Groupe Bruxelles Lambert (GBL)

As at December 31, 2024, out of a total of eleven members, GBL's Board included six representatives proposed by the controlling shareholder, Pargesa SA. The shareholding structure dictates the composition of the Board of Directors. It deviates from Article 3.7 of the 2020 Belgian Code on Corporate Governance, which suggests a Board composition such that no individual Director or group of Directors is able to control decision-making. This control structure also justifies the presence, as at December 31, 2024, of representatives proposed by the controlling shareholder, Pargesa SA, on the Audit Committee (two members out of four) and Governance and Sustainable Development Committee (one member out of three).

Over the years, GBL has gradually increased the number of women on its Board and Committees, in accordance with the Law of July 28, 2011, which aims to guarantee the presence of women on the Board of Directors of listed companies. As at the date of this consolidated sustainability statement, out of a total of eleven members, GBL's Board of Directors welcomed four female Directors (36%).

As at December 31, 2024, GBL's Board of Directors had ten non-executive Directors (91%) and one executive Director (the Chief Executive Officer) out of a total of eleven members. The Company ensures the presence and contribution of Directors from different backgrounds and with diverse skills, as well as a sufficient number of independent Directors (four independent Directors (36%) out of the total of eleven members), thereby ensuring that the interests of all the Company's shareholders are respected.

Employees and other members of GBL's workforce are as at the date of this consolidated sustainability statement not represented in GBL's Board of Directors.

GBL's executive management ("C-level") is composed of three senior officers: the Chief Executive Officer, the Chief Financial Officer, and the Corporate Secretary and Chief Operating Officer.

GBL's Board of Directors oversees IRO-related strategic orientations, policies, projects, resources, performance, reporting and related processes.

In that process, GBL's Board of Directors devotes a significant part of its activity to the development of the group's strategic plans and, in particular, to the examination of investment and divestment projects. The Board of Directors also holds a yearly review with the CEO and the Head of ESG of the strategy, policies, actions and performance implemented to address material IROs covering both GBL as a "responsible company" and GBL as a "responsible investor". Additionally, the Board of Directors is informed at each meeting of the latest significant developments related to material IROs via a dedicated section in the CEO letter. Furthermore; and considering the ESG integration process implemented at GBL, each investment memo submitted to the Board of Directors by the CEO contains by default key material IROs findings and implications for the relevant investment case.

The Governance and Sustainable Development Committee reviews and assesses IROs related to GBL acting in its capacity as a "responsible company" on an on-going. Conclusions from each Governance and Sustainable Development Committee meetings are reported to the Board of Directors by its Chairwoman.

In application of the ESG integration approach, the Audit Committee reviews and assesses on a yearly basis the risks inherent to GBL acting as a "responsible investor", including an IRO-specific risk assessment performed as part of the portfolio monitoring process.

In accordance with the CSRD requirements as implemented into Belgian law, the tasks of the Audit Committee have been extended in 2024 to monitor sustainability reporting including: (i) informing the Board of Directors about the outcome of the assurance of sustainability reporting, and how the assurance contributed to the integrity of sustainability reporting, including what the role was of the Audit Committee in the process; (ii) monitoring the sustainability reporting process; (iii) monitoring the internal control and risk management systems with regards to sustainability reporting; (iv) monitoring the assurance of sustainability reporting and; (v) monitoring the independence of the independent assurance provider.

GBL's Board of Directors ensures that appropriate mechanisms for performance monitoring are in place through several key actions: (i) the Board of Directors is supported by its Committees (Audit Committee, Governance and Sustainable Development Committee) to oversee strategic decisions, financial and sustainability reporting, risk management and compliance, and performance; (ii) regular meetings are conducted to review strategic initiatives, investment activities, operational activities, financial and sustainability performance as well as internal controls; (iii) GBL refers to various performance metrics and key performance indicators ("KPIs") to monitor and assess performance across the different dimensions covered by material IROs as reflected in its remuneration policy; and (iv) GBL engages with stakeholders on a regular basis like for example General Meetings and other forums to align company performance with stakeholders' expectations.

Integration of sustainability-related performance in incentive schemes

Overview

GBL has put in place a sustainability-related incentive scheme for its Chief Executive Officer. For detailed information, please refer to the Corporate Governance chapter of the Annual Report (§2.3 Remuneration policy, page 10).

Roles Covered

The sustainability-related incentive schemes apply to GBL's Chief Executive Officer.

Specific Sustainability KPIs

The incentive scheme includes climate-related considerations. Specifically, sustainability-related performance in incentive schemes is integrated through:

• SBTi Target #2: 100% of eligible portfolio positions with climate strategy and targets aligned with a 1.5°C pathway approved by SBTi by 2030 from a 2020 baseline. For this target, an intermediary target of 66% coverage (vs. 50% initially) by 2025 has been retained.

Performance Period and Target Structure

• Baseline year: 2020 (coverage stood at 0%)
• Intermediary target: 66% coverage by 2025
• Final target: 100% coverage by 2030

Link to Short-term or Long-term Incentive

The disclosure references integration into the CEO's remuneration policy, but does not explicitly specify whether this is linked to short-term incentive (STI) or long-term incentive (LTI).

Approval and Update Process

The Remuneration Policy is submitted for vote to GBL's Ordinary General Meeting on a regular basis and was last approved on May 2, 2024.

References to Other Documents

For comprehensive details on the remuneration policy and the specific integration of sustainability-related performance metrics, please refer to:

• Corporate Governance chapter of the Annual Report (§2.3 Remuneration policy, page 10)
• ESRS 2 GOV-3 disclosure (page 40)

GBL's due diligence process is supporting GBL's sustainability statement disclosures at each and every stage of the definition and implementation of its strategy towards sustainable IROs.

Contribution from due diligence to governance, strategy and business model

Contribution of stakeholders' engagement

Contribution to identification and assessment of adverse impacts

Support to the definitions of the range of actions (including transition plan)

For information on the internal control process over the sustainability reporting process, please refer to Risk management chapter of the Annual Report (§3.2.3 Risks specific to GBL, page 64 and §3.2.4 Control activities implemented by GBL, page 65).

GBL is an established investment holding company, with over seventy years of stock exchange listing. As a leading European investor, focusing on long-term and sustainable value creation and relying on a stable and supportive family shareholder base, GBL strives to maintain a diversified high-quality portfolio composed of global companies, leaders in their sector, in which it can contribute to value creation by being an engaged professional investor.

As an investment holding company, GBL has adopted a dual approach in structuring its sustainability strategy deriving directly from its twofold responsibility and approach to investments:

– GBL as Responsible Company (also referred to as "Responsible Corporate"), consisting of the parent company GBL and its direct and indirect subsidiaries having, as their main activity, the management of investments. In this respect, GBL has potential sustainability impacts, risks and opportunities linked to its role as an employer and contributor to the communities in which it operates; – GBL as Responsible Investor, which encompasses the companies within GBL's portfolio (whether controlled or not, including GBL Capital's portfolio). Those companies identify and address their sustainability impacts and associated risks and opportunities within the framework of their own internal controls and governance. Paramount in the sustainability strategy and business model of GBL in this context is the ESG integration approach implemented through the investment cycle (pre-/post investment phase), independently of the characteristics of the assets (whether controlled or not).

GBL's core processes therefore relate to: (i) investment pre-investment phase (origination, due diligence) and post-investment phase (value creation and monitoring, divestment); and (ii) supporting operations.

Intrinsic to the nature of its investment holding activity, GBL has a rather limited exposure to upstream value chain, mainly via the business relationships it maintains with a potential large pool of financial service providers (e.g. auditors, financial advisors and consultants, lawyers), its landlords (offices) and its suppliers of mobility services (e.g. mobility devices provided by GBL to its own workforce).

In accordance with ESRS 1 §63, EFRAG IG 2 §26, §66 and §67, GBL's non-controlled portfolio participations (being listed or private portfolio companies, including GBL Capital's portfolio) form part of GBL's business relationships which are deemed to form part of GBL's value chain as investments.

As an investment holding company deploying permanent capital, GBL has no customers.

The purpose of GBL's stakeholder engagement process is to enable GBL to identify key stakeholders' potential interests and concerns based on an ongoing interaction and dialogue between GBL and its key identified stakeholders. It supports the identification and definition of sustainability topics and related IROs to which GBL will apply criteria for assessing potential impact and financial materiality, and supports the formulation of strategies, policies, action plans, and targets to mitigate material impacts and risks. It ensures that GBL shares on a regular basis these developments and achievements with the key identified shareholders. In 2024, GBL conducted its DMA process for the first time in accordance with ESRS 1 section 3 and EFRAG IG 1 requirements.

In accordance with ESRS 1 section 3.1, the stakeholders identified by GBL are spread over the following categories:

(i) Affected stakeholders: it covers the individuals or groups whose interests are affected or could be affected – positively or negatively – by GBL's activities and its direct and indirect business relationships across its value chain as well as "nature" as a silent stakeholder. Under this category, GBL identified the controlled portfolio companies and GBL's workforce;

(ii) Users of sustainability statements: it covers the primary users of general-purpose financial reporting and other users of sustainability statements, including the undertaking's business partners, social partners, civil society and non-governmental organizations, governments, analysts and academics. Under this category, GBL identified the financial institutions GBL is working with;

(iii) As highlighted in ESRS 1 section 3.1, some stakeholders can belong to these two categories. It is typically the case for shareholders and their elected representatives like GBL's Board of Directors and the representatives of the controlling families as well as the external support such as notably auditors, lawyers or consultancy firms. It also covers the landlords and facilities sub-contractors.

Considering the nature of the contractual and commercial relationships between GBL and the stakeholders referenced in financial services and landlords & facilities contractors above, GBL considers that sustainability topics and related IROs for these groups are not relevant for its own stakeholder engagement strategy and they have therefore not been retained in the list of key stakeholders.

"Nature" as a silent stakeholder has also been considered by GBL in its mapping of the value chain and the mapping of the stakeholders. Considering the characteristics of GBL's operations, mainly being an office activity, "nature" has been considered as non-relevant for GBL and has therefore not been retained in the list of key stakeholders.

In 2024, GBL's stakeholder engagement was conducted via direct interviews with the representatives from the different categories of stakeholders mentioned above. The interviews conducted with the internal and external stakeholders are based on scripts addressing a set of questions based on the profile and expertise of the stakeholders and their outcome is documented via the drafting of minutes.

GBL's Board of Directors and Audit Committee are informed about the views and interests of affected stakeholders with regards to sustainability-related impacts on a yearly basis. The outcome of GBL's stakeholder engagement supports the identification, definition and validation of material IROs retained by GBL as part of the DMA exercise. The key stakeholders involved in GBL's engagement process in 2024 are directly involved in the formulation and execution of GBL's strategy as well as the implementation of GBL's business model.

Through the DMA process, GBL identified the following impacts as material:

(i) Climate change - Climate change mitigation: "Climate change mitigation" sub-topic is an actual negative material impact over a long-term time horizon. It relates to the group's emissions and their impact on climate change, and encompasses GBL's endeavors to contribute to the general process of limiting the increase in the global average temperature to 1.5°C above pre-industrial levels in line with the Paris Agreement, GBL's own operations GHG emissions as defined by the GHG Protocol and the associated transition risks;

(ii) Own workforce – Equal treatment and opportunities for all – Training and skills development: "Training and skills development" sub-sub-topic is a positive actual material impact over a medium term for GBL's own operations. It relates to individualized coaching, mentoring and educational programs such as leadership courses and bespoke training sessions. Such programs positively support GBL's own workforce overall expertise, skills, knowledge and productivity and improve satisfaction and employee retention;

(iii) Business conduct – Corporate culture: "Corporate culture" sub-topic is a positive actual material impact over a long-term time horizon. Corporate culture expresses goals through shared values and beliefs. It guides GBL's activities and own operations through shared assumptions and norms such as values or mission statements. It brings positive impact as it is heightening GBL's brand identity, it is supporting GBL's ability to attract higher-caliber candidates, it is fostering a healthy work environment and it is increasing satisfaction and productivity;

(iv) Entity specific – Philanthropy: "Philanthropy" entity-specific sub-sub-topic is a positive actual material impact over a medium-term horizon. Carried out under the GBL ACT initiative and related to GBL's own operations, GBL's philanthropic activities are conducted under a truly philanthropic philosophy and approach aiming for a local positive impact across well-defined areas of intervention like education, healthcare, environmental protection or social justice. Beyond the positive local contribution to the environment and the society, GBL ACT supports own workforce motivation and retention;

(v) Entity specific – ESG integration: "ESG integration" entity-specific sub-sub-topic is a positive actual material impact over a medium-term horizon. Defined by the PRI as "the explicit and systematic inclusion of ESG issues in investment analysis and investment decision", ESG integration generates positive impact on GBL's portfolio participations sustainability journeys and achievements via a systematic engagement on material IROs at Board level and with the relevant senior management representatives of portfolio's participations.

Through the DMA process, GBL identified the following risks and opportunities as material:

(i) Own workforce – Working conditions – Adequate wage: "Adequate wage" sub-sub-topic is a risk over a medium-term time horizon. For its own operations, GBL's ability to access the right pool of talents in the financial industry in Continental Europe may require providing own workforce with market-competitive remuneration packages to ensure talent attraction and retention. The inability of GBL to provide such market-competitive remuneration packages may impede its ability to properly execute its strategy. GBL's Remuneration Policy is addressing this risk;

(ii) Business conduct – Corporate culture: "Corporate culture" sub-topic is a risk over a long-term time horizon. Corporate culture expresses goals through shared values and beliefs. It guides the undertaking's activities and the conduct of its own operations through shared assumptions and norms such as values or mission statements and the Code. The inability of GBL to ensure a strict adherence to GBL's values and the different codes, policies and processes driving GBL's investments and day-to-day activities may impact GBL's reputation and reliability. GBL's values and the Code address this risk;

(iii) Business conduct – Corruption and bribery - Incidents: "Incidents" sub-sub-topic is a risk over a short-term time horizon. Business ethics incidents cover for GBL any incident related to fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice or other financial industry laws or regulations happening in its own operations. The inability of GBL to ensure strict compliance with financial industry laws or regulations may affect GBL's reputation. GBL's Code addresses this risk;

(iv) Entity specific – ESG integration: "ESG integration" sub-sub-topic is a risk over a long-term time horizon. Defined by the PRI as "the explicit and systematic inclusion of ESG issues in investment analysis and investment decision", the inability of GBL to enforce a proper integration of ESG factors in pre-investment cycle (exclusion policy, ESG proprietary rating, ESG due diligence) and post investment cycle (ESG strategic plan, ESG engagement, ESG risk monitoring, stewardship, exit) may affect GBL's reputation and the performance of its investment activities. GBL's ESG Policy addresses this risk.

GBL aims to ensure the resilience of its strategy and business model by ensuring the identification and mitigation of material IROs on an ongoing basis under the process described above.

For GBL in its capacity as a "responsible company", the DMA methodology is based on four main steps, being (i) the identification of the sustainability landscape; (ii) the identification of an initial list of IROs supported by stakeholder engagement; (iii) the assessment of impact and financial materiality, and (iv) the mapping of the list of ESG topics and material IROs.

Identification of sustainability landscape

The initial step of the DMA focuses on outlining the sustainability landscape specific to GBL and its primary operations, as well as identifying key stakeholders impacted and their respective contributions. This step supports the investigation of potential material ESG topics to assess in a next phase the potential IROs.

During this step, the following tasks are performed: (i) the analysis of GBL's strategy, financial statements and ESG reporting covering the previous periods; (ii) a review of the economic activities and their geographic locations; (iii) a mapping of the business relationships in upstream and/or downstream value chain, including type and nature of business relationships; (iv) an understanding of the affected stakeholders and their potential interests; (v) the consultation of published information from peers; and (vi) the analysis of GBL's relevant legal and regulatory landscape.

Identification of an initial list of IROs supported by stakeholder engagement

Stakeholder engagement supports the identification and definition of the list of the sustainability topics and related IROs to which GBL will apply criteria for assessing potential impact and financial materiality and determining the material information to be disclosed. Leveraging on the stakeholder mapping performed by GBL, a dialogue is initiated via interviews with a selection of different internal and external stakeholders in order to identify and evaluate potential material ESG topics and matters related to GBL's corporate activities.

To ensure the stakeholders' views and interest are gathered throughout the various stages of the DMA, some stakeholders may be involved multiple times at different stages of the process, i.e. (i) identification and validation of potential ESG topics and related IROs; (ii) validation of the assessment and scoring performed during the impact materiality phase; and/or (iii) validation of the assessment and scoring performed during the financial materiality phase.

Impact materiality assessment

The long list of ESG topics and related IROs is reviewed in order to establish an intermediate list of the ESG topics and IROs that will be used for the impact and financial materiality assessment. In line with ESRS 1, Appendix A, AR10 and AR 11, and EFRAG IG 1 §3.6, all potential material ESG topics and related IROs identified in the intermediate list are scored taking into account in particular the scale (1 'minimal' to 5 'maximal'), scope (1 'limited' to 5 'global'), level of irremediability (0 'very easy to remedy' to 5 'irreversible') and likelihood (1 'very low' to 4 'very high') of the impact. GBL retained "Equal to or above 8" as the impact materiality threshold.

The definition of the thresholds as well as the scoring calculation of each sustainability matter retained on the intermediate list was performed initially by GBL's Head of ESG. The impact materiality threshold has been initially defined by GBL's Head of ESG leveraging on the input from the Equintel AI DMA tool. The thresholds have been validated by different stakeholders during the workshop sessions, in particular GBL's Chief Financial Officer and GBL's General Counsel and General Secretary.

Financial materiality

As for the financial materiality, the purpose of scanning ESG risks and opportunities is to establish an intermediate list of ESG topics resulting from the risk and opportunity analysis. In line with ESRS 1, Appendix A, AR15, and EFRAG IG 1 §3.7, all potential risks and opportunities identified in the intermediate list are scored taking into account in particular the potential magnitude of the financial effect (1 'very low' to 4 'very high') and likelihood of occurrence (1 'very low' to 4 'very high') under short-, medium- or long-term time horizons. "Equal to or above 0.5" is retained by GBL for GBL "as a responsible company" as the financial materiality threshold.

The definition of the thresholds as well as the scoring calculation of each sustainability matter retained in the intermediate list has been performed initially by GBL's Head of ESG. The thresholds were validated by different stakeholders during the workshop sessions, in particular GBL's Chief Financial Officer and GBL's Group Risk Controller.

Following the outcome of the DMA process, GBL has been complying with the list of ESRS disclosure requirements as summarised in the following disclosures:

ESRS E1 - Climate change

Governance:

• ESRS 2, GOV-3: Integration of sustainability-related performance in incentive schemes

Strategy:

• E1-1: Transition plan for climate change mitigation
• ESRS 2, SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business model

IRO:

• ESRS 2, IRO-1: Description of the processes to identify and assess material climate-related impacts, risks and opportunities
• E1-2: Policies related to climate change mitigation and adaptation
• E1-3: Actions and resources in relation to climate change policies

Metrics and targets:

• E1-4: Targets related to climate change mitigation and adaptation
• E1-5: Energy consumption and mix
• E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions
• E1-7: GHG removals and GHG mitigation projects financed through carbon credits
• E1-8: Internal carbon pricing
• E1-9: Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

ESRS S1 - Own Workforce

Strategy:

• ESRS S1, SBM-2: Interests and views of stakeholders
• ESRS S1, SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business mode

IRO:

• S1-1: Policies related to own workforce
• S1-2: Processes for engaging with own workers and workers' representatives about impacts
• S1-3: Processes to remediate negative impacts and channels for own workers to raise concerns
• S1-4: Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those action

Metrics and targets:

• S1-5: Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
• S1-6: Characteristics of the undertaking's employee
• S1-7: Characteristics of non-employee workers in the undertaking's own workforce
• S1-8: Collective bargaining coverage and social dialogue
• S1-9: Diversity metrics
• S1-10: Adequate wages
• S1-11: Social protection
• S1-13: Training and skills development metrics
• S1-14: Health and safety metrics
• S1-15: Work-life balance metrics
• S1-16: Compensation metrics (pay gap and total compensation)
• S1-17: Incidents, complaints and severe human rights impacts

ESRS G1 - Business conduct

Governance:

• ESRS 2, GOV-1: The role of the administrative, supervisory and management bodies

IRO:

• ESRS 2, IRO-1: Description of the processes to identify and assess material impacts, risks and opportunities
• G1-1: Business conduct policies and corporate culture
• G1-2: Management of relationships with suppliers
• G1-3: Prevention and detection of corruption and bribery

Metrics and targets:

• G1-4: Incidents of corruption or bribery
• G1-5: Political influence and lobbying activities
• G1-6: Payment practices

GBL has developed a comprehensive climate transition plan. Considering ESRS E1-1 disclosure requirements, the content of the EFRAG Draft IG on Transition Plan for Climate Change Mitigation, and the specific nature of GBL's activity as an investment holding company, the key features of GBL's transition plan are summarized hereafter.

Considering the challenges and threats of climate change, GBL publicly endorses the Paris Agreement under the United Nations Framework Convention on Climate Change ("UNFCCC") and supports the development of long-term adaptation and mitigation climate strategies for GBL and its portfolio of participations.

For GBL, as an investment holding company deploying permanent capital, the climate challenges and opportunities lie primarily in its ability to ensure alignment of its existing portfolio of participations to the long-term carbon trajectories induced by the Paris Agreement and the investment in assets benefiting from this structural shift.

In 2012, GBL initiated a structural rebalancing of its portfolio with the objective of diversifying, reinforcing toward growth and resilience, and optimizing potential to create value over the long term. Over the last decade, GBL progressively exited its exposure to fossil industries (e.g., energy, utilities or cement) to focus on sectors benefiting from megatrends shaping the economy (e.g., consumer experience, health, technology, sustainability or digitalization). This rebalancing has made a significant contribution to the decarbonization of the portfolio, with the carbon intensity of GBL's portfolio (GBL's greenhouse gas emissions scope 3 cat. 15 'Investments' / GBL's Net Asset Value ("NAV")) divided by a factor 30 between FY2012 and FY2024.

GBL's 2025-2030 ESG commitments and climate transition plan are anchored on this trend and address both GBL as a "responsible company" and GBL as a "responsible investor" in delivering further progress. As a "responsible company", GBL is committed to minimizing its carbon footprint in line with the 1.5°C requirements as part of its overall climate transition plan. As a "responsible investor", GBL is dedicated to leveraging its influence on its portfolio companies to ensure they adopt 1.5°C climate-aligned strategies and targets.

Under its 2025-2030 ESG commitments, GBL committed to the Science Based Target initiative ("SBTi") in May 2021. In January 2022, GBL became the first investment holding company on a global basis to have climate targets aligned with a 1.5°C pathway approved by SBTi for both its own operations and its eligible portfolio of participations.

For its own operations, GBL retained the following target: "SBTi target #1: 52% reduction of its greenhouse gas emissions scope 1 (direct emissions) and scope 2 (electricity-related emissions) by 2030 from a 2019 baseline". GBL's scope 1 (direct) and scope 2 (indirect electricity-related, market-related methodology) greenhouse gas emissions stood at 236 tCO2e in FY2019 (baseline).

The promotion of leading energy efficiency across its different offices, the switch to 100% renewable electricity in its energy supply and the implementation of an ambitious clean mobility policy for GBL's own workforce support GBL's ability to deliver on this target.

As a "responsible investor", GBL retained the following target: "SBTi target #2: 100% of eligible portfolio positions with climate strategy and targets aligned with a 1.5°C pathway approved by SBTi by 2030 from a 2020 baseline. For this target, an intermediary target of 66% coverage (vs. 50% initially) by 2025 has been retained". Coverage stood at 0% in FY2020 (baseline).

As of FY2024, GBL is on track with the implementation of its climate transition plan. In FY2024, GBL delivered a 53% decrease in its GHG emissions scope 1 and scope 2 versus the FY2019 baseline mainly due ongoing refurbishment of GBL's main office and the temporary relocation of GBL team in a significantly smaller office. With 78% of GBL's SBTi eligible NAV covered by 1.5°C SBTi-validated targets in FY2024, GBL delivered its intermediary coverage target (66% eligible NAV coverage by 2025) a year in advance.

At GBL's holding level, operational expenditures (OpEx) required for the implementation of GBL's climate transition plan cover primarily car fleet leasing and clean electricity supply. In FY2024, the financial resources allocated to support the implementation of the transition plan (OpEx) amounted to EUR 410,889.

At GBL holding level, due to the nature of its activity as an investment holding company, there is no CapEx required for the implementation of GBL's climate transition plan.

GBL has no significant locked-in greenhouse gas emissions from its portfolio of participations. As an investment holding company, GBL's business model primarily focuses on deploying proprietary capital which inherently results in a lower direct carbon footprint compared with industries with significant physical assets.

Over the reporting period, no CapEx has been spent on either coal-related, oil-related or gas-related economic activities.

Pursuant to the Commission Delegated Regulation (EU) 2020/1818 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks, and based on its own assessment, GBL ("Groupe Bruxelles Lambert NV") as a listed entity does not foresee any significant challenges not to be eligible for inclusion in EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks.

The ESG Policy reflects the core values that guide GBL on environmental, social and governance issues. It presents the commitments and implementation guidelines for GBL. It addresses the management of material IROs related to climate change and covers climate change adaptation, climate change mitigation, energy efficiency and renewable energy.

The ESG Policy's scope of application ("ESG scope") applies to GBL and its direct and indirect wholly-owned subsidiaries ("GBL as a "responsible company"). The companies within GBL's portfolio are included in the ESG scope under the "GBL as a "responsible investor" approach. Those companies identify and address their sustainable IROs within the framework of their own internal controls and governance.

The ESG Policy has been reviewed and approved by GBL's Board of Directors. The CEO is responsible for the oversight of the ESG Policy implementation (including but not restricted to its climate component) and he is supported in that matter by the Head of ESG. GBL's Board of Directors is assessing the ESG Policy implementation on a yearly basis.

As part of the ESG Policy implementation, GBL promotes transparency. For climate reporting, GBL in particular supports the adoption of the Task Force on Climate-related Financial Disclosures recommendations ("TCFD") and the disclosure of climate data to the CDP via its ongoing engagement with its portfolio's participations. GBL also supports its portfolio's participations on their compliance journey with the latest European Union sustainable finance regulation requirements and, in particular, the Regulation (EU) 2019/2088 of the European Parliament and of the Council on Sustainability‑related disclosures in the financial services sector (the "SFDR regulation"), the Regulation (EU) 2020/852 of the European Parliament and of the Council (the "Taxonomy regulation") and the Corporate Sustainability Reporting Directive (EU) 2022/2664 ("CSRD").

The ESG Policy is publicly available on GBL's website.

GBL approach to climate risks, GBL's ESG Policy and GBL's 2025-2030 ESG commitments guide the implementation of GBL climate transition plan, addressing both GBL as a "responsible company" and GBL as a "responsible investor" in delivering climate progress.

As a "responsible company", GBL is committed to minimizing its carbon footprint in line with the 1.5°C requirements as part of its overall climate transition plan. As a "responsible investor", GBL is dedicated to leveraging its influence on its portfolio companies to ensure they adopt 1.5°C climate-aligned strategies and targets. This commitment is part of GBL's broader climate transition plan aimed at further reducing the carbon footprint of its portfolio.

Key Actions

Energy Efficiency

GBL promotes leading energy efficiency initiatives across its offices, none of which are owned by GBL. GBL therefore conducts regular engagement with the landlords of the premises it occupies. In 2024, this engagement concentrated on GBL's head office in Brussels and GBL Capital's new premises in London. GBL's head office building is currently being renovated with the aim to achieve HQE ("Haute Qualité Environnementale"), BREEAM Outstanding and CO2 Neutral certifications. The renovation works started in 2023 and are expected to be completed during 2025.

Over the period 2019 (SBTi baseline) to 2030, 10% energy efficiency achieved across its premises would lead to a reduction of 5t. CO2e (scope 1). There is no CapEx spending attached to such initiative for GBL. OpEx are related to rental costs of the premises and amounted to EUR 1.5 million in 2024.

Renewable Energy

GBL targets 100% of its electricity supply to come from renewable sources by the end of 2025. Over the period 2019 (SBTi baseline) to 2030, the switch to renewable electricity should support the reduction of 76t. CO2e (scope 2). In 2024, GBL's offices in Brussels, Luxemburg, London and Milan already benefited from clean and renewable electricity sourcing and GHG emissions scope 2 electricity-related amounted to 6.7t. CO2e (-91% from 2019 baseline).

There is no CapEx spending attached to such initiative for GBL. OpEx are related to electricity costs of the premises benefiting from clean and/or renewable electricity and amounted to EUR 77,604 in 2024.

Clean Mobility

GBL adopted in 2021 under its ESG Policy an ambitious clean mobility policy ruling out internal combustion engine vehicles from employee's newly-acquired fleet of vehicles in favor of hybrid or electric vehicles. So far, 19 vehicles out of 37 have been converted from thermal to hybrid or electric power engines.

Over the period 2019 (SBTi baseline) to 2030, the implementation of GBL's clean mobility policy is expected to lead to a reduction of 55t. CO2e (scope 1). In FY2024, GHG emissions scope 1 related to "owned and leased car fleet" amounted to 69.2t CO2e (-37% from 2019 baseline). Car fleet leasing contracts are leading to an OpEx of EUR 333,285 in GBL financial statements for FY2024.

GBL is on track with the implementation of the targets set out in its climate transition plan. GBL delivered in FY2024 a 53% decrease in its GHG emissions scope 1 and scope 2 versus FY2019 baseline.

GBL expects the future financial resources allocated to the transition plan (CapEx and OpEx) to remain stable in the future.

Under its 2025-2030 ESG commitments, GBL committed to the Science Based Target initiative ("SBTi") in May 2021. In January 2022, GBL became the first investment holding company on a global basis to have climate targets aligned with a 1.5°C pathway approved by SBTi for both its own operations and its eligible portfolio of participations. In 2023, due to the evolution of GBL Capital's governance and faster than anticipated progress towards its intermediary 2025 target, GBL re-submitted to SBTi its baseline for validation and requested an uplift of its intermediary targets. Revised targets were validated in November 2023.

For its own operations, GBL retained the following target: "SBTi target #1: 52% reduction of its greenhouse gas emissions scope 1 (direct emissions) and scope 2 (electricity-related emissions) by 2030 from a 2019 baseline". GBL's scope 1 (direct) and scope 2 (indirect electricity-related, market-based methodology) greenhouse gas emissions stood at 236 tCO2e in FY2019. This baseline is representative of GBL's activities covered with limited influences from external factors and it benefits from PwC Bedrijfsrevisoren / Reviseurs d'Entreprises SRL limited assurance in GBL's FY2022 Annual Report and GBL's FY2023 Annual Report.

GBL aims to deliver on this target by leveraging on the following decarbonization levers: (i) ensuring leading energy efficiency practices in its offices; (ii) switching to 100% renewable electricity in its energy supply; and (iii) implementing an ambitious clean mobility policy.

As a "responsible investor", GBL retained the following target: "SBTi target #2: 100% of eligible portfolio positions with climate strategy and targets aligned with a 1.5°C pathway approved by SBTi by 2030 from a 2020 baseline. For this target, an intermediary target of 66% coverage (vs. 50% initially) by 2025 has been retained". Coverage stood at 0% in FY2020 (baseline benefiting from PwC Bedrijfsrevisoren / Reviseurs d'Entreprises SRL reasonable assurance in GBL's FY2022 Annual Report and GBL's FY2023 Annual Report).

With 78% of GBL's SBTi eligible NAV covered by 1.5°C SBTi-validated targets in FY2024, GBL delivered its intermediary coverage target (66% eligible NAV coverage by 2025) a year in advance.

Energy consumption and mix

GBL holding level (own operations)

As an investment holding company operating in offices, GBL has no activity in high climate impact sector.

Scope: GBL holding own operations (offices). No intensity ratio reported at holding level.

Consolidated level (including controlled participations)

Energy consumption data for consolidated entities is reported within individual controlled participations' disclosures. GBL consolidated entity reporting focuses on GHG emissions and does not separately aggregate energy consumption across controlled participations. See individual appendices for:

• Affidea: 83,320 MWh total energy consumption (100% fossil sources reported; nuclear and renewable split not yet available for all locations)
• Sanoptis: Energy consumption not separately disclosed in excerpt
• Canyon: 4,560 MWh total energy consumption (55% fossil, 0% nuclear, 45% renewable)

No consolidated energy consumption table provided across all controlled participations.

Gross Scopes 1, 2, 3 and Total GHG emissions

GBL Holding (Responsible Company)

GBL's GHG emissions are calculated according to the GHG Protocol (2012) under the equity-share methodology.

¹ Non significant
² Please refer to GBL GHG emissions – Portfolio level (FY2024) table
³ No revenue recognized for GBL holding. Cf. Note 8, Consolidated financial statements 'Turnover'
⁴ Please refer to GBL GHG emissions – Portfolio level (FY2024) table
⁵ For an investment holding company, an intensity ratio based on revenue metric is non-relevant. Intensity ratio based on FTEs to assess own operations or on NAV to assess portfolio carbon intensity shall be considered
⁶ Please refer to GBL GHG emissions – Portfolio level (FY2024) table

GBL Consolidated (including controlled participations)

Consolidated GHG emissions across GBL consolidated entities (FY2024):

¹ Non-significant
² Please refer to GBL GHG emissions – Portfolio level (FY2024) table
³ No revenue recognized for GBL holding. Cf. Note 8, Consolidated financial statements 'Turnover'
⁶ For an investment holding company, an intensity ratio based on consolidated revenue metric is non-relevant when the assets consolidated represent only 27.2% of the NAV.

GBL Portfolio Level (FY2024)

GHG emissions across GBL's consolidated and non-consolidated entities:

¹ Scope 3 - Cat. 15 (GHG Protocol)

Methodology notes:

• GBL's GHG emissions are calculated according to the GHG Protocol (2012) under the equity-share methodology.
• GBL's scope 3 GHG emissions category 15 "investments" represent 99.99% of GBL's total GHG emissions.
• At the time of Annual Report completion, GHG emissions for FY2024 have been publicly disclosed by GBL's portfolio participations representing 86% of GBL's GHG emissions and 78% of GBL's NAV. When not available, scope 1, 2 and 3 emissions data for FY2024 have been directly carried over from FY2023 without extrapolation.
• For GBL Capital investments representing 6.4% of GBL's NAV, emissions factor intensity linked to geographical regions and GICS codes have been used where direct data was unavailable.
• Scope 3 category 1, 2 and 9 use spend-based estimation with industry/product category specific carbon emission factors where supplier Product Carbon Footprint (PCF) is unavailable.

Key assumptions and sources:

Under its 2025-2030 ESG commitments, GBL aims to invest in projects in order to balance its carbon footprint related to its direct and indirect emissions excluding its portfolio's emissions (GHG Protocol, Scope 3 – Category 15 Investments, equity-share accounting methodology). GBL achieves this by acquiring and cancelling voluntary carbon certificates attached to specific projects and issued by recognized organizations.

In line with GBL ACT's selected areas of intervention, one project (100% reduction, 0% removal), currently active and related to the promotion and implementation of clean water filters in Kenya was selected to source carbon certificates.

In FY2024, verified emission reduction credits (certified Gold Standard credits) were acquired to compensate 761t. CO2e corresponding to GBL's FY2023 residual carbon footprint (direct and indirect emissions excluding portfolio emissions). These credits were cancelled during the year.

GBL refers to its internal carbon pricing scheme, a shadow price, to seek to drive low-carbon investment, to identify and evaluate financing opportunities, to identify and seize low-carbon opportunities, to navigate regulations and to stress test investments. Due to the distribution of GHG emissions at GBL with scope 3 category 15 representing more than 99.9% of GBL's overall emissions, internal carbon pricing schemes are predominantly used to cover scope 3 categories emissions, the other categories being non-significant.

Different factors are considered when determining the internal carbon price: (i) the alignment with scientific guidance and the 1.5°C trajectory set forth by the Paris Agreement; (ii) the alignment with the price of allowances under an emissions trading scheme; (iii) the cost of required measures to achieve climate-related targets; and (iv) scenario analysis.

Considering current carbon market dynamic and the ongoing development of national or regional carbon markets in different parts of the world, GBL assumes an average EUR 100 / t.CO2e up to 2025. For the period 2025-2030, GBL expects carbon prices to be on an upward trend with the potential to reach EUR 80-120 / t.CO2e by 2030. GBL also expects carbon prices to remain higher in Europe than in the US or in emerging Asia.

GBL, as an active and engaged institutional investor, is actively contributing to its portfolio companies' climate strategy elaboration and climate risk management initiative programs via its involvement in their Board of Directors, Audit Committee, Strategy Committee or Nomination and Remuneration Committee. Internal carbon price tools are then used to assess the climate strategy and risk management programs proposals made by the management of these companies or the medium and long term cost and impact on EBITDA of carbon compensation schemes or the constitution of carbon offset reserves by the portfolio's companies for example.

Due to the uncertainty related to the development of carbon markets outside Europe (e.g. Asia and China) and the potential for Europe to impose a carbon border tax, a conservative EUR 100 / t.CO2e internal carbon price is used independently of the geographical location of the assets across GBL's portfolio.

As GBL's internal carbon pricing schemes are predominantly used as part of the ESG integration approach, carbon prices used in internal carbon pricing schemes are consistent with those used in financial statement.

Through the DMA process, GBL identified "Climate change - Climate change mitigation" sub-topic as an actual negative material impact over a long-term time horizon. It relates to the group's emissions and their impact on climate change, and encompasses GBL's endeavors to contribute to the general process of limiting the increase in the global average temperature to 1.5°C above pre-industrial levels in line with the Paris Agreement, GBL's own operations GHG emissions as defined by the GHG Protocol and the associated transition risks.

Considering the characteristics of GBL's operations, being mainly an office activity, and its small size workforce (83 employees in its own workforce at the end of FY2024), negative impact associated with climate change mitigation at a corporate level ("holding segment") remains in absolute terms negligible due to the limited direct and indirect electricity-related GHG emissions compared to GBL's GHG emissions scope 3 cat. 15 'Investments'. GBL does not expect a notable change in the potential impact of climate risks and opportunities on its own operations in the medium to long term.

Climate Risk Assessment Process

Since 2020, GBL has been conducting an in-depth analysis on GBL's portfolio participation potential exposure to climate transition and physical risks. This assessment notably aims to: (i) map the climate impact; (ii) identify the portfolio's maturity on this matter and its exposure to carbon pricing mechanisms; (iii) understand the portfolio's exposure to physical and climate transition risks; (iv) feed GBL's sustainable IRO management process (in particular the annual sustainable IRO review) and investment strategies and ultimately; and (v) support the development and implementation of long-term mitigation strategies for GBL and its portfolio of participations.

Climate Scenario Analysis

For climate transition risk and opportunity analysis, the modelling of future carbon prices is based on two different scenarios developed by the International Energy Agency ("IEA"): the stated policies scenario ("STEPS") and the net zero emissions scenario ("NZE"). The STEPS scenario is designed to provide a sense of the prevailing direction of energy system progressions based on a detailed review of the current policy landscape. The NZE scenario is a normative scenario showing a pathway to achieve net zero CO2 emissions by 2050 consistent with limiting the global temperature rise to 1.5°C with at least a 50% probability.

For climate physical risk analysis, climate-related hazards are first identified using high emission scenarios like SSP 5-8.5 (Share Socioeconomic Pathways "Fossil-fueled Development") and SSP2-4.5 (Share Socioeconomic Pathways "Middle of the Road") developed by the Intergovernmental Panel on Climate Change (IPCC).

By 2023, all the participations included in the initial scope of the climate risk analysis program launched in 2020 as well as the participations acquired since 2021 have been covered in accordance with GBL's commitments. In 2024, as part of the annual update, GBL reviewed climate transition risk analysis and physical risk analysis for all portfolio participations (excluding GBL Capital and Sienna Investment Managers).

Risk Assessment Results

Under the different climate scenarios considered in the medium and long term (as defined under ESRS 2) and even under high impact scenarios, the weighted percentage of EBITDA at risk (climate transition) for GBL and its portfolio is very low as is its weighted exposure to climate physical risks thanks to (i) no significant transition and physical risks related costs for its own operations, (ii) a well-diversified portfolio, (iii) the ongoing structural reduction of its exposure to carbon assets, and (iv) underlying companies demonstrating strong climate resilience (potential unpriced carbon costs expressed in percentage of each portfolio's participation EBITDA at Risk ranging from 0.07% to 7.68% to their respective EBITDA in 2030 under STEPS/SBT scenario).

In the case of material climate risks identified in this assessment, they are monitored by GBL's representatives in the governance bodies of the portfolio companies. The result of these assessments is also discussed with the portfolio companies via dedicated climate meetings. Since 2024, GBL has been granting its portfolio companies access to GBL's climate dashboard, enabling them to view all the underlying physical and transition data that supports the climate risk analysis.

Due to the limited exposure to climate risks and the ability for GBL to mitigate such risks via its portfolio rebalancing, the different climate scenarios used are compatible with GBL's financial statements.

Note: For purposes of its consolidated sustainability statement and in accordance with ESRS 1, Appendix C, GBL has applied the phase-in provisions related to ESRS E1 E1-9 related to the anticipated financial effects from material physical and transitions risks and potential climate-related opportunities, whereby this consolidated sustainability statement does not include such information for this year's reporting.

Policies related to own workforce

GBL's policies addressing the management of impacts on its own workforce are detailed in the following documents:

Work Regulation

Scope: Applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly owned subsidiaries.

Key content: Describes the work regulations applying to GBL's workforce and covers among other things (but not limited to) working conditions, remuneration, psychosocial risks and training and skills development.

Governance: Reviewed and approved by GBL's Operational Management Committee, which includes representatives from GBL's senior management and different operational departments (e.g. Finance department, General Secretariat, Human Resources department, Communication department, IT department).

Public availability: The Work Regulation is shared with each new employee and GBL's workforce can access it in GBL's premises.

Diversity & Inclusion Policy (D&I Policy)

Scope: Applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly owned subsidiaries.

Key content: Supports and facilitates a diverse and inclusive environment that embraces differences and recognizes their benefits. These differences can be notably age, gender, sexual identity and orientation, disability, ethnicity, cultural and religious background.

Governance: Formally reviewed and approved by GBL's Board of Directors with the support from the Governance and Sustainability Committee. On an annual basis, the Governance and Sustainable Development Committee and the Executive Management will assess the performance in view of GBL diversity objectives and commitments.

Public availability: The D&I Policy is publicly available on GBL's website.

Remuneration Policy

Scope: Applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly owned subsidiaries.

Key content: Sets the principles in terms of alignment of GBL's CEO remuneration with GBL's interests and addresses in particular the provision of adequate wages.

Governance: Formally reviewed and approved by GBL's Board of Directors with the support from the Governance and Sustainability Committee. Submitted for vote to GBL's Ordinary General Meeting on a regular basis and was last approved on May 2, 2024.

Public availability: The Remuneration Policy is made available to the public via GBL's Annual Report publication.

ESG Policy

Scope: Applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly owned subsidiaries.

Key content: Reflects the core values that guide GBL on environmental, social and governance issues. It presents the commitments and implementation guidelines for the teams.

Governance: Formally reviewed and approved by GBL's Board of Directors with the support from the Governance and Sustainability Committee.

Public availability: The ESG Policy is publicly available on GBL's website.

Code of Conduct and Ethics (the "Code")

Scope: Made available to the workforce and the Directors. Applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly owned subsidiaries.

Key content: Provides guidance in conducting business activities in accordance with the highest legal, ethical and professional standards. It notably covers compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery, relations with third parties, respect at work and non-discrimination. Contains provisions regarding grievance mechanisms through the Whistleblowing Procedure.

Governance: Formally reviewed and approved by GBL's Board of Directors with the support from the Governance and Sustainability Committee.

Public availability: The Code is publicly available on GBL's website.

International standards alignment: Through these policies, GBL is committed to carrying out its business ethically and in accordance with all applicable laws and regulations. GBL has been formally committed to the United Nations Global Compact ("UNGC") initiative since 2018. Adhering to the UNGC and its 10 principles (covering human rights, labor, environment and anti‑corruption) allowed GBL to cover all general areas that could be impacted by its activities. Under its commitment to the UNGC initiative, and its ESG Policy, GBL recognizes in particular the provisions offered by the UN Guiding Principles on Human Rights and the Organisation of Economic Co‑operation and Development ("OECD") Guidelines for Multinational Enterprises.

Implementation and monitoring: GBL aims to ensure that all people in own workforce are trained in the Code, the D&I Policy and the Work Regulation so that they adopt best practices in the context of their activities. GBL is particularly committed to raising awareness among its employees of GBL's values and practices and organizes on a yearly basis mandatory training for its entire workforce. Ultimately, the effectiveness of the channel offered by the Whistleblowing Procedure is reviewed on an annual basis by GBL's Governance and Sustainable Development Committee.

Taking action on material impacts on own workforce

GBL Holding

Overview

GBL's actions related to own workforce are carried out under the GBL ACT initiative and relate to GBL's own operations. GBL's philanthropic activities are conducted under a truly philanthropic philosophy and approach aiming for a local positive impact across well-defined areas of intervention like education, healthcare, environmental protection or social justice. Beyond the positive local contribution to the environment and the society, GBL ACT supports employee's motivation and retention.

Scope: Own operations (holding segment)

Time horizon: Medium-term

Resources Allocated

Considering the nature of GBL's activity, no CapEx is involved in the implementation of own workforce related action plans (current or future resources).

OpEx-related spending for the own workforce action plans covers:

• Training expenses
• Total compensation
• Cost of the carry plan

FY2024 OpEx: EUR 62.9 million

Expected future resources: GBL expects the OpEx related amounts to remain stable in the short term horizon.

Integration with Risk Management

The management of GBL's material IROs related to its own workforce is an integral part of the overall risk management process.

Consolidated Entities

GBL's consolidated entities (Imerys, Sanoptis, Canyon, Sienna IM) report their own workforce actions in separate appendices. These are incorporated by reference in the consolidated sustainability statement.

Targets related to own workforce

GBL holding (own operations)

S1-5 is listed as incorporated by reference on page 22 and page 81, with a dash ('-') indicating the disclosure location. The document explicitly states on page 38 that S1-5 is applicable to GBL holding, but no specific targets are disclosed in the excerpts provided for GBL holding's own workforce.

GBL consolidated entities

The sustainability statement is structured with separate disclosures for controlled participations. Targets related to own workforce are disclosed at the individual entity level:

Imerys (controlled participation)

Health & Safety Targets (page 537):

Diversity, Equity & Inclusion Targets (page 542-543):

The DE&I Index is composite metric with five equally weighted components (20% each):

• Gender representation in senior and professional roles
• Pay gap (percentage within explained or non-significant gap)
• Nationality diversity in senior roles
• Registered headcount with disability
• Inclusion/engagement score

Safety Performance (2024):

• Combined Lost Time Accident (LTA) rate: 1.76
• Combined Total Recordable Injury Rate (TRIR): 3.39 (above 2024 target of 2.18)
• Fatalities: 0
• Life changing injuries: 1 (January 2024)

Occupational Health Action Plan (OHAP):

• 2024 completion: 94% of planned actions
• Cumulative performance since 2022: 63%
• Annual target: 75% completion rate

Other controlled entities

Canyon, Sienna IM, and other consolidated entities have S1-5 listed in their disclosure tables (pages 254, 368) but specific workforce targets are not detailed in the provided excerpts.

Characteristics of the undertaking's employees

GBL Holding Segment

Total headcount and FTE

Headcount by gender

Headcount by country/region

Headcount by contract type and gender

Percentages by contract type and gender:

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

Not disclosed for GBL holding segment.

Non-guaranteed hours employees

Non-employees in workforce

Positions breakdown

Percentages:

C-level gender distribution:

Percentages:

Employee turnover

Turnover calculated as number of employees who left during the year divided by average number of employees during the year.

New hires

Not disclosed.

Consolidated entities

Total headcount across GBL's consolidated entities (FY2024):

Affidea detailed breakdown (FY2024)

By gender:

• Women: 7,253
• Men: 1,980
• Other: 0
• Not Disclosed: 0
• Total: 9,233

By contract type and gender:

By country:

Average number of employees: 577.06 (headcount)

Turnover:

• Number of employees who left during the year: 1,632
• Employee turnover rate: 18.40%

Sanoptis detailed breakdown (FY2024)

Total headcount: 4,692

By contract type and gender:

By geographical area:

Turnover:

• Number of employees who left: 938
• Employee turnover rate: 20%

Methodology notes:

• All employees' data reported in headcount as at the end of the reporting period except where explicitly mentioned as average.
• Numbers reported as headcounts as of December 31, 2024 (Sanoptis).
• GBL: Non-employees are professionals with contracts to supply labor (e.g., advisors, interim workers); the CEO has independent status but is counted under employees.
• For GBL, "top management" (C-level) includes three positions: CEO, CFO, and General Secretary/COO.

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

GBL Holding (own operations)

GBL employed at the end of FY2024 83 employees and welcomed 5 non-employees in its own workforce. GBL's non-employees in its own workforce are predominantly advisors or experts in a dedicated field (e.g. investment, IT/AI).

For GBL, non-employees are professionals with contracts with the undertaking to supply labor or people provided by undertakings primarily engaged in employment activities (NACE code N78). For GBL, non-employees typically cover independent employees like advisors (e.g. IT/AI, investment) or employees working for GBL under an interim contract.

Due to the size of GBL's operations and the specificities of the tasks and roles conducted by non-employees at GBL, the non-employee number is not an estimated number but an exact number.

Methodology: Exact headcount (not estimated) at end of reporting period.

Consolidated entities

Affidea

Affidea has a large part of its workforce as contracted clinical personnel, who are either self-employed or working through an agency. Most common type of non-employees are contracted doctors, who provide radiologist services. They could be physically located in one of Affidea's clinics to perform a radiology service and report to the patient, or offer tele-radiology services from their own clinics. There are also doctors who provide clinical consultation services.

Disclosure note: Affidea has decided to report on non-employees from 2025, so this is a phased-in disclosure. No quantitative data disclosed for 2024.

Canyon

Canyon defines non-employees as individuals who contribute to its operations but are not employed by Canyon or its Network Partners. This includes independent contractors, consultants, and third-party personnel.

In addition to its permanent employees, Canyon has commissioned self-employed workers worldwide, to whom certain programs (e.g., mental health services) are not available.

Disclosure note: No specific quantitative data on non-employee numbers disclosed.

Sanoptis

Sanoptis defines non-employees as individuals who contribute to its operations but are not employed by Sanoptis or its Network Partners. This includes, but is not limited to, independent contractors, consultants, affiliated doctors (self-employed physicians working within the Network), and third-party personnel such as anesthetists engaged through external service providers.

Disclosure note: No quantitative data on non-employee numbers disclosed.

Sienna IM

No self-employed people / people provided by third party undertakings primarily engaged in employment activities are part of the own workforce of Sienna IM.

Imerys

Methodology: The total hours worked by non-employees are converted to Full-Time Equivalent by dividing the annual non-employees worked hours by 12 and then by the monthly statutory hours of a permanent employee in the respective countries.

Collective bargaining coverage and social dialogue

GBL Holding

GBL's own workforce is covered in full by a collective bargaining agreement. Due to the size of GBL and the lack of employee representative, there is no agreement with employees for representation by European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea (SCE) Works Council.

Table 18 – Collective bargaining agreements' coverage

GBL Consolidated

For GBL as a consolidated entity, ESRS S1-8 disclosure requirements are incorporated by reference. The disclosure is marked as "Not applicable" at the consolidated level in the ESRS disclosure requirements tables.

Affidea (Controlled Participation)

Approximately 39% of Affidea's own workforce is covered by collective bargaining agreements on a global level.

Collective bargaining coverage and social dialogue per country

Coverage Rate by Country:

Detailed country breakdown

Affidea reports that determination of working conditions and terms of employment for employees not covered by collective bargaining agreements will be a phased-in disclosure from 2025. Disclosure of the extent to which working conditions of non-employees are influenced by collective bargaining agreements will also be phased in from 2025.

Canyon (Controlled Participation)

Collective agreements cover approximately 90% of Canyon's workforce in Germany. In 2023, a new collective agreement was successfully negotiated and implemented between Canyon and the IG Metal labor union. This agreement establishes a framework for regulated working conditions and structured collaboration between the company and its employees.

Sienna IM (Controlled Participation)

Coverage rate summary:

Sienna IM reports there is no agreement in place for representation by European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea (SCE) Works Council. France is the only country with more than 50 employees representing at least 10% of total employees.

Imerys (Controlled Participation)

Coverage rate by country or region:

Imerys has a European Works Council (EWC) covering Group employees in 18 countries. The most recent EWC agreement was signed on May 24, 2022, covering 2022-2026. The EWC is composed of an employee delegation of 15 members representing different nationalities and five EWC officers. In 2024, one plenary session was held and the EWC's five officers met three additional times during the year.

Diversity metrics

GBL discloses diversity metrics for its own workforce (holding company) and provides aggregated data at the consolidated level. Diversity metrics are disclosed on a voluntary basis per investor requests (SFDR Art. 8 funds).

GBL Holding - Workforce diversity and employment characteristics

GBL Holding - C-level gender distribution

GBL Holding - Age distribution

GBL Consolidated - Number of employees

Controlled Participation - Affidea Top Management Gender Diversity

Board's gender diversity ratio:

• Percentage of female management board members: 0%
• Percentage of female supervisory board member: 0%
• Percentage of female senior leadership team members (top management): 20%

Controlled Participation - Affidea Employees by Category and Gender

Definition: Top management of Affidea includes the management board members, executive committee and the senior leadership team (SLT).

Controlled Participation - Affidea Employees by Age Group by Country

Controlled Participation - Sienna IM Top Management Gender Distribution

Definition: Top management employees correspond to Sienna IM's Management Committee members, Sienna expertise's Management Committee members, and other business heads.

Controlled Participation - Sienna IM Age Distribution

Methodology: Data based on headcount at end December 2024, sourced from Lucca SIRH software and two expertise data not included in Lucca.

Controlled Participation - Imerys Registered Headcount by Gender

Note: Top management level includes Executive Committee members and Senior Management roles. Senior management roles include roles that directly report to Executive Committee members (excluding assistants/secretaries) or directly report to the Chief Information Officer or Business Area Purchasing Directors.

Controlled Participation - Imerys Disability Metrics

Controlled Participation - Imerys Age Distribution

Adequate wages

GBL Holding (own workforce)

Benchmark used: Minimum local mandatory salary (not a living wage benchmark)

Coverage:

• 100% of own employees paid above minimal local mandatory salary (FY2024)
• 100% of non-employees paid above minimal local mandatory salary (FY2024)

Materiality assessment: GBL identified "Adequate wage" as a material risk over a medium-term time horizon. The risk relates to GBL's ability to access talent in the financial industry in Continental Europe, requiring market-competitive remuneration packages to ensure talent attraction and retention. The inability to provide such packages may impede strategy execution.

Policy and actions: GBL's Remuneration Policy addresses this risk through:

• Competitive incentive schemes (short-term incentive plan, long-term incentive plan, carry plan)
• Yearly tracking of remuneration trends in the financial and private equity industry in Continental Europe
• All employees can benefit from STIP and LTIP programs

OpEx: FY2024 own workforce action plans' OpEx related-spending (including total compensation) amounted to EUR 62.9 million

Note: GBL does not disclose use of a living wage benchmark. The disclosure references "minimal local mandatory salary" and "market-competitive remuneration packages" but does not assess wages against living wage standards.

Affidea (controlled participation)

Benchmark used: Country-level adequate wage benchmarks (not specifically identified as living wage)

Coverage:

• 100% of employees paid adequate wage in line with country benchmarks
• 0% of employees paid below applicable adequate wage benchmark
• Non-employees: phased-in disclosure from 2025

Methodology: Annual salary benchmarks for non-clinical personnel via agreement with Willis Towers Watson. Clinical personnel (mostly contractors) receive ad-hoc fees aligned with market at country level.

Risk identified: Risk of higher employee turnover if company fails to pay adequate wages (material negative impact)

Other controlled participations

S1-10 marked as "Not applicable" or "Not material" for:

• Canyon: Not material
• Sanoptis: Not disclosed in excerpts
• Sienna IM: Not disclosed in excerpts
• Imerys: Included in Duty of Care risk scenarios as "inadequate wages" under working conditions category, but no specific S1-10 metrics disclosed in excerpts

Social protection

GBL Holding

All employees in GBL's own workforce are covered by social protection through public programs or GBL's benefits offered against:

• Loss of income due to sickness
• Loss of income due to unemployment starting from when the relevant own worker is working for GBL
• Loss of income due to employment injury and acquired disability
• Loss of income due to parental leave
• Loss of income due to retirement

GBL is not operating in countries where employees do not have social protection with regard to one or more of the types of events mentioned before.

Consolidated entities

Affidea

Affidea has reported the number of employees covered by social protection against loss of income due to major life events including sickness and family leave, but not all details of type of events are disclosed yet.

A country by country report is available.

Sienna IM

100% of Sienna IM employees are covered by social protection for the following 5 situations:

• Sickness
• Unemployment starting from when the own worker is working for the undertaking
• Employment injury and acquired disability
• Parental leave
• Retirement

All Sienna IM's employees are covered by social protection healthcare insurances (public/and or private) legally mandatory in each respective countries. Same logic for pension plans.

In France, Sienna IM ensures that all employees are covered by mutual health insurance and provident schemes ('mutuelle et prévoyance'). The social protection system in France is mandatory.

For operations outside of France, social coverage is provided to all employees. This coverage may vary depending on the public programs available in each country or the specific benefits offered by Sienna IM. Sienna IM does not have a private insurance system that supplements the local social protection system.

Percentage of persons with disabilities amongst employees: 2.21%

Methodology: Sienna relies on headcount at end December 2024. Social protection methodology: information coming from each HR representative of each country where Sienna operates.

Imerys

Imerys' global and comprehensive program (Global Management System) for benefits management maps all the healthcare, death and disability benefits provided to its employees. This program ensures harmonized coverage levels across the Group, aligning with local regulations and market practices while maintaining efficient management.

All Imerys employees in countries covered by the Global Management System benefit from social protection. This represents 98% of Imerys' workforce.

Persons with disabilities

GBL Holding

S1-12 is listed as disclosed on a voluntary basis (page 23) and marked as Not applicable for the GBL consolidated entity (page 63).

Affidea

Percentage of persons with disabilities amongst employees subject to legal restrictions on collection of data: 1.43%

Methodology: A country by country report is available. For example in Spain, for the retention scheme, they need to report whether and how much disabilities they have.

Canyon

Coverage by representative for employees with disabilities is mentioned in governance context. No quantitative metrics disclosed.

Sienna IM

Percentage of persons with disabilities amongst employees subject to legal restrictions on collection of data: 2.21%

Methodology: Sienna asked each HR representative to communicate the number of disabled people in their subsidiaries, then related this figure to the total workforce. Sienna relies on headcount at end December 2024. Disability information coming from each HR representative of each country where Sienna operates.

Imerys

Number of employees with a disability (headcount):

• 2024: 154
• 2023: 195
• 2022: 189

Percentage of registered headcount with a disability:

• 2024: 1.24%
• 2023: 1.42%
• 2022: 1.36%

Gender breakdown (2024):

Percentage of persons with disabilities in the Group subject to legal restrictions on the collection of data (2024): 1.33%

Methodology and scope exclusions: Definitions of "disability" vary from country to country in legal terms. Imerys has adapted the approach to take account of these differences while ensuring consistent reporting across its businesses. In countries with broader legal definitions, the data includes individuals who may not be recognized as disabled under narrower interpretations in other jurisdictions. Data collection focuses on gathering information from countries where Imerys is legally allowed to do so, and records any variations in disability definitions across various regions. The Group regularly revises its methodology to adapt to changing legal frameworks and improve data accuracy. Imerys does not collect disability data in jurisdictions where this practice is prohibited by law.

Context: In 2024, a change was observed in the proportion of employees declaring a disability. This evolution is primarily due to organizational changes, particularly divestitures. Imerys continues to prioritize increasing the percentage of registered headcount with a disability through policy reviews, education, awareness and accessibility actions at site.

Training and skills development metrics

GBL Holding

The table below summarizes GBL's own workforce participation in performance review.

As disclosed above, employees benefit from an annual and a semi-annual review meeting (i.e. 2 meetings per year). 100% of the meetings planned in 2024 have been held.

The table below summarizes GBL's own workforce training and skills development efforts.

Affidea

Employees that participated in regular performance and career development reviews per country per gender

Employees that participated in training per country per gender

Sienna IM

Employees that participated in regular performance and career development reviews

Average number of hours of training provided to employees, by gender

Sienna relies on headcount at end December 2024. Regular performance and career development: information coming from each HR representative of each country where Sienna operates. Training hours methodology: information coming from Skillup tool for France, and HR representatives for the other countries where Sienna operates.

Imerys

Metrics related to training and skills development

2024 marked a transformative year for training and development at Imerys. The Group launched the Imerys Performance Journey, a strategic initiative set for full implementation in 2025. This program provided extensive training for managers and HR professionals throughout the year. This contributed to a 10% increase in technical skills training compared to 2023 and a 14% rise in the percentage of employees participating in regular performance and career development reviews. Additionally, the Imerys Learning Hub was celebrated during a dedicated Learning Week, offering a wide range of self-development opportunities. This initiative helped drive a 5% increase in average training hours compared to 2023.

Health and safety metrics

GBL Holding

All employees at GBL are covered by the Work Regulation which covers accidents when on the way to work. However, there are no formal H&S management systems in place, given this is not applicable to the sector in which GBL operates as the nature of the work typically involves lower physical risk compared to heavier industries.

Coverage: All employees at GBL are covered by the Work Regulation.

GBL Consolidated

The consolidated figures are incorporated by reference to the individual controlled participation disclosures (Imerys, Affidea, Sanoptis, Canyon, Sienna IM). See Appendix for detailed entity-level H&S metrics.

Affidea (Appendix I)

Coverage: 100% of all Affidea employees are covered by health and safety management system.

Affidea has a large set of policies & procedures related to clinical governance aligned with country medical regulations. 90% of medical centers performing CT or X-ray examinations are accredited with 5* by the European Society of Radiology.

Canyon (Appendix III)

Coverage: Approximately 80% of employees are currently covered by the health and safety management system, based on the Occupational Health and Safety Act §1, applying to all operations in Germany. Coverage will be extended to other Canyon sites in line with international expansion plans.

All accidents at work are documented via a digital first aid book accessible to all employees. Accident statistics are compiled monthly to identify causes.

Sanoptis (Appendix II)

Sanoptis has not implemented a network-wide workplace accident prevention policy. Network Partners independently determine appropriate actions to fulfill legal obligations. The Sanoptis Academy offers training courses on workplace safety and accident prevention.

No specific H&S metrics are disclosed for Sanoptis.

Imerys (Appendix V)

Coverage: 100% of employees and non-employees covered by Imerys health and safety management system (SMS) based on legal requirements and recognized standards.

As of December 2024, the combined Lost Time Accident (LTA) rate was 1.76 and the combined Total Recordable Injury Rate (TRIR) was 3.39. The Imerys Safety System (ISS) is developed in compliance with ISO 45001 standards. One life-changing injury occurred in January 2024, and no fatality has been recorded for more than 2 years.

Sienna IM (Appendix IV)

No H&S metrics are disclosed for Sienna IM.

Work-life balance metrics

GBL Holding

All GBL's employees are entitled to family-related leave through social policy and collective bargaining agreements.

Table 27 – Family-related leave

In FY2024, none of GBL's employees have been in a position to take family-related leave (no birth or similar qualifying event).

GBL Consolidated

ESRS S1-15 is incorporated by reference and not consolidated at the GBL group level. The disclosure requirement is reported separately for each controlled participation.

Controlled Participations

Affidea

All employees are entitled to family-related leaves through social policy and/or collective bargaining agreements.

Number and percentage of employees that took family related leave by country by gender:

Canyon

No specific metrics disclosed for Canyon in the excerpts provided.

Sanoptis

No specific metrics disclosed for Sanoptis in the excerpts provided.

Sienna IM

No specific metrics disclosed for Sienna IM in the excerpts provided.

Imerys

No specific metrics disclosed for Imerys in the excerpts provided. The disclosure requirement S1-15 is listed as "Material" and "Phased in" in the disclosure requirements table, indicating it will be reported in a future period.

Compensation metrics

GBL Holding

Pay gap

Gender pay gap (all employees): 41%

Gender pay gap (C-level & Non-executive level): 12%

Gender pay gap (workforce level): 12%

In accordance with ESRS S1 §97, gender pay gap is defined as the difference in average gross annual salary between female and male employees for employees in the company as of Dec. 31st 2024. Pay data exclude interns as well as GBL Capital's employees, highest and lowest paid employees were removed from the data series.

Please note that the generic "Gender pay gap (all employees)" metric may be heavily distorted and subject to statistical challenges due to (i) a very concentrated workforce (ii) the nature of the private equity industry and associated remuneration schemes offered by GBL to attract and to retain key persons; and (iii) the positions not being doubled and therefore not supporting comparability.

In accordance with ESRS S1 §98, the generic "Gender pay gap (all employees)" metric is therefore completed by gender pay gap metrics for specific relevant and more homogenous groups within GBL's own workforce: (i) C-level and non-executive level; and (ii) workforce level.

Remuneration ratio

Annual total remuneration ratio: 13.7

Affidea

Pay gap

Gender pay gap: 31.58%

A country by country report is available.

Remuneration ratio

Annual total remuneration ratio: 84.44

Sanoptis

Sanoptis reports that both gender pay gap and excessive CEO pay ratio are non-material for the company.

Canyon

Canyon reports that unadjusted gender pay gap and excessive CEO pay ratio are not material for the company.

Sienna Investment Managers

No specific compensation metrics (S1-16) were disclosed in the excerpts for Sienna IM.

Imerys

Remuneration ratio

The annual remuneration ratio covers all Imerys employees worldwide. Certain categories of employees are excluded (e.g., non-active staff, part-time employees, obviously incorrect remuneration, missing annual salaries, etc.). In 2024, these exclusions account for 6% of the total workforce.

The worldwide average and median remuneration at Imerys includes the base salary and fixed bonuses only. For reliability reasons, all variable bonuses have been excluded.

The highest remuneration considered is that of the CEO.

2024 Global Remuneration Ratio (Total Compensation): 140.6

Based on total remuneration (including annual variable components) as described in Chapter 4, section 4.3.2.1 of the Universal Registration Document.

Five-year evolution (Adjusted Remuneration Ratio - salary + fixed bonuses):

These elements provide a comprehensive and transparent view of the Group's remuneration policy, while taking into account the methodological constraints resulting from the diversity of Imerys' locations.

Pay gap

Imerys does not report an unadjusted gender pay gap figure under S1-16 in the excerpts provided.

Methodology

GBL holding provides a detailed methodology for its gender pay gap calculation, noting data exclusions and the challenges of comparing across diverse roles in a concentrated workforce. Imerys provides a comprehensive methodology for its remuneration ratio, distinguishing between adjusted (fixed components only) and total compensation ratios, and noting exclusions representing 6% of the workforce. Affidea and other subsidiaries provide limited methodological detail.

Incidents, complaints and severe human rights impacts

GBL Holding

No work-related incident of discrimination on the grounds of gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant form of discrimination involving internal and/or external stakeholders across GBL's own operations in the reporting period, including incidents of harassment as a specific form of discrimination, has been recorded in FY2024 (incident of discrimination, work-related grievances, incident and complaints related to social and human rights matters as reported under Whistleblowing Procedure or through any other legal channels).

Over the reporting period, (i) no severe human rights issues and incidents connected to own workforce have been recorded; (ii) no material fines, penalties and compensation for severe human rights issues and incidents connected to own workforce have been imposed; and (iii) no material fines, penalties and compensation for damages as result of violations regarding social and human rights factors have been recorded.

Consolidated Entities

Affidea

Incidents of discrimination: 2

Number of complaints filed through channels for people in own workforce to raise concerns: 0

Number of complaints filed to National Contact Points for OECD Multinational Enterprises: 0

Amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors: 0

Number of severe human rights issues and incidents connected to own workforce: 0

Number of severe human rights issues and incidents connected to own workforce that are cases of non respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises: 0

Sanoptis

Total number of incidents of discrimination, including harassment, during the reporting period: 5

Number of complaints filed through channels for people in own workforce to raise concerns: 0

Number of complaints filed to National Contact Points for OECD Multinational Enterprises: 0

Amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors: 0 EUR

Number of severe human rights issues and incidents connected to own workforce: 0

Number of severe human rights issues and incidents connected to own workforce that are cases of non respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises: 0

Amount of material fines, penalties, and compensation for severe human rights issues and incidents connected to own workforce: 0 EUR

Sanoptis has no knowledge of any severe human rights issues or incidents occurring in 2024.

Canyon

Total number of incidents of discrimination during the reporting period: 10

Number of complaints filed through channels for people in own workforce to raise concerns: 29

Number of complaints filed to National Contact Points for OECD Multinational Enterprises: 0

In the reporting period, 29 cases were submitted through the reporting channels by the company's own workforce. These cases covered a range of issues, including 10 cases of discrimination (accounting for 34% of all reported cases), 2 cases of fraud, 2 cases related to working hours, 1 case concerning health and safety, and 14 cases categorized as 'Others'. Each case was thoroughly investigated, with appropriate measures, including disciplinary actions, taken as necessary. By the end of the reporting period in 2024, 97% of the cases reported during this time had been closed and resolved, with no financial penalties resulting from reported cases of discrimination.

Amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors: 0 EUR

Number of severe human rights issues and incidents connected to own workforce: 0

Number of severe human rights issues and incidents connected to own workforce that are cases of non respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises: 0

Amount of material fines, penalties, and compensation for severe human rights issues and incidents connected to own workforce: 0 EUR

No severe human rights violations have been reported within Canyon's workforce during the reporting period.

Imerys

Sienna IM

Not disclosed in the excerpts provided.

Business conduct policies and corporate culture

Code of Conduct and Ethics (the "Code")

Policy name: Code of Conduct and Ethics (the "Code")

Scope: The Code applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly own subsidiaries. It applies to GBL's workforce and the Directors.

Governance and oversight: The Code has been formally reviewed and approved by GBL's Board of Directors with the support from the Governance and Sustainability Committee. The CEO is responsible for the oversight of GBL's business conduct and the direct responsibility for business conduct has been delegated to the Corporate Secretary and Chief Legal Officer.

Key content/principles: The Code provides guidance in conducting business activities in accordance with the highest legal, ethical and professional standards. It notably covers compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery, relations with third parties, respect at work and non-discrimination. The Code defines the values and principles that govern the management of activities and are established as rules of good conduct. Corporate culture expresses goals through shared values and beliefs and guides GBL's activities through shared assumptions and norms such as values or mission statements.

Public availability: The Code is publicly available on GBL's website.

Link to international standards: Through the Code, GBL is committed to carrying out its business ethically and in accordance with all applicable laws and regulations. GBL has been formally committed to the United Nations Global Compact (UNGC) initiative since 2018. Adhering to the UNGC and its 10 principles (covering human rights, labor, environment and anti‑corruption) allowed GBL to cover all general areas that could be impacted by its activities. Under its commitment to the UNGC initiative, GBL recognizes in particular the provisions offered by the UN Guiding Principles on Human Rights and the Organisation of Economic Co‑operation and Development (OECD) Guidelines for Multinational Enterprises. GBL recognizes the United Nations Convention against Corruption (disclosure reference 10(b)).

Monitoring implementation: Cooperation and involvement of all employees is expected in order to ensure compliance with the Code either directly by exemplary behavior or indirectly by approaching the Compliance Officer or by reporting any breach confidentially through the Whistleblowing Procedure. GBL aims to ensure that all people in own workforce are trained in the Code so that they adopt best practices in the context of their activities. GBL is particularly committed to raising awareness among its employees of GBL's values and practices and organizes on a yearly basis mandatory training for its entire workforce. GBL retained the target of having 100% of its own workforce trained on the Code on an annual basis over the period FY2025-FY2030. In FY2024, 100% of its own employees have been trained on the Code. The Code and its implementation are evaluated by GBL's Governance and Sustainable Development Committee and GBL's Board of Directors on an annual basis.

Code of Conduct for Suppliers (the "Supplier Code")

Policy name: Code of Conduct for Suppliers (the "Supplier Code")

Scope: The Supplier Code applies to GBL's suppliers.

Key content/principles: In accordance with GBL's Code of Conduct and Ethics and the Supplier Code, GBL maintains standard, market-practice contractual and commercial relationships with suppliers to conduct its operations.

Public availability: Not specified.

ESG Policy (the "ESG Policy")

Policy name: ESG Policy (the "ESG Policy")

Scope: The ESG Policy applies to GBL as a "responsible company", i.e., the parent company GBL SA and its 100% direct and indirectly own subsidiaries.

Governance and oversight: The ESG Policy has been formally reviewed and approved by GBL's Board of Directors with the support from the Governance and Sustainability Committee.

Key content/principles: The ESG Policy reflects the core values that guide GBL on environmental, social and governance issues. It presents the commitments and implementation guidelines for the teams. The ESG Policy addresses the risk that the inability of GBL to enforce a proper integration of ESG factors in pre-investment cycle (exclusion policy, ESG proprietary rating, ESG due diligence) and post investment cycle (ESG strategic plan, ESG engagement, ESG risk monitoring, stewardship, exit) may affect GBL's reputation and the performance of its investment activities.

Public availability: The ESG Policy is publicly available on GBL's website.

Dealing Code

Policy name: Dealing Code

Scope: Particular attention must be paid to "Relevant Persons" as defined in the Dealing Code regarding compliance with these obligations.

Governance and oversight: GBL's Board of Directors has issued a set of rules compiled in the Dealing Code.

Key content/principles: As an investment holding company, GBL is committed to safeguarding the integrity and transparency of markets by combating any form of market abuse (insider dealing, dissemination of false information and price manipulation) concerning GBL securities or those of its subsidiaries. The Dealing Code sets the policy on the prevention of market abuse, as defined by the Market Abuse Regulation (EU) 596/2014 of the European Parliament and of the Council and its European and Belgian implementing provisions. GBL prioritizes compliance with the principle of equal information between investors.

Public availability: The Dealing Code is part of the Charter and can be accessed on GBL's website.

Monitoring implementation: GBL undertakes to ensure that its own workforce is trained in the Code and the Dealing Code so that all the employees adopt best practices in the context of their activities. In FY2024, training efforts focused on market abuse and portfolio compliance.

Whistleblowing Procedure

Policy name: Whistleblowing Procedure

Key content/principles: Under the Whistleblowing Procedure detailed in the Code, all employees may exercise their right to securely report an actual or potential violation of the Code or any other violation covered by the procedure. Reporting via the scheme by approaching the Compliance Officer is confidential and the employee, when acting in good faith and in compliance with the rules of the Whistleblowing Procedure, shall not be subject to reprisal. GBL is committed to investigating any business conduct incident promptly, independently and objectively. The Code includes provisions regarding protection of whistle-blowers (disclosure reference 10(d)).

Monitoring implementation: Ultimately, the effectiveness of the channel offered by the Whistleblowing Procedure is reviewed on an annual basis by GBL's Governance and Sustainable Development Committee.

Additional Policy Commitments

Anti-corruption and anti-bribery: Integrity in conducting business is established as a fundamental value within GBL both with regard to the trust of its stakeholders and vis-à-vis legal risks that may result from the commission of corruption or other related offences. GBL recognizes corruption and influence peddling as an obstacle to free competition and the economic development of our companies. GBL adopts a zero tolerance approach to any actions by its employees that may be linked in one way or another to acts of corruption or political influence.

Political contributions and lobbying: GBL intends to solely exercise its investment purpose and not to jeopardize it with any direct or indirect involvement in policy, law and regulation development or lobbying activities. Under the Code, GBL does not make any political contributions and is not involved in any lobbying activity as this would jeopardize its independence and ability to exercise its investment activity characterized by a long term investment horizon.

Business Conduct Metrics (FY2024)

• Percentage of functions-at-risk covered by training programs: 100%
• Number of convictions for violation of anti-corruption or anti-bribery laws: 0
• Amount of fines for violation of anti-corruption or anti-bribery laws: EUR 0
• Number of confirmed incident of corruption or bribery: 0
• Number of confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents: 0
• Number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery: 0

Prevention and detection of corruption and bribery

GBL Holding (own operations)

G1-3 is marked as incorporated by reference on page 44, but no specific anti-corruption or anti-bribery policy details are disclosed in the GBL holding section. The disclosure references are not materially covered in the excerpts provided for GBL's own operations as a holding company.

GBL Consolidated Entity

At the consolidated level, G1-3 is marked as "Not applicable" in the disclosure requirements table (page 63 and page 78). This indicates that prevention and detection of corruption and bribery was not assessed as material at the consolidated GBL level.

Controlled Participations

Affidea

Anti-Bribery Policy

• Scope: Applies to all Affidea personnel globally
• Key content: Prohibits solicitation or acceptance of bribes, kickbacks, or other corrupt payments. Defines bribery and sets out prohibited conduct. Any violation may result in disciplinary action up to and including termination of employment and/or criminal prosecution
• Governance: Management board is notified of any allegations. Investigations conducted internally or through external parties. General Counsel and Chief Risk and Compliance Officer are whistleblowing referents
• Monitoring: Annual online "Code of Conduct certification" training. In February 2024, 5,212 employees completed training (80% completion rate). Top management completion rate: 100%. Training via Cognito platform includes video materials, interactive exercises, and knowledge tests
• Links to international standards: Not explicitly stated
• Training coverage: 100% of functions-at-risk covered by training programs

Sanoptis

Sanoptis has not yet adopted a standalone anti-corruption or anti-bribery policy. Whistleblower protection is provided through national regulations in countries where Sanoptis operates (Germany, Austria, Greece, Spain, Italy, Switzerland), but no specific anti-corruption compliance program is disclosed.

Canyon

No information provided in the excerpts.

Sienna IM

Anti-Corruption/Anti-Bribery Policy

• Scope: Applies to all Group entities and employees
• Key content: Consistent with the UN Convention against Corruption. Supported by several implementing procedures including management of conflicts of interest, gifts and benefits, whistleblowing, AML/FT, personal transactions, and purchase policy. Employees prohibited from soliciting gifts/benefits. Gift value limit of €200. Gifts above this threshold must be reported to DRCCI and returned
• Governance: RCCI (Risk and Compliance) or Head of Compliance and Internal Control reports to CEO or Chairman of the Board. Findings reported to entity Risk and Compliance Committees and Board of Directors, as well as to Sienna IM Group Chief Risk and Compliance Officer. Organization based on "three lines of defense" principle ensuring independence of control functions
• Public availability: Global policy regrouping principles, procedures, escalation process being finalized (expected Q1 2025). Several procedures already in place for regulated entities as part of mandatory internal control
• Links to international standards: UN Convention against Corruption
• Monitoring: Controls embedded in operation processes, dedicated control teams (risk and compliance), and internal audit. Annual reporting to Risk and Compliance Committee, Management Committee, and Board of Directors. Alert notes for detected corruption events within 5 working days. Mandatory training planned for all employees in Q3 2025
• Training: As of 2024, 0% of functions-at-risk covered (new general policy with mandatory training for all employees planned for Q3 2025)

AML/CFT Procedures

• Scope: Applies to investment services and marketing of collective investment schemes
• Governance: Overseen by AMF (Autorité des Marchés Financiers) in France, CSSF and other authorities in Luxembourg
• Key content: Risk assessment and management systems for Anti-Money Laundering and Counter-Terrorist Financing

Imerys

Antibribery Policy

• Scope: Applies to all directors, officers and employees of any Imerys legal entity, covering all activities in all jurisdictions where the Group operates. Suppliers required to comply with Imerys' Supplier Environmental, Social & Governance Standards including antibribery compliance
• Key content: Zero tolerance against corruption and bribery. Prohibits bribery from business practices. Available in 23 languages and reviewed annually. Defines and illustrates different types of prohibited behaviors
• Governance: Overseen by Ethics Committee. Investigation process detailed in Group whistleblowing policy
• Public availability: Available on Group intranet, accessible to all employees. Translated into Group's main working languages. Forms part of Internal Rules (Règlements Intérieurs) of French entities. Available on Imerys website for payments to governmental authorities report
• Links to international standards: Compliant with French Law "Sapin II"
• Monitoring: Comprehensive compliance program including:
  • Internal alert system for employees and external parties
  • Regularly updated risk map to identify, analyze and assess bribery exposure risks
  • Processes to evaluate third parties considered most at-risk
  • Extensive antibribery accounting controls
  • Training initiatives for most at-risk functions
  • Disciplinary sanctions for policy breaches
  • Regular monitoring and assessment by Ethics Committee
  • Mandatory online training for newcomers and at-risk functions (11% of all employees)
  • Voluntary virtual classes for operations and legal functions

Supporting Procedures

• Gifts & hospitality procedure (includes reporting and prior approval rules)
• Conflict of interest procedure (reporting and management rules)
• Donations procedure (reporting and approval requirements)
• Intermediary due diligence procedure (for agents and distributors)

Group Tax Policy

• Key content: Fully in line with best international standards on anti-tax avoidance and tax evasion. No artificial arrangements for tax planning, no transfer of value to low tax jurisdictions, no use of tax havens. Committed to full compliance with tax obligations

Performance

• Affidea: Zero confirmed incidents of corruption or bribery in FY2024
• Sienna IM: Not disclosed in excerpts
• Imerys: No convictions or fines for violation of anti-corruption and antibribery laws in 2024

Incidents of corruption or bribery

GBL Holding (Part I)

GBL discloses business conduct metrics in its sustainability statement for the holding segment.

Consolidated entities

For GBL's consolidated entities (Affidea, Sanoptis, Canyon, Sienna IM), corruption and bribery incidents are disclosed as follows:

Affidea:

• Number of convictions for violation of anti-corruption or anti-bribery laws: None
• Amount of fines for violation of anti-corruption or anti-bribery laws: None
• Number of confirmed incidents of corruption or bribery: None
• Number of confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents: None
• Number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery: None

Sanoptis: Corruption and bribery assessed as non-material. No quantitative disclosures provided under G1-4.

Canyon: Corruption and bribery assessed as not material for Canyon. No quantitative disclosures provided under G1-4.

Sienna IM: No specific G1-4 disclosures identified in the excerpts.

Investigation and speak-up mechanisms

GBL has implemented a Whistleblowing Procedure as part of its Code of Conduct. All people in own workforce may exercise their right to securely report an actual or potential violation of the Code or any other violation covered by the Whistleblowing Procedure. Reporting via the scheme is confidential and the employee, when acting in good faith and in compliance with the rules of the Whistleblowing Procedure, shall not be subject to reprisal.

GBL is committed to investigating any business conduct incident promptly, independently and objectively. The effectiveness of the channel offered by the Whistleblowing Procedure is reviewed on an annual basis by GBL's Governance and Sustainable Development Committee.

At the consolidated level, GBL reports that 100% of its activities are covered by a Code of Conduct including a whistleblowing process across all consolidated entities (GBL, Imerys, Affidea, Sanoptis, Canyon, Sienna IM).

Political influence and lobbying activities

Political engagement approach

GBL intends to solely exercise its investment purpose and not to jeopardize it with any direct or indirect involvement in policy, law and regulation development or lobbying activities. Under the Code, GBL does not make any political contributions and is not involved in any lobbying activity as this would jeopardize its independence and ability to exercise its investment activity characterized by a long term investment horizon.

Ethical standards and guidelines

Integrity in conducting business is established as a fundamental value within GBL both with regard to the trust of its stakeholders and vis-à-vis legal risks that may result from the commission of corruption or other related offences. GBL recognizes corruption and influence peddling as an obstacle to free competition and the economic development of our companies. GBL adopts a zero tolerance approach to any actions by its employees that may be linked in one way or another to acts of corruption or political influence.

Political contributions

GBL does not make any political contributions.

Amount: €0

Lobbying expenditure

GBL is not involved in any lobbying activity.

Amount: €0

Trade association memberships

No disclosure of trade association memberships or related fees at the GBL holding company level. GBL's role is focused on investment management rather than industry-specific advocacy.

Training and compliance

GBL undertakes to ensure that its own workforce is trained in the Code and the Dealing Code so that all the employees adopt best practices in the context of their activities. GBL is particularly committed to raising awareness among its workforce of GBL's anti-corruption and business conduct values and practices. Yearly training courses are organized for its workforce.

In FY2024, 100% of its own employees have been trained on the Code.

EU Transparency Register

Not registered. GBL does not engage in lobbying activities.

Consolidated entities disclosure

For GBL as a consolidated entity, ESRS G1-5 (Political influence and lobbying activities) is marked as Not applicable in the disclosure requirements table.

Controlled participations

Affidea: Does not engage in any lobbying or political activities. The Gift and Hospitality policy strictly regulates this matter. No financial or in-kind political contributions. Not registered in EU transparency register.

Sanoptis: No specific G1-5 disclosure provided.

Canyon: Does not engage in lobbying activities. No financial or in-kind political contributions reported.

Sienna IM: Does not have material impacts on political influence and lobbying activities.

Imerys:

• Political contributions made: €0 (2024)
• Financial or in-kind contributions regarding lobbying expenses: €0 (2024)
• In line with its Code of Business Conduct and Ethics, Imerys is committed to ensure that its lobbying activities and the representation of its business interests are carried out with integrity and transparency.
• Imerys is registered in the EU Transparency Register under number 175286523869-61 and the French national transparency register (Répertoire des représentants d'intérêts of the French High Authority for Transparency in Public Life (HATVP)).
• In 2024, Imerys was not directly involved in lobbying activities around proposed regulations. The Group participated in the public debate indirectly through its memberships in professional associations.

Payment practices

GBL Holding (Part I)

G1-6 Payment practices is listed as incorporated by reference on page 44 but marked as "-" (no specific page reference provided). The topic was assessed as non-material for GBL holding.

GBL Consolidated (Part II)

G1-6 Payment practices is listed as "Not applicable" for GBL consolidated entity across all disclosure requirement tables.

Controlled Participations

Affidea

Payment practices description:

Affidea's standard payment terms are payment on receipt of invoice for medical materials, which is generally within 30 days. For larger purchases for global/large suppliers, payments are between 45-60 days.

Average payment time:

Standard payment terms by supplier category:

• Large global suppliers: 45-60 days
• Contrast media: 90 days
• Small local suppliers: up to 30 days

Percentage of payments aligned with standard payment terms: Data not available in detail for 2024, will be compiled in 2025.

Legal proceedings:

Contextual information: Affidea has global procurement policy for large equipment from large companies (e.g. GE, Siemens, Philips). The payment terms for such global suppliers is in accordance with globally acceptable payment terms. For local/country suppliers of medical materials, payment terms are in accordance with contractually agreed periods or on receipt of invoice.

Sanoptis

No G1-6 payment practices information disclosed.

Canyon

No G1-6 payment practices information disclosed.

Sienna IM

No G1-6 payment practices information disclosed.

Imerys

Payment practices monitoring:

Imerys monitors compliance with payment terms to mitigate the risk of late payment. Currently, this monitoring includes payments to SMEs, however the Group is not technically capable of monitoring SMEs specifically and separately from other suppliers.

Average payment time (2024):

Standard payment terms: Imerys has defined a list of standard payment terms in its Purchasing Policy, subject to applicable national regulations. Alignment with standard payment terms is monitored in the Group information systems, taking into account Group payment practices. Specific payment term details by category not disclosed.

Legal proceedings:

Status: In December 2024, Imerys became involved in two legal proceedings related to late payments. Following interventions, Imerys successfully resolved one case by reaching an agreement with the supplier, while the other case is ongoing.

Multi-year comparison:

Policy context: The Group purchasing function is responsible for the management of Imerys' relationship with suppliers. The general principles relating to the purchasing process (including payment terms) and allocation of responsibilities is defined in the Group purchasing policy. Sustainable behavior includes complying with legal and contractual payment terms and ensuring a smooth payment process for suppliers. The Group purchasing policy defines standard payment terms applicable to suppliers, including SMEs, based on applicable legal payment terms.