Groupe Bruxelles Lambert (GBL)

Reference: pages 11-12. Board composition and diversity datapoints are also incorporated by reference to Annual report volume 1, section 2.2, page 25 (Appendix II, Note 3, page 81).

The Board has 12 members: 11 non-executive (92%) and 1 executive, the Managing Director. Four are women (33%) and four are independent (33%). Six were proposed by the controlling shareholder, Pargesa SA, a structure GBL says departs from Article 3.7 of the 2020 Belgian Code on Corporate Governance. Employees are not represented on the Board. Executive management is three people: the Managing Director, the CFO and the General Secretary & Chief Operating Officer.

Two committees support the Board: the Audit Committee (four members, two proposed by the controlling shareholder) and the Governance and Sustainable Development Committee (three members, one proposed by the controlling shareholder). In 2025 the Audit Committee's remit was extended to cover sustainability reporting, its internal controls and the independence of the assurance provider (page 12).

Reference: pages 12, 14. Appendix II, Note 3 points to pages 11 and 47 for GOV-2 (page 81).

The Board reviews strategy, policies, actions and performance on material IROs once a year with the Managing Director and the Head of ESG, covering both GBL as a Responsible company and as a Responsible investor. It also gets the latest developments at each meeting through a section of the Managing Director's letter, and each investment memo carries the key material IRO findings for that case (page 12).

The Governance and Sustainable Development Committee reviews the Responsible company IROs on an ongoing basis. The Audit Committee reviews every year the risks of acting as a Responsible investor, including an IRO-specific risk assessment run as part of portfolio monitoring. Each committee reports to the Board through its Chairwoman (page 12).

The Board and Audit Committee are informed once a year of affected stakeholders' views and of peer review and benchmarking conclusions (page 14).

Reference: pages 13, 18.

GBL states that no specific sustainability-related performance measure is part of its incentive schemes today, given its progress on sustainability matters and its current level of ESG integration (page 13). For climate it says the same: no specific climate-related performance is in the incentive schemes, although it is delivering against its SBTi targets (page 18). The Remuneration Policy is incorporated by reference to Annual report volume 1, section 2.3.1, page 38 (not part of this document).

Note: page 21 lists among the Board's climate oversight tasks monitoring of "achievement of climate KPIs included in short-term and long-term incentive plans", which sits uneasily with the statements on pages 13 and 18.

Reference: pages 13, 65. The statement itself is Appendix I, Note 1, Table 30 (page 65).

GBL says its due diligence process supports its sustainability disclosures at every stage of defining and implementing its strategy on sustainable IROs (page 13).

Table 30 groups the due diligence elements and points each to an ESRS 2 disclosure: contribution to governance, strategy and business model (GOV-2, GOV-3, SBM-3); contribution of stakeholder engagement (GOV-2, SBM-2, IRO-1, MDR-P); identification and assessment of adverse impacts (IRO-1, SBM-3); and support to the range of actions, including the transition plan (MDR-A, MDR-M, MDR-T). The table cites pages 12, 14, 16 and 48 of this document and page 38 of Annual report volume 1.

Reference: pages 13, 12. By reference to Annual report volume 1, which is not part of the source text read here.

GBL gives no standalone description in this volume. For internal control over sustainability reporting it points to the Risk management chapter of the Annual report: section 3.2.1 Risks specific to GBL (page 63) and section 3.2.4 Control activities (page 67) (page 13). Appendix I, Note 4 (page 72) appears to cite pages 65 and 67 of volume 1 for the same disclosure, so the first page number differs between the two places.

Inside this volume, the Audit Committee's 2025 tasks include monitoring the sustainability reporting process, the internal control and risk management systems for it, the assurance, and the assurance provider's independence (page 12).

Reference: pages 13, 4-5.

GBL is an investment holding company with over seventy years of stock exchange listing, permanent capital and a stable family shareholder base. It splits its sustainability strategy in two (page 13): GBL as a Responsible company (the parent and its direct and indirect wholly owned subsidiaries, with impacts as an employer and community contributor) and GBL as a Responsible investor (all portfolio companies, controlled or not, handled through ESG integration across the investment cycle).

Core processes are pre-investment (origination, due diligence), post-investment (value creation, monitoring, divestment) and supporting operations. Upstream exposure is limited to financial service providers, office landlords and mobility suppliers. Non-controlled participations are treated as part of the value chain, and GBL has no customers (page 13). At year-end 2025 it had 73 employees in 6 offices (page 10).

Controlled participations in scope: Imerys, Affidea, Canyon, Sanoptis and Sienna Investment Managers, the last shown as a discontinued activity (page 5).

Reference: pages 14, 30-31.

GBL names its key stakeholders (page 14): affected stakeholders (its portfolio companies and its workforce); users of sustainability statements (financial institutions and banking relationships); and stakeholders in both groups (shareholders, the Board and Committees, controlling families, peers).

Engagement is part of the DMA. In 2024 it ran as direct interviews with representatives of each category. In 2025 key stakeholders were involved directly in formulating and running GBL's strategy and business model. The Board and Audit Committee are told once a year what affected stakeholders think about sustainability impacts, together with the conclusions of peer review and industry benchmarking (page 14).

On the workforce, see page 30. GBL treats auditors, lawyers, financial advisors and landlords as value chain stakeholders and sees no reason to believe those relationships are material, so it leaves them out of its own engagement strategy (page 31).

Reference: pages 16-17. Phase-in applied to the SBM-3 anticipated financial effects (page 9).

The DMA for GBL as a Responsible company found nine material items, a list GBL says is identical to 2024 (page 15). No opportunities are listed.

Impacts: climate change mitigation (actual negative, long term, from GBL's own operations but driven indirectly by portfolio emissions); training and skills development (positive, medium term); corporate culture (positive, long term); philanthropy (entity-specific, positive, medium term); ESG integration (entity-specific, positive, medium term).

Risks: adequate wage (medium term); corporate culture (long term); incidents of corruption and bribery, meaning fraud, insider trading, anti-trust and market manipulation (short term); ESG integration (long term).

GBL says its financial statements are deemed to reflect the current effects of these risks, and that it protects the resilience of its strategy by identifying and mitigating material IROs on an ongoing basis (page 17).

Reference: pages 14-15.

GBL runs the DMA for GBL as a Responsible company in four steps: (1) map the sustainability context (strategy, financials, activities and locations, value chain, stakeholders, peers, legal context); (2) build a longlist of IROs from ESRS 1 AR 16, topics from the Equintel AI DMA tool, a peer benchmark and entity-specific topics, tested through stakeholder interviews; (3) assess impact and financial materiality, with three stakeholder representatives (controlling families, senior management, own workforce); (4) map and validate the material IROs.

Impacts are scored on scale (1 to 5), scope (1 to 5), irremediability (0 to 5) and likelihood (1 to 4). Risks and opportunities are scored on magnitude of financial effect (1 to 4) and likelihood (1 to 4). The thresholds are 8 or above for impacts and 0.5 or above for financial materiality (page 15).

In 2025 GBL updated the 2024 DMA with no change in methodology. At consolidated level a risk is material only if the effect on NAV exceeds EUR 500 million, and none reached it (page 54).

Reference: pages 16-17. The lists are in Appendix I, Notes 2 to 5 (pages 66-74) and Appendix II, Notes 1 to 3 (pages 75-83).

GBL points to Note 3 (pages 70-71) for the ESRS disclosure requirements it complied with for GBL holding: E1, S1 and G1. Within S1 the only disclosure requirement missing from that list is S1-12. Note 4 (pages 72-73) lists what is incorporated by reference, and Note 5 (page 74) lists data published voluntarily: E1-5, S1-1, S1-6, S1-8, S1-9, S1-11, S1-14, S1-15, S1-16 and G1-5. Note 2 (pages 66-69) marks the datapoints from other EU legislation, with "Not material" against those for E2 to E5 and S2 to S4.

On negative materiality (page 17), GBL says E2, E3, E4, E5, S2, S3 and S4 did not arise in its longlist and were reassessed and confirmed non-material in 2025. It did not screen its sites for E2 to E5 IROs. Page 57 says the same for GBL consolidated.

Reference: pages 18-19.

GBL says it has a transition plan covering both roles: as a Responsible company it cuts its own footprint on a 1.5°C path; as a Responsible investor it presses portfolio companies to adopt 1.5°C targets. Since 2012 it has exited fossil industries (energy, utilities, cement), and the carbon intensity of the portfolio (scope 3 category 15 emissions divided by NAV) fell by a factor of 30 between 2012 and 2025.

GBL committed to SBTi in May 2021 and had 1.5°C targets approved in January 2022 for its own operations and eligible portfolio. Target 1: cut scope 1 and 2 emissions 52% by 2030 from 2019 (236 to 113 tCO2e). Levers: renewable electricity (-76 t), clean mobility (-55 t), energy efficiency (-5 t), against +13 t from activity growth (Table 3).

2025 progress: scope 1 and 2 down 70% on 2019, mainly from the office refurbishment and a temporary move to a smaller office; 69% of SBTi-eligible NAV covered, against an interim 66% target. OpEx for the plan was EUR 515,055 (+25%), mostly car leasing and clean electricity; no CapEx. No significant locked-in emissions (page 19).

Reference: pages 20-22.

Back-filled from ESRS 2 IRO-1 and the climate DMA subsection, where this content is disclosed in the FY2025 report (pages 20-22). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

GBL has analyzed climate risk across its portfolio since 2020, updated yearly, using geo-localization data for more than 12,500 sites; the 2025 update covered all participations except GBL Capital and Sienna Investment Managers. Time horizons follow ESRS 1 paragraph 77 (page 21).

Transition: two IEA scenarios, Stated Policies (STEPS) and Net Zero Emissions (NZE), each run on a business-as-usual and a science-based-targets pathway; carbon cost is the price per tonne times forecast emissions. GBL treats STEPS/SBT as the one that prevails to 2030 and sees too much uncertainty beyond 2035. Physical: IPCC SSP5-8.5 and SSP2-4.5, with exposure combined with vulnerability (sensitivity plus capacity to cope with a hazard) into one score (page 21). The report gives no global temperature projection per scenario beyond footnote descriptions.

Reference: pages 21-22.

Back-filled from ESRS 2 SBM-3 and the climate DMA subsection, where this content is disclosed in the FY2025 report (pages 21-22). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

GBL says that under the scenarios it used, even high-impact ones, the weighted share of EBITDA at risk from climate transition for GBL and its portfolio is very low, as is weighted exposure to physical risk. It gives four reasons: no significant climate costs in its own operations, a diversified portfolio, a continuing reduction of exposure to carbon assets, and resilient portfolio companies. Potential unpriced carbon costs range from 0.06% to 8.59% of each participation's 2030 EBITDA under STEPS/SBT (page 22).

GBL has not identified any participation that is incompatible with, or needs significant effort to fit, a climate-neutral economy (page 21). It adds that it can mitigate risk through portfolio rebalancing, and that the results go to the Board once a year (page 22).

Reference: pages 22-23.

GBL's climate policy is its ESG Policy, which sets the 2025-2030 ESG commitments and implementation guidelines. It covers climate change adaptation and mitigation, energy efficiency and renewable energy (page 22).

It applies to GBL and its direct and indirect wholly owned subsidiaries. Portfolio companies fall under the Responsible investor approach and manage their own IROs through their own governance. The Board approved the policy, the Managing Director oversees it with the Head of ESG, and the Board reviews its implementation yearly. The policy is public on GBL's website.

On reporting, GBL supports climate disclosure by portfolio companies consistent with IFRS S2 and CDP, and helps them with SFDR, Taxonomy and CSRD requirements (page 22). A 2021 clean mobility policy under the ESG Policy rules out combustion-engine vehicles from newly acquired employee fleet vehicles (page 23).

Reference: pages 23-24.

GBL's actions for its own operations follow three levers (page 23). All offices are leased, so none is owned.

Energy efficiency: after two years of renovation the team moved into the renovated Brussels head office in November 2025; 10% efficiency from 2019 to 2030 would cut 5 t of scope 1. Premises rent was EUR 2.1 million (+36%).

Renewable electricity: the Brussels, Luxembourg, London and Milan offices already used clean or renewable electricity in 2025; scope 2 was 5 tCO2e (-93% on 2019). The target is 100% by end 2030, worth 76 t. Electricity cost EUR 71,372 (-8%).

Clean mobility: 29 of 31 vehicles converted to hybrid or electric; expected cut 55 t; fleet scope 1 was 52 tCO2e (-53% on 2019). Fleet leasing cost EUR 443,683 (+33%).

No CapEx is attached to these actions. GBL did not engage in GHG removal or mitigation project financing in 2025 (page 24).

Reference: pages 23-24, 63.

Both targets are SBTi-approved 1.5°C targets set with the GHG Protocol equity share method (page 23).

Target 1 (own operations): cut scope 1 and 2 emissions by 52% by 2030 from a 2019 baseline of 236 tCO2e. Scope 1 and 2 emissions were 70 tCO2e in 2025 (page 27).

Target 2 (portfolio): 100% of eligible portfolio positions with SBTi-approved 1.5°C strategy and targets by 2030, with an interim 66% coverage by 2025. Coverage was 0% in the 2020 baseline and 69% of eligible NAV in 2025, so the interim target was met (page 24).

Note: page 24 gives the target 2 baseline as 2020, while page 63 words it as 2022 and shows 78% as the share of eligible portfolio companies with validated targets at end 2025 (footnote 18), against 69% of eligible NAV on page 24.

Reference: page 25. The index lists E1-5 at page 25 and Note 5 also marks it as published voluntarily for CDP and SFDR indicators (page 74).

Total energy consumption was 696 MWh in 2025, down from 859 MWh in 2024 (Table 4).

• Fossil: 379 MWh (54% of the total, 69% in 2024), made up of 71 MWh natural gas, 228 MWh other fossil fuels and 80 MWh purchased energy from fossil sources. Crude oil products fell from 333 MWh to 0.
• Nuclear: 111 MWh (16%), up from 33 MWh.
• Renewable: 205 MWh (30%, 27% in 2024), all purchased electricity, heat, steam or cooling. No self-generated renewable energy.

GBL states that, as an office-based holding company, it has no activity in a high climate impact sector.

Reference: pages 26-28, 58-59.

GBL's 2025 emissions (Tables 5 and 24):

• Scope 1: 65 tCO2e (104 in 2024; 160 in the 2019 base year).
• Scope 2: 35 tCO2e location-based, 5 tCO2e market-based (7 in 2024).
• Scope 1 and 2 market-based: 70 tCO2e, 70% below 2019 (236).
• Total scope 3: 14,084,558 tCO2e (17,020,934 in 2024); category 15 investments is more than 99.9% of the total. Own-operations categories are small: business travel 336 t, employee commuting 29 t, upstream energy 25 t.
• Total (market-based): 14,084,628 tCO2e, down 17%.

Scope 3 category 15 is split between equity-share scope 1 and 2 of investees (1,109,894 t), their scope 3 (4,212,457 t) and discontinued Sienna IM (8,761,810 t) (page 26). Intensity per FTE for scope 1 and 2 is 0.9 t (page 27).

For GBL consolidated, total market-based emissions were 16,657,223 tCO2e against 19,705,115 in 2024 (page 59). For investees, 2024 data was carried forward where 2025 data was not yet published; GBL says scope 3 figures carry high measurement uncertainty (page 28).

Reference: page 24. The index lists E1-7 at page 29, where the text is not found.

GBL states: "In 2025, GBL did not engage in GHG removal and GHG mitigation project financing." (page 24). This is a nil return for 2025, and no carbon credits are reported as purchased or planned.

Reference: page 29.

GBL runs an internal carbon price, a shadow price, to steer low-carbon investment, test financing opportunities, stress test investments and meet regulation. Because scope 3 category 15 is more than 99.9% of its emissions, the scheme is used mainly on the portfolio.

The price reflects the 1.5°C path, ETS allowance prices, the cost of measures to reach targets and scenario analysis, built on a database of public carbon prices, scenarios from sources such as the OECD, IEA and Climate Action Tracker, and a pass-through model. GBL assumes rising prices to 2030 with a possible range of EUR 80 to 120 per tCO2e. Given uncertainty outside Europe and a possible EU border carbon tax, it applies a conservative EUR 100 per tCO2e to all assets regardless of location.

GBL's representatives on investee boards use the price to challenge capex plans and carbon positions. GBL says the prices match those used in its financial statements.

Reference: pages 22, 9, 20-21. The index lists E1-9 at pages 20 and 9.

GBL applied the phase-in for E1-9: the statement "does not include such information for this year’s reporting" (page 9), and the same relief covers the SBM-3 anticipated financial effects. GBL gives no monetary amounts for assets or revenue at risk.

What it does give is qualitative analysis plus one percentage range. The climate transition risk and opportunity analysis covers the portfolio, with potential unpriced carbon costs of 0.06% to 8.59% of each participation's 2030 EBITDA under the STEPS/SBT scenario, and weighted physical risk exposure described as very low (page 22). GBL says the scenarios it used are compatible with its financial statements (page 22).

Reference: pages 31-32.

GBL's workforce policies are the Work Regulation (working conditions, remuneration, psychosocial risks, training), the Diversity & Inclusion Policy, the Remuneration Policy, the ESG Policy, the Code of Conduct and Ethics and the Corporate Governance Charter. They cover GBL SA and its wholly owned subsidiaries. The Board approved the Charter, Code, ESG Policy, Remuneration Policy and D&I Policy; the Operational Management Committee approved the Work Regulation. The Remuneration Policy was last approved on May 2, 2025.

GBL has been committed to the UN Global Compact since 2018 and recognizes the UN Guiding Principles and OECD Guidelines. The Charter, Code and Work Regulation provide protection against discrimination on grounds such as age, ethnicity, gender identity, disability and religion; complaints go to the Compliance Officer. GBL sees no specific group at risk, so it sets no group-specific commitments (page 32). Note 5 marks the diversity policy as published voluntarily at investors' request (page 74).

Reference: pages 33-34.

Training and skills development (positive impact): an annual review feeds a training development plan, agreed by line managers and the Head of HR and carried out within 12 months, with a half-year review to track progress.

Adequate wage (risk): GBL mitigates it through a short-term incentive plan (12 months), a long-term incentive plan (10-year horizon, vesting over 3 to 4 years) and a carry plan (typically 10 years) limited to selected people. All employees can benefit from the STIP and LTIP. GBL tracks pay trends in the financial and private equity industry in Continental Europe each year.

Philanthropy is covered at page 44. No CapEx is involved. OpEx for these action plans, mainly training, total compensation and the carry plan, was EUR 105 million in 2025 (+67%), and GBL expects it to stay stable in the short term (page 34).

Reference: pages 34-35.

The Board, supported by the Governance and Sustainable Development Committee, reviews and approves the workforce targets. The workforce was neither involved in setting them nor in tracking them (page 34).

• Target 1: 100% of the workforce covered by an annual review (2025-2030, baseline 2023 at 100%). Result in 2025: 100%.
• Target 2: keep employee turnover at a reasonable level (baseline: 9.6% five-year average, 2019-2023). Result in 2025: 14.1%, above the baseline. GBL judges this target line by line.
• Target 3: keep the employee engagement score above 65% (baseline 2023: 69%). Result in 2025: 71%.

All three apply to the holding segment (page 35).

Reference: pages 35-36. Note 5 marks the average FTE and headcount datapoints as voluntary (page 74).

GBL had 73 employees at the end of 2025 (80 in 2023, 83 in 2024): 40 men and 33 women; none reported as other. FTEs were 78.5 (average 79.9). By country: Belgium 50, rest of EEA 20, UK 3.

By position: 3 C-level, 30 non-executive and 40 workforce level. Ten employees left in 2025, a turnover of 14.1% (17.6% in 2024, 8.3% in 2023). Turnover counts permanent employees leaving for any reason, excluding fixed-term contracts (Table 7).

Headcount is at period end. The Managing Director has an independent status under Belgian rules but is counted in employee headcount (footnote 19, page 36).

Reference: pages 35-36.

GBL had 6 non-employees in its workforce at the end of 2025 (5 in 2024, 3 in 2023): 4 self-employed people and 2 interims. There were no non-guaranteed hours employees (Table 7).

Non-employees are mainly advisors or experts in a dedicated field, such as investment or IT/AI. GBL defines them as people with contracts to supply labor or supplied by employment agencies (NACE N78). Because of the small numbers, the figure is an exact count, not an estimate (footnote 20, page 36).

Reference: page 37. Note 5 marks this disclosure as published voluntarily at investors' request (page 74).

100% of employees were covered by a collective bargaining agreement in each of 2023, 2024 and 2025 (Table 8). GBL says there is no agreement for representation by a European Works Council, SE Works Council or SCE Works Council, because of its size and the lack of an employee representative.

Reference: pages 37-38. Note 5 marks this disclosure as published voluntarily at investors' request (page 74).

Top management (C-level) has 3 people: 2 men and 1 woman (67% and 33%, unchanged since 2023).

Contract type in 2025: men 37 permanent and 3 temporary; women 32 permanent and 1 temporary. Permanent staff are 51% men and 44% women of the workforce (Table 9).

Age: 13 employees under 30 (18%), 43 aged 30 to 50 (59%), 17 over 50 (23%) (Table 11). In 2024 the split was 21, 45 and 17.

Reference: page 38.

100% of employees, and 100% of non-employees, were paid at or above the minimum local mandatory salary in 2024 and in 2025 (Table 12). GBL defines the minimum local mandatory salary as the national minimum wage (footnote 22).

GBL identifies adequate wage as a medium-term risk about attracting talent: it may need market-competitive packages in the financial industry in Continental Europe (pages 16, 34).

Reference: page 38. Note 5 marks this disclosure as published voluntarily at investors' request (page 74).

100% of employees were covered by social protection in 2024 and 2025 (Table 13), through public programs or GBL benefits, against loss of income from sickness, unemployment, employment injury and acquired disability, parental leave and retirement. GBL says it does not operate in countries where employees lack social protection for any of these events.

Reference: page 39.

100% of employees took part in a performance review in 2024 and 2025, men and women alike. Each employee has an annual and a semi-annual review meeting, and 100% of the meetings planned in 2025 were held.

Average training hours per employee: 7.7 in 2025 (9.4 in 2024). Men: 5.4 (7.4 in 2024). Women: 10.6 (12.6 in 2024) (Tables 14 and 15).

GBL ties training to the annual review and the resulting development plan (page 34).

Reference: page 39. Note 5 marks this disclosure as published voluntarily at investors' request (page 74).

GBL reports zero in both 2024 and 2025 for: fatalities in its own workforce, fatalities of other workers on its sites, accidents, rate of recordable work-related accidents, recordable work-related ill health, and days lost to injury, fatality or ill health (Table 16).

All employees are covered by the Work Regulation, which includes accidents on the way to work. GBL has no formal health and safety management system, saying it does not apply to a sector where work typically carries lower physical risk.

Reference: page 40. Note 5 marks this disclosure as published voluntarily at investors' request (page 74).

100% of employees are entitled to family-related leave through social policy and collective bargaining agreements, in both 2024 and 2025. In 2025 four employees were in a position to take family-related leave, and 100% of them did, men and women alike (Table 17). The 2024 take-up figure is shown as "Not relevant".

Reference: page 40. Note 5 marks this disclosure as published voluntarily at investors' request (page 74).

Gender pay gap (Table 18): all employees 45% in 2025 (41% in 2024); C-level and non-executive level 25% (12%); workforce level 10% (12%). Annual total remuneration ratio: 15.6 (13.7 in 2024).

GBL defines the gap as the difference in average gross annual salary between women and men at December 31, 2025. The data excludes interns and GBL Capital employees, and the highest and lowest paid were removed. GBL warns the all-employee figure may be distorted by a very concentrated workforce, private equity pay schemes and positions that are not doubled, so it adds the two sub-group gaps.

Reference: page 41.

As in 2024, GBL recorded no work-related incident of discrimination in 2025, including harassment, and no work-related grievances, incidents or complaints on social and human rights matters through the Whistleblowing Procedure or other legal channels.

It also records no severe human rights issues or incidents connected to its own workforce, no material fines, penalties or compensation for severe human rights incidents, and none for damages from violations of social and human rights factors.

Reference: pages 42-43.

The Board oversees business conduct, supported by the Governance and Sustainable Development Committee, which reviews the Code, and the Audit Committee. The Managing Director oversees it and has delegated direct responsibility to the General Secretary & Chief Operating Officer (page 42).

Corporate culture is a positive impact (long term) and a risk (long term). The Code of Conduct and Ethics sets the values and rules of good conduct and is distributed to staff and published on the website. Anyone can report a breach to the Compliance Officer or through the Whistleblowing Procedure, which is confidential and protects good-faith reporters; GBL commits to investigate promptly, independently and objectively (page 42).

The Dealing Code in the Charter covers market abuse under Regulation (EU) 596/2014. GBL takes a zero-tolerance approach to corruption and influence peddling (page 43). Appendix I, Note 2 points to page 42 for the UN Convention against Corruption datapoint and page 33 for whistle-blower protection (page 69).

Reference: page 43.

Back-filled from the business conduct chapter. G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS; the report was prepared under the 2023 ESRS.

GBL states a target of having 100% of its own workforce trained on the Code on an annual basis over 2025-2030, with a 2024 baseline of 100%. In 2025, 100% of its own employees were trained on the Code. The Governance and Sustainable Development Committee and the Board evaluate the Code and its implementation each year. It is the only business conduct target stated in the chapter.

Reference: page 43.

Table 19 shows zero in both 2024 and 2025 for: convictions for violation of anti-corruption or anti-bribery laws; fines for such violations (EUR 0); confirmed incidents of corruption or bribery; confirmed incidents in which own workers were dismissed or disciplined; and confirmed incidents leading to business partner contracts being terminated or not renewed. 100% of functions-at-risk were covered by training programs in both years.

Incidents of corruption and bribery are listed by GBL as a short-term risk (page 16).

Reference: pages 43, 42. Note 5 marks this disclosure as published voluntarily for the CDP questionnaire (page 74).

GBL says it intends to use its investment role without any direct or indirect involvement in policy, law or regulation development or lobbying. Under the Code it "does not make any political contributions and is not involved in any lobbying activity", to protect its independence and long-term investment approach (page 43). This is a nil return.

Reference: page 42. The index lists G1-6 at page 42, but pages 42-43 contain no payment-practice information.

GBL gives no average time to pay an invoice, no share of payments made within standard terms and no number of late-payment legal proceedings for the holding. The pages cited deal with ethical conduct oversight, the Code and the Dealing Code. Appendix II shows G1-6 as "Not applicable" for GBL consolidated (page 83).

The only related text is the description of GBL's upstream relationships, which are limited to financial service providers, landlords and mobility suppliers (page 13). Affidea gives payment-practice figures in its own appendix (page 225), which is a voluntary disclosure at GBL level (page 57).