Grupa Pracuj S.A.

Reference: page 80

The Management Board, the executive body of three persons, manages the organisation including impacts, risks and opportunities. The Supervisory Board, a non-executive body of seven persons, oversees the Management Board and supervises the impacts, risks and opportunities process through the Audit Committee. As at 31 December 2024 the Management Board comprised Przemyslaw Gacek (President), Gracjan Fiedorowicz and Rafal Nachyna; 100% were men, two aged 30 to 50 and one over 50. On the Supervisory Board the ratio of women was 40%, four members (57.1%) were independent, 71.4% were aged 30 to 50 and 28.6% over 50. There is no employee or value chain worker representation on either body. The Audit Committee comprises three independent members. Since October 2024 the sustainability team reports directly to the President of the Management Board. The Management Board approved an updated Code of Ethics, a Code of Ethics in Business Relationships, a Diversity Policy and signed the Diversity Charter. All Management Board members took part in the double materiality assessment.

Reference: page 82

The President of the Management Board is responsible for managing the Group's sustainability matters, which are integrated into management processes. Meetings between the ESG team and the President take place at least once every two weeks to review activities, with additional meetings with other Management Board members and key managers as needed. The Audit Committee plays a central role in overseeing the sustainability agenda. Since 2024, ESG matters covering implemented and planned initiatives, project completion stages and material impacts, risks and opportunities have been systematically presented at Audit Committee meetings, held at least quarterly. In 2024 the Management Board, Supervisory Board and Audit Committee addressed sustainability matters including work environment surveys, compensation, the Diversity Policy, updates to the Code of Ethics and the Code of Ethics in Business Relationships, compliance and whistleblower matters, organisational culture values, reporting requirements under the amended Accounting Act, required reporting standards, assessment of reporting readiness, significant matters from the double materiality analysis, and selection of the assurance provider.

Reference: page 84

Currently the incentive scheme for the administrative, management and supervisory bodies does not incorporate sustainability-related performance criteria. Under the Remuneration Policy for members of the Management Board and Supervisory Board adopted by the Extraordinary General Meeting on 12 November 2021, the Supervisory Board is authorised to define the criteria for variable remuneration of Management Board members. These criteria may be financial and non-financial, and may encompass social interests, the Company's contribution to environmental protection, and measures aimed at preventing and eliminating the negative social effects of the Company's activities. The Group states that this matter will be analysed by the Supervisory Board and Management Board in 2025.

Reference: page 85

The Group provides a statement on due diligence mapping the core elements of due diligence to sections of the Statement. Embedding due diligence in governance, strategy and the business model is covered in ESRS 2 GOV-2, GOV-3 and SBM-3, and in E1 SBM-3, S1 SBM-3 and S2 SBM-3. Engaging with affected stakeholders in all key steps is covered in ESRS 2 GOV-2 and SBM-2, and in E1 SBM-2, S1 SBM-2 and S2 SBM-2. Identifying and assessing adverse impacts is covered in ESRS 2 IRO-1 and SBM-3. Taking actions to address adverse impacts and tracking the effectiveness of these efforts and communicating are both covered in ESRS 2 E1, S1, S2 and G1.

Reference: page 86

The Group operates a comprehensive risk management system covering identification and assessment of risks at strategic and operational levels, with plans to address and monitor the level of risk. Further detail is given in the 'Risk factors and risk management' section of the Management Board's Report. The aim of the process is to reduce adverse effects on the business by efficiently identifying, classifying, evaluating and controlling risks. The process is managed by the Director of Information Security and Risk Management, who reports directly to the CFO. It is a continuous procedure, with risk identification and assessment conducted regularly within a two- or three-year cycle. Subsidiary management is responsible for risk management within their entities, while the Management Board holds ultimate responsibility for assessing the process Group-wide and plays a central role in the system, including for sustainability matters. During Audit Committee meetings the Director provides updates on ongoing and planned risk management activities, enabling the Supervisory Board to evaluate the processes.

Reference: page 88

The Grupa Pracuj S.A. Group is a European leader in HR Technology supporting talent recruitment and management. As a technology-driven platform it develops proprietary technologies using artificial intelligence, process automation and Big Data, focused on two areas, recruitment platforms and recruitment management systems, delivered through a Software as a Service model. It has operated over 20 years in Poland, over 15 years in Ukraine, and since 2022 in Germany. As at 31 December 2024 the workforce was 1,091 employees and Group revenue was PLN 700,015 million (Poland 540,416, Germany 177,189, Ukraine 52,410). Strategic sustainability objectives have not yet been formally established but will be defined in 2025. The value chain comprises an upstream part (energy, network infrastructure, IT equipment, with Tier 1, 2 and 3 suppliers), own operations (recruitment platform services and products, recruitment management systems, multi-posting, sales and marketing, plus support functions, organised into Poland, Germany and Ukraine segments), and downstream end users and customers. Consolidated employee benefits expense was PLN 271.8 million.

Reference: page 92

The Group maintains open, two-way communication with each identified stakeholder group to facilitate continuous information exchange grounded in mutual respect for needs and expectations. Key stakeholders were identified during the 2024 double materiality assessment, with materiality assessed by analysing both the scale of the Group's impact on the stakeholder and the stakeholder's impact on the Group. The Management Board is informed about stakeholder opinions through channels including customer and employee satisfaction surveys, platform user feedback, the infringement reporting system, internal reporting, direct meetings, public opinion monitoring and recommendations from operating teams and the PR department. Reports are analysed by the Management Board and integrated into long-term strategy. The Group identified eight key stakeholder groups: employees, customers, consumers and end-users, investors, suppliers, potential employees, media, and financial institutions. The Statement sets out the methods of engagement, topics addressed and purpose of engagement for each group, such as regular meetings, surveys, hotlines, websites, webinars, conferences and reports.

Reference: page 95

A double materiality assessment identified material topics where the Group has a significant impact (impact materiality) or that significantly affect its operations (financial materiality). Material topics were categorised into two priority levels, highest and moderate. Unless specified, the impacts, risks and opportunities apply across all geographical areas, are dependent on the workforce, and are relevant across short, medium and long-term horizons. The material areas are E1 Climate change, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct. E1 covers the carbon footprint of digital services, greenhouse gas emissions and climate-related physical and transition risks. S1 covers working conditions, secure employment, working time, adequate wage, social dialogue, health and safety, gender equality and equal pay, training, diversity and privacy. S2 covers suppliers' and customers' workers including secure employment, child and forced labour and privacy. S4 covers privacy, personal safety, cybersecurity, social inclusion, non-discrimination and responsible marketing. G1 covers corporate culture, whistleblower protection, supplier relationships and payment practices, and corruption and bribery. This is the Group's first ESRS statement, so no changes in materiality occurred.

Reference: page 100

In 2024 the Group conducted a double materiality assessment aligned with the Act amending the Accounting Act dated 6 December 2024 and the ESRS standards, with support from external advisory firm Materiality sp. z o.o., using the MAX 4 Materiality Assessment Matrix version 4. The assessment covered impacts, risks and opportunities for all topics in the ESRS 1 AR 16 table. Sources included analysis of the business model and value chain, a comparative analysis of nine companies in the job posting and HR digital tools sector, a questionnaire survey of internal thematic experts, a questionnaire and structured interviews with six external stakeholder representatives, and evaluations by external experts. The assessment ran from April to July 2024 and the Management Board approved the results by resolution of 28 November 2024. For impact materiality, four parameters were assessed (scale, scope, irremediable character and likelihood) on a five-point scale, with important, significant or critical topics deemed material. For financial materiality, magnitude and likelihood were assessed on a five-point scale, with topics rated at least medium-high deemed material. Employee representatives were consulted and their opinion delivered to the Supervisory Board.

Reference: page 102

The Statement includes a table of compliance with ESRS disclosures mapping each disclosure requirement to the relevant section of the Statement. It covers the ESRS 2 General Disclosures, including BP-1 (general basis for preparation) and BP-2 (disclosures in relation to specific circumstances), alongside the governance, strategy and impact, risk and opportunity management disclosures (GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1 and IRO-2). The topical standards reported reflect the outcome of the double materiality assessment, with disclosures provided for the material standards E1 Climate change, S1 Own workforce, S2 Workers in the value chain, S4 Consumers and end-users, and G1 Business conduct. The standards E2, E3, E4, E5 and S3 were not assessed as material and are therefore not reported. As this is the Group's first statement prepared in accordance with ESRS, no changes occurred relative to the previous year.

Reference: page 108

The Group has not yet defined a transition plan towards a sustainable economy to ensure its strategy and business model are compatible with the transition to a sustainable economy and with limiting global warming to 1.5 degrees C in line with the Paris Agreement and the objective of achieving climate neutrality by 2050. The Group expects to develop a transition plan within the next two years. So the climate neutrality ambition referenced is the 2050 goal, but no formal company-level plan or interim milestones have yet been adopted to deliver it.

Reference: page 109

The Group currently does not have a formally adopted policy relating to climate change mitigation. It recognises the growing importance of environmental protection and plans to develop an Environmental and Climate Policy to proactively manage impacts and risks linked to mitigation and adaptation. The Management Board intends to address: setting environmental goals and priorities supporting the transition to a net-zero economy, improving energy efficiency and use of renewable energy; establishing mechanisms to monitor Scope 1, 2 and 3 GHG emissions; promoting climate-conscious behaviours through employee education and stakeholder engagement; integrating climate risks into risk management and strategy; and engaging in climate partnerships supporting the Paris Agreement.

Reference: page 109

In 2024 the Group did not have a formal climate change policy and has not yet defined a GHG reduction plan. Group companies are active in initiatives fostering awareness of digital ecology and related climate challenges, centred on market education about the environmental impact of technology. Through its theprotocol.it brand the Group runs the Digital Footprint of Technology project and in 2024 published the Poles on a Digital Balance Beam report, covering cybersecurity, refurbishing of electronic devices, and digital balance. It also continued its partnership with the Polish Smog Alert and the Smoke Belcher Stove Ranking, and surveyed Pracuj.pl users on environmental and air quality attitudes. These actions, primarily in the Polish market, lay groundwork for future formalisation of an environmental and climate policy.

Reference: page 111

The Group has not set quantified GHG reduction targets with a base year, target years or reduction percentages. Based on the organisation's 2024 emissions data, the Group will conduct a decarbonisation pathway analysis in 2025 to outline its approach to reducing emissions. No mitigation or adaptation targets are therefore disclosed for the reporting period.

Reference: page 111

The Group's total energy consumption (including fuel, electricity and heat) in 2024 amounted to 2,665.5 MWh. Of this, 2,440.8 MWh (91.6%) came from non-renewable sources and 224.8 MWh (8.4%) from renewable sources. Fossil fuel consumption included 1,162.8 MWh from crude oil and petroleum products and 74.5 MWh from natural gas, with zero from coal. Consumption of purchased electricity, heat, steam and cooling from fossil sources was 1,203.5 MWh, while purchased renewable electricity, heat, steam and cooling totalled 224.8 MWh. There was no nuclear consumption, no fuel-based renewable consumption and no self-generated non-fuel renewable energy.

Reference: page 115

Emissions were calculated under the GHG Protocol across all three scopes, with 2024 as the base year. Gross Scope 1 GHG emissions were 279.4 tCO2eq. Gross Scope 2 was 504.6 tCO2eq location-based and 476.6 tCO2eq market-based. Total Scope 3 emissions were 8,548.5 tCO2eq across ten calculated categories, dominated by Category 1 Purchased goods and services at 5,311.7 tCO2eq, followed by Investments 1,576.3, Capital goods 658.3, Employee commuting 299.6, Use of sold products 266.5 and Business travel 228.0. Total GHG emissions were 9,332.5 tCO2eq location-based and 9,304.5 tCO2eq market-based. Emission intensity was 12.1 tCO2eq per PLN million of revenue.

Reference: page 116

In 2024 the Group did not implement any GHG removals and storage projects in its own operations or in the upstream and downstream value chain. No carbon credits were purchased or used to finance GHG mitigation projects. Separately, biogenic CO2eq emissions from fuels containing biocomponents were identified and reported as out of scope: 15.1 tCO2eq from gasoline and 1.4 tCO2eq from diesel oil, totalling 16.5 tCO2eq.

Reference: page 117

With reference to the disclosures prescribed by paragraph 62 of ESRS E1-8, the Group does not apply internal carbon pricing schemes. No carbon price, shadow price or internal fee per tonne of CO2eq is applied in the Group's decision-making.

Reference: page 128

The Group manages its own workforce through a set of internal documents grounded in respect for human rights, aligned with the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and ILO conventions. Key policies include the Grupa Pracuj Code of Ethics, the Anti-Bullying and Non-Discrimination Policy, the Diversity Policy, Work rules, Remuneration Rules, Rules of the Company Social Benefits Fund, Personal Data Protection Policy, a Whistleblowing procedure, and Recruitment, Onboarding and Offboarding rules. The Group maintains zero tolerance for child labour, forced labour, human trafficking, modern slavery, discrimination and bullying. Policies fall within the remit of the Management Boards of individual companies, with implementation primarily handled by HR departments. In 2024 the Group developed and adopted a Diversity Policy and became a signatory of the Diversity Charter under the patronage of the European Commission. At softgarden a Corporate Policy guides local operations.

Reference: page 132

Responsibility for engaging with employees rests primarily with managers and directors of organisational units, grounded in direct operational contact. Meeting frequency is set individually by teams and leaders. For more significant matters, such as changes to internal regulations or policies, engagement expands to consultations with employee representatives invited to give feedback. The Management Board and Leadership Team foster open dialogue through regular town halls, team sessions and informal interactions. At the international level, English is the common language; organisation-wide meetings held at least quarterly are simultaneously interpreted into local languages. Employee voices are gathered through regular work environment and culture surveys, hackathons, and an annual competition for improvement and innovation ideas. Modern tools include online surveys and an interactive intranet enabling two-way communication. Employees attend dialogue sessions with HR business partners and managers. Structured feedback includes 360-degree evaluations for managers and 270-degree evaluations for employees, feeding personalised development plans.

Reference: page 132

The Group provides multiple channels for raising concerns accessible to all employees, with regular reminders through internal communications including email updates and intranet announcements. Detailed reporting procedures are covered in the ESRS G1 Business conduct section. All reports are treated as confidential, with access restricted to specifically designated individuals. As part of onboarding, every new hire is informed about feedback channels, including the employee satisfaction survey and the designated whistleblowing platform for reporting irregularities and misconduct: www.gp.zalezymi.pl in Poland and https://whistleblower.softgarden.de in Germany. In Ukraine, concerns can be raised directly via a dedicated email address (MarinaH@robota.ua). The system guarantees full security, confidentiality and protection of personal data. Mechanisms for handling complaints and grievances related to employee matters are further described in the ESRS G1 Business conduct section of the Statement.

Reference: page 133

The Group undertakes targeted actions to eliminate negative impacts on its workforce. Actions implemented include promotion of flexible work arrangements such as a hybrid model and flexible working hours; part-time work opportunities where legally applicable; regular meetings between employees and management at Group and company levels; annual work environment surveys; planned 2025 evaluation of formal employee representation at remaining entities; standardised office workstation ergonomics; ongoing review of the remuneration policy; transparent remuneration and salary-raise principles based on market benchmarks; equal access to training irrespective of gender; and a planned 2025 evaluation at Robota International TOV of a formalised training access procedure. Effectiveness is monitored through annual satisfaction surveys, employee feedback channels, anti-discrimination and anti-bullying monitoring via the compliance system, and annual non-financial reporting to the Management Board and investors. Resources allocated span human, financial, and organisational categories, including HR teams, an ESG Team, and the OHS Committee.

Reference: page 134

In 2025, the Group is focusing on strengthening an organisational culture fostering high performance and employee engagement, deploying IT tools for talent management alongside performance and leadership potential assessment processes to enable succession planning and develop future leaders. Employee engagement remains a top priority, so a work environment survey will be conducted in Poland, Germany and Ukraine to identify areas requiring change, with results informing dedicated workshops and working groups. An important step involves standardisation of the onboarding process, with new training materials, e-learning modules and assessments rolled out across the Group. HR departments will focus on communication and managerial training under the GP Leader Profile initiative, which produced a competence matrix and support pathways for managers spanning self-improvement, team leadership, and contribution to organisational growth. In 2025, the Group will define medium- and long-term targets for managing material impacts, risks, and opportunities related to its own workforce.

Reference: page 135

As at 31 December 2024, the Group's total employee head count was 1,091, comprising 449 male and 642 female employees, with 0 reported as other or not reported. By segment: Poland 653 (248 male, 405 female), Germany 192 (120 male, 72 female), and Ukraine 246 (81 male, 165 female). By contract type, the Group had 998 permanent employees (413 male, 585 female) and 93 temporary employees (36 male, 57 female), plus 1 non-guaranteed hours employee. By working time, there were 1,027 full-time employees (416 male, 611 female) and 63 part-time employees (32 male, 31 female). Starting 2024 the Group reports on a head-count basis rather than FTEs; in 2023 it had 963 active employees and 1,043 total head count. In 2024, 148 employees left the Group, an employee turnover rate of 15%, while 154 new employees were hired.

Reference: page 136

In 2024, the number of non-employees in the Group's own workforce amounted to 132, including 28 women and 104 men. A majority of the non-employees (91.7%) supplied labour under business-to-business (B2B) contracts. The remaining 8.3% comprised individuals engaged under civil-law contracts and those provided by temporary employment agencies. By detailed breakdown, 121 were workers with B2B contracts, 5 were workers provided by temporary employment agencies, and 6 were workers with civil-law contracts (mandate and specific-task contracts). Non-employees comprise sole traders (self-employed people), individuals with service provision contracts with the Group, and personnel provided by external undertakings primarily engaged in employment activities. These figures are reported as head count as at 31 December 2024.

Reference: page 136

At the Group, there are no trade unions or works councils, and no collective bargaining agreements or social agreements in place. At the largest Polish companies, Grupa Pracuj S.A. and eRecruitment Solutions sp. z o.o., employee representatives have been appointed and are invited to take part in consultations on key employee matters. These representatives are chosen through general elections held every two years, and every meeting involving them is formally recorded in minutes to ensure transparency and the continuity of social dialogue. In 2024, consultations with employee representatives primarily concerned amendments to the internal regulations of the Company Social Benefits Fund. At other Group companies, employees are encouraged to submit feedback, concerns, and suggestions through generally available channels, fostering open communication and a dialogue-based, participatory organisational culture.

Reference: page 137

The Group's top management comprises managers and directors. At top management level the gender distribution was 96 female (49%) and 98 male (51%), with 0 other and 0 not disclosed (0%). Across the total workforce of 1,091 employees, the gender split was 449 male and 642 female. By age group: 314 employees were under 30 years old (29%), 744 were aged 30-50 (68%), and 33 were over 50 years old (3%). The Group is committed to promoting balanced gender distribution across all levels of the organisation and to gender balance as set out in its Diversity Policy adopted in 2024. Diversity-related topics are a key area assessed in the annual work environment surveys conducted at each Group entity, with findings used to plan targeted initiatives.

Reference: page 137

In 2024, all of the Group's employees were paid above the adequate wage, determined in line with the minimum wage benchmarks published by Statistics Poland and its counterparts in other countries where Group companies operate. The percentage of the Group's employees paid below the adequate wage was 0.0%. The remuneration framework applies to employees working under employment contracts. In collaboration with an external partner, Grupa Pracuj undertook a job valuation process and developed a salary grid assigning specific positions to corresponding salary levels, intended to establish compensation reflecting the nature of the job and the employee's skills, and to prevent gender-based salary disparities. Annually, all entities within the Group perform salary level analyses against local market benchmarks to maintain their competitive position.

Reference: page 138

The Group's employees are covered by social protection against loss of income provided by the countries where Group companies operate. In 2024, all employees (individuals with employment contracts) were covered by social protection through public programmes. In addition, Grupa Pracuj S.A. operates a Company Social Benefits Fund, under which employees may apply for non-wage social benefits if facing difficult life, family, or financial circumstances, such as serious or chronic illness, accidents, or the death of a close relative. Due to specific local conditions, Robota International TOV has implemented a support and reintegration programme for war veterans returning to work after active military service, providing legal consultations, psychological counselling, and financial assistance. The company also provides quarterly training sessions to raise awareness of veterans' challenges, and employees performing military service continue to receive regular remuneration.

Reference: page 138

The percentage of employees with disabilities in the Group's own workforce was 2.3%, of whom 1.1% were women and 1.2% were men. The Group articulates its approach to non-discrimination, equal opportunities, and the promotion of diversity and social inclusion primarily through its Code of Ethics and Diversity Policy, guaranteeing equal access to employment, professional growth and advancement for all and striving to foster an inclusive, supportive and engaging work environment in which every employee feels safe, valued and respected.

Reference: page 138

The Group provides training and development following the 70/20/10 model, where 70% of learning comes from experience, 20% from others, and 10% from formal development activities such as training, conferences and courses. Formal initiatives include internal and external training on soft skills and technical expertise, conferences, postgraduate courses, coaching, mentoring, specialist literature, and language classes, plus funded access to a self-selected e-learning platform. Programmes such as Your Growth Festival, webinars, discussion panels, and the Insights Discovery test support development. The average number of training hours per employee was 31 for female employees and 34 for male employees. The percentage of employees participating in regular performance and career development reviews was 84% for women and 77% for men. The 270- and 360-degree evaluations cover all employees after onboarding, and annual career development sessions plan development goals.

Reference: page 139

In 2024, there were no minor, serious, or fatal accidents at the Group, nor were there any occupational diseases identified. The Group's business activities are not associated with work performed in hazardous conditions, as work duties are primarily carried out in office-based settings. The most relevant occupational risks include inadequate workstation ergonomics, prolonged sitting, work-related stress, task monotony, noise, and improper lighting. A comprehensive Occupational Health and Safety management system is in place across the Group, encompassing procedures, instructions, regulations, and internal standards. At Grupa Pracuj S.A. and eRecruitment Solutions sp. z o.o., OHS obligations are enhanced through an external service provider, while in other companies management monitors adherence. An OHS Committee operates at the Company and at softgarden to safeguard employee well-being and improve working conditions.

Reference: page 139

All of the Group's employees, in Poland and on the other markets of Ukraine and Germany, are entitled to take family-related leave. The percentage of employees entitled to take family-related leave was 100% for both female and male employees. The percentage of entitled employees that actually took family-related leave was 12% for women and 6% for men. The Group also promotes work-life balance through flexible working arrangements including remote, hybrid, and office-based models tailored to individual and team needs, respect for defined working hours, and clearly established rules for communicating employee availability, with staff engaged predominantly under employment contracts ensuring comprehensive protection of employee rights and access to full employment-related benefits.

Reference: page 139

The gender pay gap at the Group, calculated by subtracting the mean hourly pay rate for women from the mean hourly pay rate for men, dividing the difference by the mean hourly pay rate for men and multiplying by 100, amounted to 32%. This value is significantly influenced by the employment structure: approximately one-third of the workforce are IT experts, a group commanding higher remuneration and predominantly male, and top management positions are primarily held by men. The methodology encompasses the entire workforce including inactive employees on long-term sickness absence or parental leave, largely women whose pay is not regularly indexed. A refined internal methodology shows less pronounced disparities, with a reverse pay gap in some tiers. An in-depth pay gap analysis will be conducted in 2025. In 2024, the ratio between the total annual remuneration of the highest paid individual and the median remuneration for employees (excluding the highest-paid individual) was 16.

Reference: page 139

The Group monitors and reports the number of complaints related to employee matters. In 2024, no incidents of discrimination, including harassment, were identified. Furthermore, no serious incidents were reported in 2024 that would constitute violations of the principles set out in the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational Enterprises. The total amount of fines, penalties, and compensation for damages as a result of the incidents and complaints disclosed above was PLN 0.

Reference: page 144

The primary policy governing value chain workers is the Code of Ethics in Business Relationships, a mandatory part of supplier contracts that defines minimum standards for business partners. It covers legal compliance, counteracting corruption and conflicts of interest, a safe and friendly work environment, information security, personal data protection, preventing unfair competition, and reporting irregularities. It was structured in line with the OECD Guidelines for Multinational Enterprises and forms part of a due diligence process designed under the UN Guiding Principles on Business and Human Rights. It explicitly rejects and prohibits child labour and forced labour. Oversight rests with the Pracuj Group Compliance Officer, with implementation across subsidiaries overseen by each company's CFO. In 2024 the Company implemented a Supplier Due Diligence process to screen suppliers on compliance, sustainability, and environmental, social and labour issues. The Group's Code of Ethics also commits to respecting human rights and prioritising the safety and dignity of value chain workers.

Reference: page 145

The Group's processes for engaging with value chain workers include screening of suppliers and contractors with attention to human rights, equal treatment and health and safety standards; educational initiatives, including on pay transparency and sharing research findings on employees' and candidates' needs; following high-quality customer service standards; conducting surveys assessing customer and user satisfaction and needs; and payment practices such as timely payments alongside transparent procurement procedures. The Group has not established a general process for engaging with value chain workers, but their perspectives, particularly those of individuals working for the Group's customers and users of its platforms, are taken into account in decision-making and significantly influence product and service development and the business model. To mitigate potential negative impacts, the Group engages with suppliers directly at the procurement stage by screening key supplies under the Supplier Due Diligence process and incorporating the Code of Ethics in Business Relationships into contracts with key suppliers. The most comprehensive 2024 engagement initiative was the double materiality assessment, with suppliers, contractors and partners invited to surveys and interviews.

Reference: page 145

The Group has not identified any material actual negative impacts affecting workers in its value chain. The Code of Ethics in Business Relationships, implemented across the Group's largest Polish companies, contains information on the path for reporting irregularities and cases of misconduct, described in more detail in the ESRS G1 Business conduct section. In addition, individuals who perform services for the Group have access to direct communication channels, hotlines, and topic-specific email addresses. Communication and engagement methods differ by group: customers and employees of customers use Customer Service Departments, a hotline and Contact Centre, brand websites, satisfaction surveys, educational meetings, publications and webinars; employees of suppliers are reached through contact during procurement procedures, direct contact with Group representatives, and industry conferences. The Group has not assessed whether value chain workers are aware of and trust the structures and processes put in place for raising concerns. The whistleblower protection policy, which also applies to value chain workers, is described in the ESRS G1 Business conduct section.

Reference: page 146

The Group has not identified any material actual negative impacts affecting workers in its value chain. To prevent identified potential negative impacts, it implements and follows best practices and procurement procedures and adheres to the Code of Ethics, which helps prevent excessive negotiating pressure on suppliers for whom the Group is a key customer; sets realistic delivery timelines based on reasonable estimates to reduce impacts of overly tight deadlines; communicates ethical standards and incorporates the Code of Ethics in Business Relationships into supplier contracts; and ensures a high standard of customer service as measured by the Net Promoter Score (NPS). Positive impacts stem from the Group's role as a reliable business partner, enforcement of high ethical standards among contractors, and educational initiatives promoting equal opportunities, diversity and pay transparency. The Group identifies needed actions by analysing customer and user feedback and insights from supplier surveys under the Supplier Due Diligence process and by reviewing market best practices. In 2024 the Group received no reports of severe human rights issues or incidents connected to its upstream or downstream value chain.

Reference: page 146

The Group has not yet established specific targets related to its relationships with value chain workers. In 2025, an analysis will be carried out to define measurable sustainability targets. Findings from the 2024 double materiality assessment, which gathered insights on current practices and key sustainability challenges affecting value chain workers, were incorporated into the final materiality report and will be used in the process of defining the Group's sustainability goals, planned for 2025.

Reference: page 154

The Group does not identify consumers under ESRS but identifies end-users: employers and HR consulting agencies (customers), employees of corporate HR departments and HR consulting agencies, and job seekers. All Group companies have detailed terms and conditions of service setting out rules for accessing and using its products, platforms and applications, aligned with legal requirements, ethical standards, and the Group's Data Protection Policy and Information Security Policy. Users submit job postings via a dedicated form, allowing the Content Management Team to review advertisements for violations of platform content rules, service terms or laws; non-compliant advertisements are removed, and in 2024, 70 such cases were identified. This is governed by the Procedure for Handling Reports of Illegal or Non-compliant Content. Terms also cover purchasing, complaints, contract termination, and access to support. In all interactions the Group applies its Code of Ethics, including respect for human rights, personal data protection and privacy, and transparency. Internal documents incorporate Polish and EU consumer protection law, in particular the Consumer Rights Act, and are written in clear language following legal design principles.

Reference: page 154

The Group places great importance on open and transparent relationships with customers and end-users and has established structured processes to understand their needs and monitor its impact on user experience. It regularly gathers feedback through satisfaction surveys and user research, including interviews and both qualitative and quantitative studies, which support ongoing refinement of products and services. In 2024, users of the Pracuj.pl recruitment platform and the eRecruiter.pl recruitment management system submitted over 10,000 satisfaction surveys related to service quality. The Group also monitors user opinions across social media and other digital channels to identify needs and emerging trends early. End-users are actively involved in platform development and the testing of new features through beta testing and pilot implementations, with their input directly informing further development. Users access support through a hotline, live chat, social media and dedicated email addresses, with a trained support team. Advanced Customer Relationship Management (CRM) systems let the Group monitor notifications and reports, analyse needs and respond to service quality issues. Dedicated channels handle privacy, data access and system security concerns.

Reference: page 154

The Group ensures that customers have accessible and reliable ways to raise concerns, ask questions, or provide feedback, such as hotlines, dedicated online forms and email. These contact options are clearly communicated via the Group's websites, making it easy for users to seek support when needed. In addition, the Group provides a formal grievance mechanism enabling customers to report irregularities and cases of misconduct, described in detail in the ESRS G1 Business conduct section. The Group handles all submissions with care and transparency, ensuring prompt follow-up actions. These practices are central to building trust and ensuring that the Group's operations align with the highest ethical and regulatory standards.

Reference: page 155

The Group has not identified any material actual negative impacts affecting end-users. To prevent identified potential negative impacts it acts across five areas. For data privacy and security, it applies strict personal data protection procedures in full compliance with the Personal Data Protection Act and other privacy laws, with advanced security technologies and access control protocols. For monitoring satisfaction and customer relations, it uses surveys, interviews and Net Promoter Score (NPS) metrics to identify needs and enhance service quality. For transparency and user education, it provides straightforward information on terms of use and platform features plus educational resources such as user guides and manuals. For grievance and complaint mechanisms, users can raise concerns and report misconduct through dedicated channels designed for confidentiality and prompt response. For protection against advertisers' misconduct, all job postings are reviewed for legal and ethical compliance, and Robota introduced privacy-focused features allowing candidates to apply without disclosing sensitive data such as name or phone number. The Group also runs educational initiatives, including webinars, reports and career resources, for employers and job seekers.

Reference: page 157

The Group has not yet established specific targets related to its relationships with end-users. In 2025, an analysis will be carried out to define measurable sustainability targets.

Reference: page 161

Organisational culture has anchored the Group for nearly 25 years and is reflected in the Grupa Pracuj Code of Ethics and the Code of Ethics in Business Relationships. Responsibility for compliance lies with the Compliance Officer. Compliance policies and procedures include the Code of Ethics, Code of Ethics in Business Relations, Anti-Corruption Code, Non-Discrimination and Anti-Bullying Policy, Gift Policy, Instructions for Reporting Irregularities, and a Whistleblowing Procedure under the Whistleblower Protection Act. New employees and non-employee workers must complete e-learning on compliance during onboarding; in 2024, 94.44% of new hires at Grupa Pracuj S.A. and eRecruitment Solutions completed the training, run monthly on the LMS platform. The updated Code of Ethics was approved by 92.6% of employees and non-employee workers of the Polish companies in 2024. A confidential reporting channel available 24/7 at https://gp.zalezymi.pl/ allows anonymous or named reports, managed by the Compliance Officer with protection against retaliation.

Reference: page 164

To uphold compliance standards in its supply chain, Grupa Pracuj applies a Code of Ethics in Business Relationships, a compulsory element of supplier agreements that sets minimum standards covering legal compliance, counteracting corruption and conflicts of interest, a safe work environment, information and data security, fair competition, reporting irregularities, and care for the environment. In 2024 the Code was extended with environmental provisions and implemented at Grupa Pracuj, eRecruitment Solutions, softgarden, and Robota. A Supplier Due Diligence process was implemented at Grupa Pracuj in 2024 to screen suppliers against Group standards and legal requirements, mitigate business and tax risk, reduce engagement with unreliable contractors, and identify the supply chain. It currently applies to procurement projects exceeding PLN 100,000 annually and all technological purchases. Only suppliers passing screening continue in the tender process. A Procurement Guide and Supplier Cooperation Best Practices toolkit support staff. Rollout to eRecruitment Solutions is planned by end of 2025.

Reference: page 165

The Group does not accept corruption or bribery and takes active measures to counter it. Detailed rules are set in the Anti-Corruption Code, which defines benefits and corruption, forbidden actions, sectors susceptible to corruption, protocols for communicating with suppliers and customers, and tender participation rules. All employees and non-employee workers must comply with anti-corruption rules, refrain from offering or accepting benefits, resolve conflicts of interest, and contact the Compliance Team in case of doubt. The Gift Policy permits occasional gifts only where market value does not exceed PLN 200 gross, no return benefit is expected, no conflict of interest arises, and gifts are not given to public officials. The Anti-Corruption Code and Gift Policy are implemented at Grupa Pracuj S.A., eRecruitment Solutions, softgarden, and Robota. Anti-corruption clauses are included in standard contract templates. Compliance training covering anti-corruption topics for all Polish-company employees was scheduled for the first quarter of 2025.

Reference: page 166

In 2024, there were no incidents of corruption or bribery at any Group company. The number of confirmed incidents was zero. Separately, the reporting and whistleblowing system shows that in 2024 Grupa Pracuj S.A. received one report under the Whistleblowing Procedure; following an investigation, no irregularities were found. At softgarden, which has had a reporting instruction aligned with the German Whistleblower Protection Act (HinSchG) and a platform since 2023, no irregularities were reported in 2024. At Robota, where the whistleblowing procedure operates on a voluntary basis because Ukrainian law does not yet provide for whistleblower protection, no irregularities were reported in 2024 either.

Reference: page 167

In line with business ethics and the Act on Counteracting Excessive Delays in Commercial Transactions, the Group is committed to timely payments, particularly to small and medium-sized enterprises, but it does not have a formal policy specifically aimed at preventing payment delays and is currently analysing scenarios for implementing one. The Group generally adheres to standard payment terms and observes contractual deadlines; no companies categorise suppliers into predetermined groups. The average payment period at Grupa Pracuj and eRecruitment Solutions taken together is 15 days, with invoices for services and goods paid on average within 14 days, and 80% of invoices paid within the set time limit. At Robota, approximately 97% of payments are made within 30 days. At softgarden, the average payment period for publishers is 25 days, with services paid on average 17 days after invoice (about 5% of annual invoices) and the remainder within 23 days (about 16%). In 2024, no court proceedings were pending or initiated against Group companies over payment delays.