy, business model and value chain

Reference: pages 143-144, 142. Strategic Report pages 12, 14, 46-47, 60 and 62-64 are incorporated by reference (page 139).

Glanbia has three segments: Performance Nutrition (PN, sports and lifestyle nutrition), Health & Nutrition (H&N, nutritional and functional ingredients and premixes) and Dairy Nutrition (DN, cheese and dairy ingredients, with its joint venture). It operates in the Americas, ASPAC and EMEA, sells in over 100 countries, runs 27 manufacturing sites and has over 5,000 employees across 31 countries (pages 143-144).

The value chain graphic names raw materials, packaging, innovation and quality, food manufacturing, distribution, sales, marketing and waste management. Glanbia owns and operates agricultural land next to two dairy manufacturing sites (page 143). The 'Better Nutrition, Better World' sustainability strategy rests on three pillars: planet, people and performance (page 142). Paragraphs 40(b) and (c) are covered by phase-in (page 139).

Interests and views of stakeholders

Reference: pages 145-146.

For the DMA, Glanbia interviewed or surveyed representatives of employees, customers and consumers, shareholders, suppliers, its joint venture partner, local communities and nature representatives (page 145). A table on pages 145-146 sets out, for each group, the topics it cares about, how Glanbia engages and the outcome.

Examples: employees through town halls, pulse surveys, the Workforce Engagement Director and Employee Resource Groups; shareholders through investor meetings, a Capital Markets Day and CDP reporting; suppliers and the joint venture partner through surveys, audits and tenders; regulators, governments, industry associations and NGOs through briefings and multi-stakeholder forums (pages 145-146). The Board is kept informed of stakeholder engagement, see pages 76-77 of the Directors' Report (page 145).

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

Reference: pages 150-151, 142.

Tables on pages 150-151 classify each material IRO and give its time horizon and value chain location. 32 rows:

• Climate: energy efficiency and energy procurement; sustainable agricultural practices; GHG emissions; changing consumer behaviour; GHG reduction commercial benefit; decarbonising the value chain.
• Water and biodiversity: water use in areas at water risk; dairy operations and supply chain in high water stress; deforestation and biodiversity loss from material sourcing; increased regulations and compliance requirements.
• Resource use: packaging waste of finished products; waste within own operations.
• Workforce: workplace accidents and injuries; adequate wages; employee wellbeing; equality and equal pay; inclusion and belonging; training and skills development; responsible sourcing and its process breakdown.
• Consumers and governance: effective labelling; food safety and quality; responsible brand communication; labelling infringement product recall; ingredient solution innovation capabilities; corporate culture; cybersecurity attack.

Seven workforce IROs repeat under S2 as joint venture employees count as value chain workers (pages 149-150). Glanbia states the identified risks and opportunities "did not identify any current financial effects" on its position, performance, cash flows or asset values (page 142).

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

Reference: pages 147-149.

Glanbia ran a DMA first completed in November 2024 and refreshed in October 2025 (page 147). The Audit Committee approved the process and output in October 2025, with final approval at a joint Audit and Sustainability Committee meeting in January 2026 (page 148).

Steps (pages 147-148): understanding the context (business model, value chain mapping, TCFD analysis, Group Risk Register, peer benchmarking, regulatory scan, stakeholder identification); identifying actual and potential IROs from an ESRS-based long list; assessing impacts on an inherent basis by scale, scope, likelihood and irremediability; assessing financial risks and opportunities by potential scale and likelihood after a capital screening analysis; setting a materiality threshold with internal subject matter experts, with IROs scoring above it treated as material.

The assessment was "primarily carried out qualitatively" (page 149). Glanbia "has not specifically screened site locations or screened business activities and assets across our value chain in relation to the topics of ESRS E2 Pollution and ESRS E5 Resource use and circular economy" and has not run targeted consultations (page 149).

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

Reference: pages 211-213.

The content index (page 211) covers "the eight topic standards which are material to Glanbia": E1, E3, E4, E5, S1, S2, S4 and G1. It lists E1-1 to E1-8, E3-1 to E3-4, E5-1 to E5-3 and E5-5, S1-1 to S1-6, S1-9, S1-10, S1-14, S1-16 and S1-17, and G1-1, each with pages (page 211). E4, S2 and S4 appear only under the generic headings Policies, Actions, Targets and Metrics, and a separate G1 Cybersecurity block carries the entity-specific cybersecurity disclosure (page 211).

The Appendix B datapoint table (pages 212-213) marks each datapoint as material, not material, not applicable or phase-in availed of. Datapoints under E1-9, E4, S2 and S4 are marked phase-in. E2-4, E3-1 (paragraph 14), S3-1, S3-4 and G1-4 datapoints are marked not material. Phase-in also covers ESRS 2 paragraphs 40(b), 40(c) and 48(e) (page 139).

Transition plan for climate change mitigation

Reference: pages 157-158.

Glanbia states: "Glanbia does not currently have a formal transition plan in place." It expects to consider adopting one in a strategic review as it nears completion of its 2030 targets, with that review expected to begin within two years (page 157).

In place of a formal plan it describes a medium-term decarbonization plan in line with the Paris Agreement (page 157). Targets: a 50% absolute reduction in Scope 1, Scope 2 and biogenic emissions by 2030, plus a 30% absolute reduction in Scope 3 FLAG emissions and a 25% absolute reduction in Scope 3 non-FLAG emissions, both by 2030 (page 157). Indicative capital need: about $39 million for Scope 1 initiatives over five years and about $5 million for Scope 2 to 2030. Glanbia says these figures "do not represent approved projects or committed expenditure" and remain subject to Board approval (page 157). No locked-in emissions were identified that would compromise the 2030 targets, and the Board approved the targets (page 158). Glanbia is not excluded from the EU Paris-aligned benchmarks (page 157).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 SBM-3 (resilience analysis) and IRO-1, where this content is disclosed in the FY2025 report (pages 148, 154-156). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 154-155.

Senior leaders confirmed in 2025 that the 2024 TCFD qualitative scenario analysis remained valid (page 154). It covers ten physical and transition risks and opportunities across the full value chain, including the joint venture, and uses three scenarios (pages 154-155):

• Current policies, as a baseline.
• 1.5°C transition, consistent with SBTi and the NGFS Net Zero 2050 scenario, time horizon to 2033.
• 3-4°C physical risk, based on IPCC RCP 8.5 and the NGFS Current Policies scenario, time horizon to 2050.

Physical exposure was screened for each manufacturing location using third-party climate models and site coordinates, with a Carbon Trust tool that follows ESRS E1 Appendix A AR 11. Assumptions cover methane regulation, carbon pricing, energy mix and low-carbon technology availability (page 154). The analysis uses its own horizons (0-3, 3-10 and beyond 10 years), which differ from ESRS 2 (page 155).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 154-156). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 155-156.

A results table (pages 155-156) sets each driver against financial impact and mitigants. It rates the expected financial impact as low for the market, reputation, policy, packaging, energy-price and water-scarcity drivers once mitigation applies, and short-to-medium-term exposure to temperature effects on the dairy supply chain as low (pages 155-156). Long-term physical risks may affect dairy viability after 2033, with possible effects on milk supply and input costs (page 156).

On adaptability, Glanbia says "While no fundamental changes were required, targeted adaptations have been introduced to strengthen resilience", including climate risk in business continuity planning for high-risk sites (page 156). It states the timing and magnitude of climate risks "remain uncertain" and that no locked-in emissions are known that could jeopardize its 2030 targets (page 156). The analysis dates from 2024 and was confirmed as still valid in 2025 (page 154).

Policies related to climate change mitigation and adaptation

Reference: page 161.

The Glanbia Environmental Policy, approved by the Board in 2025, is the key policy behind the management of material IROs across E1, E3 and E5. It applies across all operations, including the two joint venture facilities under operational control, and covers parts of the value chain where climate IROs were identified (page 161).

It addresses climate change mitigation, adaptation, energy efficiency and renewable energy. Commitments: pursue emissions targets in line with the Paris Agreement; improve operations through energy-efficient and low-carbon technology, supply chain decarbonization and carbon market participation; build resilience through climate-smart agriculture, continuity planning and product innovation; and adopt renewable energy to decarbonize the value chain (page 161). The Sustainability Committee oversees governance, the Group Operating Executive drives implementation, and the policy is reviewed each year after the DMA (page 161).

Actions and resources in relation to climate change policies

Reference: pages 159-161.

Glanbia lists decarbonization levers with actions (pages 159-161):

• Purchased renewable energy: matched 214,417 energy attribute certificates (up 32.3% on 2024), worth 21,087 tCO2e of reduction; expected contribution 44,731 tCO2e, 17%.
• Energy efficiency: heat pump feasibility study at one site, investment review in early 2026; expected contribution 36,013 tCO2e, 14%.
• Thermal energy efficiency and low-carbon heat: many small energy efficiency projects, with no firm data yet to quantify their 2025 effect. Glanbia expects zero tCO2e of reduction from this lever because organic growth offsets it.
• On-farm partnership: emissions assessments of 13 Idaho farms (23% of Idaho milk volume), roadmaps for 10, and a co-funded manure management pilot with a strategic customer.
• Supply chain: adopted the US Dairy Stewardship Commitment, completed Stage 3 of Sustainable Dairy Partnership verification and began life cycle assessments.
• Transport: a global forum gathered primary shipment data for about 80% of transport spend.

Resources are budgeted in normal financial planning, and Glanbia says the actions "all fall under business as usual" (page 158). As this is the first ESRS year, no progress against prior-period actions is reported (page 161).

Targets related to climate change mitigation and adaptation

Reference: pages 158-160.

Three absolute targets, all validated by the SBTi (pages 158-160):

• Scope 1, 2 (market-based) and biogenic: 50% reduction by 2030 from 2018, in line with 1.5°C. 2025 emissions were 212,779 tCO2e against 233,365 in 2024 (-8.8%) and a 266,589 base year (-20.2%). Glanbia says it is behind the linear trajectory because of the 2021 start-up of a joint venture dairy plant in Michigan (page 159).
• Scope 3 FLAG (dairy sourcing): 30% reduction by 2030 from 2023. 7,441,778 tCO2e in 2025 against 8,455,553 in the base year (-12.0%), 78% of Scope 3 (page 159).
• Scope 3 non-FLAG: 25% reduction by 2030 from 2023, in line with a 1.75°C scenario. 2,052,665 tCO2e against 2,647,824 (-22.5%) (page 160).

Progress is reviewed quarterly and at Sustainability Committee meetings, and no targets or methods changed (pages 158-159).

Energy consumption and mix

Reference: pages 162-163.

Total energy consumption in 2025 was 1,256,648 MWh (624,876 wholly-owned, 631,772 joint venture), against 1,215,015 MWh in 2024 (page 162). Fossil sources supplied 878,273 MWh, or 69.9%, of which natural gas was 758,621 MWh. Renewable sources supplied 378,375 MWh, or 30.1%, up from 28.0% (page 162). Fossil use rose mainly on higher natural gas consumption (page 163).

Energy intensity was 0.82 MWh per tonne produced (0.81 in 2024) and 213 MWh per million USD of net revenue (214 in 2024). All revenue-generating activity is food manufacturing, which Glanbia treats as a high climate impact sector (pages 162-163). Self-generated renewable energy was 52,056 MWh and no non-renewable energy was generated internally (page 162). The 2024 figures are adjusted for the 53rd week (page 162).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 163-168.

Emissions in 2025 (tCO2e, pages 163-164): Scope 1 was 150,088 (+4.6% on 2024); Scope 2 was 132,355 location-based and 47,296 market-based (-31.9%); Scope 3 was 9,600,403 (-9.3%). Totals were 9,882,846 location-based and 9,797,787 market-based. Biogenic emissions were 15,331. Market-based intensity was 1,657.3 tCO2e per million USD of net revenue (page 164).

Purchased goods and services was the largest Scope 3 category at 9,024,819 tCO2e (page 163). Scope 3 covers 11 of the 15 GHG Protocol categories, and only 6.7% was calculated with primary emission factors (page 166). No Scope 1 emissions come from regulated emission trading schemes (page 165).

Base years are 2018 for Scope 1 and 2 and 2023 for Scope 3. The joint venture is included under operational control (pages 163-165).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 164.

Glanbia reports a nil position. It states that "During 2025, the Group did not engage in the acquisition of carbon credits through voluntary market mechanisms, nor did it implement or utilise GHG removal or storage initiatives within its own operations or across its value chain" and that it "is not exploring enhancing natural sinks or applying technical solutions to remove GHGs from the atmosphere" (page 164).

The content index lists E1-7 at page 165 and the Appendix B table marks the E1-7 datapoint as material (pages 211-212). Carbon credits appear only as a possible opportunity: installing anaerobic digesters in the value chain could contribute to climate targets and generate carbon credits (page 154).

Internal carbon pricing

Reference: page 164.

Glanbia reports a nil position. It states that "The Group does not currently apply internal carbon pricing mechanisms in its decision-making processes" and that it continues to monitor developments in carbon pricing frameworks and assess their relevance to its operations and strategic planning (page 164).

The content index lists E1-8 at page 165 (page 211). Carbon pricing also appears as a policy assumption in the resilience analysis scenarios (page 154).

Policies related to water and marine resources

Reference: page 170.

The Glanbia Environmental Policy governs water management. Its stated goal is to reduce material water withdrawals and consumption. Principles: operational efficiency (equipment cleaning, cooling, milk processing); stewardship (water recovery, reuse and recycling, storage optimization); risk-based assessment with industry tools; wastewater controls at sites with material discharges; upstream engagement to support dairy farmers in high-water-stress areas; and metrics reported against targets (page 170). The policy covers the wholly-owned business and the joint venture, with particular attention to sites in water-stressed regions (page 170).

Glanbia has no specific policy on oceans and seas, "as it is not deemed a material sub-topic" (page 170). The Appendix B table marks E3-1 paragraph 9 as material and paragraph 14 as not material (page 212).

Actions and resources related to water and marine resources

Reference: pages 170-171.

A dedicated Water Experts Team (internal specialists, site representatives and external engineering consultants) works on freshwater withdrawal at the dairy processing sites, including the US joint venture plants. It reports progress and savings quarterly to the Group Operating Executive (page 170).

2025 actions (page 170): improved clean-in-place procedures using more water-efficient cleaning agents and wash timing matched to recovered water availability; upgrades to polishing and reverse osmosis units to recover more water from milk processing. 2026 plans: commission approved condensate recovery projects and assess further recycling opportunities (page 170).

Upstream, Glanbia has "not yet established specific actions or targets to manage upstream water consumption in high-water-stress areas" and plans an update in the 2026 statement (page 170). On its Idaho farmland it applies treated plant wastewater to cut freshwater withdrawals (page 171). Resources are budgeted as business as usual (page 170).

Targets related to water and marine resources

Reference: page 171.

Glanbia set a voluntary 10% absolute reduction in freshwater withdrawal by 2025 from a 2021 base year, covering all manufacturing sites, warehouses and offices, including two joint venture facilities (page 171). It describes the target as a stretch ambition "not based on conclusive scientific evidence", and it is built into the LTIP of Executive Directors (page 171).

Result: freshwater withdrawal fell 8.7%, from 5,638,208 m3 in 2021 to 5,144,957 m3 in 2025, so the target was missed. Glanbia attributes the miss largely to reduced availability of recovered water at the joint venture's New Mexico facility. Performance improved from -1.3% in 2024 (page 171). A new target will be set in 2026 once the strategic approach is reviewed (page 171).

No measurable target exists for agricultural water use; Glanbia tracks effectiveness through daily visual checks of crop moisture stress and twice-weekly soil moisture checks (page 171).

Water consumption

Reference: pages 172-173.

Glanbia reports mandatory ESRS metrics and entity-specific metrics for wholly-owned operations and joint venture manufacturing facilities (page 172). Total water consumption in 2025 was 9,597,245 m3 (+0.8% on 2024): water consumption (manufacturing) 1,727,193 m3 (+12.7%) and water consumption (agriculture) 7,870,052 m3 (-1.4%). Total consumption in areas at water risk, including areas of high water stress, was 9,527,945 m3, and water recycled and reused was 2,856,660 m3 (-1.2%) (page 172).

Entity-specific metrics (page 172): freshwater withdrawal (manufacturing) 5,204,989 m3 (-6.0%), of which 4,092,109 m3 in areas at water risk; water recovered (manufacturing) 5,374,263 m3; total water discharged (manufacturing) 8,852,057 m3 (-4.9%). Intensity was 1.13 m3 of consumption and 3.39 m3 of freshwater withdrawal per tonne of production (page 172). Glanbia counts 18 manufacturing sites in areas of high water stress or water risk (page 173), and reports zero recycled water for sites that cannot meter it (page 173).

Policies related to resource use and circular economy

Reference: pages 175-176.

The Glanbia Environmental Policy governs the material resource use and circularity impacts. Its circularity section sets objectives to reduce, reuse and recycle waste across the value chain, with a focus on avoiding food waste by diverting surplus to animal feed (page 175). It also commits to proper end-of-life disposal of consumer packaging through consumer education and packaging designs that follow regional circular design guidelines (page 175).

The waste approach has three tiers: prevention (food waste reduction, following Food Loss and Waste protocols); reuse and recycling (a commitment to TRUE zero waste certification); and recovery and disposal where reuse or recycling is not feasible (page 175). The policy also asks for responsibly sourced products and packaging and a shift from virgin to recycled resources or lighter packaging design (page 176).

Actions and resources related to resource use and circular economy

Reference: page 176.

Resources are budgeted as business as usual (page 176). Packaging (PN): a Sustainable Packaging Working Group meets monthly, backed by quarterly brand groups and monthly technical groups. In 2025 it advanced flexible packaging projects, including a market pilot of 500,000 recyclable bar wrappers. Glanbia belongs to the Sustainable Packaging Coalition, the Association of Plastic Recyclers, WRAP and RECOUP, and uses How2Recycle (North America) and OPRL (UK) labels for region-specific disposal instructions (page 176).

Operational waste: a dedicated team works on the most material waste-producing sites. In 2025 it changed waste data definitions and processes, so animal feed now counts as food surplus and leaves the food waste target scope. The team focused on getting sites that had not yet qualified to divert 90% or more of non-hazardous waste from landfill or incineration, to meet the TRUE standard. In 2026 Glanbia will revisit its 2030 food waste target and plan a new TRUE target (page 176).

Targets related to resource use and circular economy

Reference: pages 176-177.

• Packaging (finished products, PN): a voluntary target that 100% of PN branded consumer packaging is recyclable, reusable or compostable by 2030, measured against all PN branded products sold in the year and calculated by packaging weight (page 176). The recyclable share was 88% in 2025, 84% in 2024 and 62% in 2022 (the first year), against an interim target of 83% by 2025. The target is in the Executive Directors' LTIP, and Glanbia says it "is not based on conclusive scientific evidence" (pages 176-177).
• TRUE certification: 100% of 16 legacy manufacturing facilities certified by 2025. 15 of 16 (94%) were certified in 2025, and the last site is due to submit by the end of H1 2026 (page 177).
• Food waste (under development): an ambition to cut food waste 50% by 2030, measured in kilograms, across all manufacturing sites including the joint venture. Glanbia is validating the baseline year under a new accounting method and expects to convert it into a measurable target in 2026 (page 177).

Resource outflows

Reference: pages 177-179.

The content index lists this disclosure as "E5-5: Resource outflows: waste" (page 211), and the Appendix B table marks the E5-5 datapoints for waste (paragraphs 37(d) and 39) as material (page 213). The statement reports waste data, covered under E5-5-Waste, plus one entity-specific outflow metric: the share of PN consumer packaging that is recyclable, reusable or compostable, 88% in 2025 against 84% in 2024, 76% in 2023 and 62% in 2022 (page 178).

Glanbia says it defines the metric by recyclability only; the definitions for reuse and compostability "are to be determined", so no packaging is reported under them (page 179). The E5 chapter gives no data on product durability, repairability or recycled content.

Waste

Reference: pages 177-179.

The Group generated 369,565,935 kg of waste in 2025 across wholly-owned operations (334,560,586 kg) and the joint venture (35,005,349 kg) (page 178). Of this, 362,966,679 kg was diverted from disposal: 345,824,914 kg recycled, 17,125,526 kg prepared for reuse and 16,239 kg through other recovery. 6,599,256 kg went to disposal: 5,674,114 kg landfill, 863,712 kg incineration and 61,430 kg other (page 178).

Non-recycled waste was 23,741,021 kg, or 6.4% of the total. Hazardous waste generated was 210,359 kg and radioactive waste was zero. Food waste was 14,317,442 kg with 94.1% diverted by recycling (page 178). Animal feed is classed as food surplus from 2025 and excluded from food waste (page 179).

Data comes mainly from waste contractor invoices, with estimates where measurement is missing, and recycling follows the TRUE standard definition (page 179).

Policies related to own workforce

Reference: pages 184-186.

Glanbia's policies apply to everyone employed by or engaged to provide services to Glanbia and its joint venture operations, including agency workers and contractors unless stated otherwise. The Chief Human Resources Officer is accountable for implementation (page 184). By topic (pages 184-186):

• Health and safety: the EHS Policy sets the 'Zero Harm' objective and requires every site to run the Glanbia Risk Management System. The Chief Supply Chain Officer sponsors the EHS Leadership Team.
• Working conditions: a Wellbeing Policy, with family leave procedures, and an Adequate Wage Policy (statutory minimum or better, equal pay for equal work).
• Inclusion and development: an Inclusion and Belonging Policy with zero tolerance for discrimination, and a Development Policy.
• Human rights: a Human Rights Policy in line with the UN Guiding Principles, the ILO Declaration and the OECD Guidelines, opposing forced labor, child labor and trafficking.

A third-party human rights impact assessment found no Glanbia operation at significant risk of forced, compulsory or child labor (page 185). The Appendix B table marks S1-1 paragraphs 20 to 23 as material (page 213).

Taking action on material impacts on own workforce

Reference: pages 188-189.

All actions "fall under business as usual" and are budgeted in financial planning (page 188).

• Health and safety, 2025: set up an EHS Centre of Excellence; updated the risk management system and EHS Policy; pushed peer-to-peer observation and near-miss reporting; improved the monthly site safety dashboard; ran third-party audits of site compliance (pages 188-189). For 2026, it will use near-miss and root-cause reporting to drive process change (page 189).
• Working conditions: wellbeing weeks, the 'Cheers!' recognition platform and better benefits such as health insurance, plus a salary inventory review to support pay metrics (pages 188-189).
• Inclusion: a talent review for senior succession, a refresh of the Employee Resource Group structure and an 'Inclusive Leadership' module (page 189).
• Development: a leadership program for emerging leaders, the foundational 'Leading the Glanbia Way' program and a new 'Development Days' initiative (page 189).

Targets related to own workforce

Reference: page 190.

Glanbia sets Total Recordable Incident Rate (TRIR) and Lost Time Incident Rate (LTIR) targets each year to beat the NAICS industry benchmark. They apply to wholly-owned and joint venture sites. The FY2025 benchmark rates were 3.60 TRIR and 2.60 LTIR on the OSHA basis of 200,000 hours (page 190).

Results: wholly-owned TRIR 7.0 and LTIR 2.3 per million hours worked, or 1.4 and 0.5 on the OSHA basis. Joint venture TRIR 15.0 and LTIR 9.3, or 3.0 and 1.9 on the OSHA basis (page 190). On those OSHA-basis figures both are below the benchmark rates. A new target will be set for 2026 (page 190).

For working conditions, inclusion and development, "Specific quantitative targets and a base year have not been adopted", and Glanbia is evaluating what targets to set (page 190).

Characteristics of the undertaking's employees

Reference: pages 191-192.

Headcount is the 2025 average for wholly-owned operations and excludes non-employees and joint venture staff (page 191). The joint venture has 681 employees, reported separately (page 181).

• Total employees: 5,056, of whom 3,051 male, 2,003 female and 2 other.
• Contract type: 4,963 permanent, 93 temporary and none on non-guaranteed hours.
• Region: North America 3,400, EMEA 1,198, ASPAC 325 and LATAM 133.
• Country: USA 3,299 and Ireland 550, the countries with 50 or more employees and at least 10% of the total.
• Turnover: 21%, with 1,076 leavers (page 191).

Sweetmix, acquired in August 2025, counts for the full year, while the divested SlimFast and Body & Fit businesses are excluded. A pro-rata calculation would add 74 employees (page 191). Definitions of employees, non-employees and turnover are on page 192.

Diversity metrics

Reference: page 192.

Senior management, defined as executives plus all employees in the top three employee band categories, numbered 106: 76 male (72%) and 30 female (28%), with none other or undisclosed. Employees of the recently acquired Sweetmix are not included because their bands are not yet assigned.

Age distribution of all 5,056 employees: under 30, 963 (19%); 30 to 49, 2,826 (56%); 50 and over, 1,267 (25%).

Both tables use the average over the reporting period. Gender comes from self-reported data in the SuccessFactors HR system (page 192). Board gender ratio, 42% female and 58% male, is under GOV-1 (page 141).

Adequate wages

Reference: page 193.

Glanbia states: "During 2025, Glanbia's employees, as described in S1-6 on page 192, were paid an adequate wage in line with applicable benchmarks." To test this it compared pay requirements, based on industry standards, country by country (page 193).

Payroll data covered base salary, fixed allowances and variable pay, excluding overtime. Base pay is an annualized figure from October 2025, after the July 2025 pay review. Because that date does not match the financial year, Glanbia ran checks and found no material differences in headcount, promotions or out-of-cycle increases (page 193). The Adequate Wage Policy covers Group employees only (page 184), and adequate wages is a material positive impact (page 183).

Health and safety metrics

Reference: page 194.

Glanbia reports zero fatalities from work-related injury or ill health in 2025 across wholly-owned and joint venture sites, and says 100% of its own workforce is covered by the health and safety management system (page 194). Table of results (page 194):

• Recordable accidents: 77 wholly-owned (66 employees, 11 non-employees), 21 joint venture and 98 in total.
• TRIR per million hours: 7.0 wholly-owned, 15.0 joint venture and 8.0 in total.
• Lost time cases: 25 wholly-owned, 13 joint venture and 38 in total.
• LTIR per million hours: 2.3 wholly-owned, 9.3 joint venture and 3.1 in total.

On the OSHA 200,000-hour basis the Group TRIR is 1.6 and LTIR 0.6 (page 194). Joint venture workers count as S2 value chain workers under ESRS but are included because of operational control (page 194). Glanbia lists the ill-health and days-lost part of S1-14 among its phase-in provisions (page 139), and the table reports no ill-health cases or days lost.

Compensation metrics (pay gap and total compensation)

Reference: page 193.

The gender pay gap for 2025 is "favourable to male employees by 1.16%", measured as the difference between average female and male pay as a percentage of average male pay. The annual total remuneration ratio of the highest paid individual to the median employee, excluding that individual, is 57.52 (page 193).

Glanbia notes that much of the CEO's pay comes through short-term and long-term incentive plans tied to Group performance and share price, so the ratio can swing from year to year (page 193). Payroll data covers base salary, fixed allowances and variable pay, annualized from October 2025, with variable pay summed over twelve months (page 193). The Appendix B table marks S1-16 paragraphs 97(a) and 97(b) as material (page 213).

Incidents, complaints and severe human rights impacts

Reference: page 195.

The metric covers incidents and complaints from the own workforce and from people linked to Glanbia through business relationships, captured through HR processes and the independent Safecall facility (page 195). 2025 results (page 195):

• 34 incidents of discrimination, including harassment.
• 58 complaints filed through channels for the workforce to raise concerns. Glanbia says "all 58 were reviewed and 91% have been closed following review and relevant action".
• 0 complaints filed to OECD National Contact Points.
• 0 severe human rights incidents, with $0 in fines or compensation for them.

The Appendix B table marks S1-17 paragraphs 103(a) and 104(a) as material (page 213).

Business conduct policies and corporate culture

Reference: pages 202-203, 205.

Corporate culture is the only G1 sub-topic assessed as material: a positive potential impact (Glanbia's strong corporate culture) and a risk (breakdown of corporate culture), both in own operations over the medium term (page 202).

The Code of Conduct is the core policy. Its objective is to embed the ethical standards and behaviors expected of employees, so business is conducted with integrity, transparency and accountability, and it defines Glanbia's core values. Its commitments cover health and safety and the environment, honesty and respect toward people, compliance with applicable laws, corporate governance, and customers, consumers and suppliers. Breaches can lead to disciplinary action up to dismissal or, for contract staff or suppliers, cancellation of contract. The Audit Committee oversees the Code and the Group CHRO leads implementation (page 202).

The Speak Up Policy bars retaliation and offers the independent 'Safecall' line to employees and external parties, including value chain workers. The Group Secretary and Head of Investor Relations investigates concerns (page 203). An Anti-Bribery and Corruption Policy and a Board-approved Animal Welfare Policy also apply (page 205). Cybersecurity is a separate entity-specific topic (page 206).

Targets related to business conduct

Back-filled from the G1 'Metrics and Targets' section, where business conduct targets sit as MDR-T content rather than a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: page 204.

Glanbia sets one target: 100% of eligible employees complete Code of Conduct training every two years. In 2025, 90% completed it, a 10% gap that Glanbia says it will keep working to close. Senior leadership set the target internally, without further stakeholder involvement (page 204). Employees not yet onboarded to the HR system after an acquisition (2% of eligible employees) and those in regions with labor participation rules (7%) are excluded from the metric (page 204).

For Safecall concerns, 0.30 cases were reported per 100 employees in 2025, and Glanbia deemed a target "not to be appropriate" for that metric (page 204). Targets and metrics for the separate cybersecurity risk are withheld as sensitive under ESRS 1 section 7 (pages 138, 206).