Grupa Pracuj S.A.

Reference: pages 85-89. Experience, competencies and appointment details for both boards are incorporated by reference to the "Corporate governance" section of the Management Board's Report (page 85).

Management Board (page 86): three members, all men (two aged 30-50, one over 50). It "is responsible for the management of the organisation, including the management of impacts, risks and opportunities and methods of controlling them." The sustainability area "reports directly to the President of the Management Board". Day-to-day reporting and coordination sit with the Corporate Communications Department, whose Head and an ESG Specialist lead the work (page 89).

Supervisory Board (pages 87-88): seven members, five independent (71%). The report gives the ratio of women to men as 40%. The Board oversees how impacts, risks and opportunities are managed and judges the adequacy and effectiveness of that process through the Audit Committee, which has three independent members. In 2025 it endorsed the Group strategy, including its sustainability part.

Employees and other value chain workers have no representation on either board (pages 86, 88). The Management Board reviewed and approved the updated double materiality assessment (page 89).

Reference: pages 89-90.

The President of the Management Board "is responsible for managing the Group's sustainability matters." The ESG team meets the President "at least once every two weeks" to review ongoing activities, with other Board members and key managers joining as needed (page 89).

The Audit Committee "plays a central role in supervising the Company's and Group's sustainability agenda". Reporting, material impacts, risks and opportunities, and project status are presented at its meetings, which are held "at least quarterly" (page 89).

Topics the Management Board, Supervisory Board and Audit Committee dealt with in 2025 (pages 89-90): workplace environment surveys, compensation, the pay gap, ESG-related risk management, whistleblowing and the Whistleblower Protection Act, the Compliance Policy, the assumptions behind the sustainability strategy, the Environmental and Climate Policy, decarbonization of the business, reporting requirements and standards, the update of the double materiality assessment, and the significant matters it identified.

Reference: pages 90-91, 116.

On 4 December 2025 the Supervisory Board passed a resolution adding sustainability criteria to the Management Board's compensation scheme. From 2026, "10% of the variable remuneration of Management Board members will be linked to the achievement of sustainability-related objectives."

Each year the Supervisory Board sets three to five ESG objectives with equal weights, covering environmental, social and governance matters, "in particular a reduction of greenhouse gas emissions". Each objective is scored 100% (achieved), 50% (partly achieved) or 0%, and the assessment is made by the end of May of the following year.

For the reporting period the report says: "In 2024 and 2025, remuneration at the Group was not tied to ESG objectives." Supervisory Board pay is not linked to sustainability, because of the body's supervisory role (page 90). The climate entry under E1 GOV-3 points back to this section (page 116).

Reference: page 91.

The statement on due diligence is a table that maps each core element of due diligence to the sections of the statement where it is covered:

• Embedding due diligence in governance, strategy and business model: ESRS 2 GOV-2, GOV-3 and SBM-3, plus E1 SBM-3 and S1 SBM-3.
• Engaging with affected stakeholders in all key steps: ESRS 2 GOV-2 and SBM-2, E1 SBM-2 and S1 SBM-2.
• Identifying and assessing adverse impacts: ESRS 2 IRO-1 and SBM-3.
• Taking actions to address those adverse impacts: the E1, S1 and G1 chapters.
• Tracking the effectiveness of these efforts and communicating: the E1, S1 and G1 chapters.

The section is a cross-reference table with no separate narrative. The supplier-side process it relies on is the Supplier Due Diligence process described under G1-2 (page 182).

Reference: pages 91-92.

The report names the main risks to sustainability reporting as the adequacy, accuracy, completeness and comparability of data, which may arise from the "dispersion of data sources, use of estimates, human error, regulatory changes, non-uniform reporting practices across the Group's entities".

Controls described (page 91):

• The ESG Team coordinates the process and the double materiality assessment, aligns definitions across entities, and collects and verifies data, "performing double verification of the Group's carbon footprint calculations and voluntarily calculating the carbon footprint on a semi-annual basis".
• Business owners are responsible for the quality of the datapoints in their area, using data from HR and payroll systems where possible.
• The statement is signed by the Management Board, reviewed by the Supervisory Board and approved by the General Meeting; reporting is a standing Audit Committee item (page 92).

The report is candid about maturity: "The system will be gradually expanded and formalised in relation to sustainability reporting", and the Group plans to write internal guidelines for the statement during the next calendar year (page 92).

Reference: pages 92-96.

The Group describes itself as "a European HR Technology platform, supporting companies in talent recruitment and management processes", offered as recruitment platforms and recruitment management systems on a SaaS model, in Poland (since 2000), Ukraine (since 2006) and Germany (since 2022) (page 92).

Strategy (pages 93-95): the Grupa Pracuj 2030 Strategy includes a sustainable development strategy on three pillars: environment, society and governance. It stresses Scope 3 emissions, the largest part of the footprint, and sourcing 100% of electricity from renewable sources.

Value chain (pages 95-96): upstream covers energy, network infrastructure and IT equipment suppliers in three tiers; own operations cover platform and system development plus sales and support functions; downstream covers customers and job seekers. Employee benefits expense was PLN 286.6 million, 35.3% of operating expenses (page 96). Business model detail is incorporated by reference (page 85).

Reference: pages 97-98 (own workforce and end-user detail on pages 142-144 and 162-163).

The Group says it keeps "open, two-way communication with each identified stakeholder group". Key stakeholders were identified in the 2024 double materiality assessment and did not change in 2025; each was assessed on the scale of the Group's impact on it and its impact on the Group (page 97).

There are eight groups: employees, customers, consumers and end-users, investors, suppliers, potential employees, media and financial institutions. The Management Board hears their views through customer and employee satisfaction surveys, platform user feedback, whistleblowing reports, direct meetings with investors, customers and partners, and public opinion monitoring (page 97). Page 98 gives each group's channels, topics and purpose.

For the own workforce, elected employee representatives act at Grupa Pracuj S.A. and eRecruitment Solutions. The 2025 work environment survey had participation of 94.0% in Poland, 95.0% in Ukraine and 90.0% in Germany (pages 142, 144).

Reference: pages 99-104.

The 2025 update of the double materiality assessment left four material topical standards: E1 Climate change, S1 Own workforce, S4 Consumers and end-users and G1 Business conduct (page 86). Workers in the value chain (S2) were assessed as immaterial (pages 99, 107). Adding Kadromierz sp. z o.o. produced one entity-specific material impact, an actual positive S4 impact on occupational safety and health (page 106).

The summary table (pages 100-104) gives each item's stakeholders, value chain location and time horizon. Unless stated otherwise they are "relevant across all analysed time horizons" (page 99). Counting the rows by the type label printed on each gives 43 items (a count made for this site; the report states no total):

• E1: 1 negative impact, 2 positive impacts, 2 risks
• S1: 1 negative impact, 9 positive impacts, 2 risks, 2 opportunities
• S4: 2 negative impacts, 5 positive impacts, 6 risks, 3 opportunities
• G1: 1 negative impact, 3 positive impacts, 4 risks

Risks and opportunities were consolidated in the update, so there are fewer than in 2024 (page 99).

Reference: pages 105-110 (climate detail on pages 119-127; business conduct on page 175).

The Group ran its first double materiality assessment in 2024 and updated it in the second half of 2025, using qualitative and quantitative data from internal and external stakeholders and the management of Group companies. The six stages were analysis of operations, reassessment of impacts, determination of material impacts, review of risks, identification of opportunities and formal approval by the Management Board (pages 105-110).

Impacts (pages 106-108): reviewed in workshops with internal experts and the advisory firm MATERIALITY sp. z o.o., then tested in interviews with employee and HR representatives (S1) and supplier and customer representatives (S2). They are scored 1-5 on scale, scope, irremediable character (negative impacts only) and likelihood. Severity is the mean of scale, scope and irremediability, "multiplied by the likelihood", then increased by the severity component. Actual impacts take a likelihood of 5. Impacts scoring above 2.5 are material.

Risks (pages 108-109): identified jointly by the ESG and risk management teams and rated under the Risk Management Policy; critical, high and medium risks are material.

Opportunities (pages 109-110): scored on magnitude and likelihood, with the same 2.5 cut-off.

Reference: pages 111-115 (also 85-86).

The company prints an IRO-2 compliance table (pages 111-112) listing each disclosure requirement with the section where it appears. It covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and, for the four material standards:

• E1: GOV-3, E1-1, SBM-3, IRO-1 and E1-2 to E1-8. E1-9 carries the entry "The Group omits the disclosure requirements in this standard, as permitted by Appendix C to ESRS 1."
• S1: SBM-2, SBM-3, S1-1 to S1-11, S1-13, S1-15, S1-16 and S1-17. S1-12 and S1-14 are not listed.
• S4: SBM-2, SBM-3 and S4-1 to S4-5.
• G1: GOV-1, IRO-1, G1-1, G1-2, G1-3, G1-4 and G1-6. G1-5 is not listed.

Appendix B datapoints (pages 113-115) are mapped to sections, with "Not material" entered for the E2, E3, E4, E5, S2 and S3 datapoints among others. Disclosures incorporated by reference to the Management Board's Report are tabulated on page 85, and the Appendix C phase-in is used for anticipated financial effects (page 86).

Reference: page 127 (also 122, 125).

The Group has no climate transition plan. E1-1 states: "The Group does not currently plan to define a long-term transition plan for climate change mitigation extending to 2050." It gives the reason that changes are "rapidly unfolding" and that reliably forecasting "the development of HR technologies and their impact on the Group's operations over a long-term horizon up to 2050" is hard. Shorter planning cycles give "greater strategic flexibility".

The Group says it "supports the objectives of the Paris Agreement, including the pursuit of climate neutrality by 2050, and has defined aligned targets and actions aimed at reducing Scope 1 and Scope 2 GHG emissions" (page 127). The 42% Scope 1 and 2 target and the actions sit under E1-4 and E1-3 (pages 128-129). The resilience section says the Group "has not formally adopted a low-carbon transition plan" and its actions "are operational and incremental in nature" (page 125).

The strategy table on page 94 lists "Development of a transition plan towards climate neutrality by 2050". The text extraction interleaves that table's columns, so which period the item belongs to is not clear, and it sits awkwardly with page 127.

Reference: pages 119-127.

Back-filled from ESRS E1 IRO-1, where this content is disclosed in the FY2025 report (pages 119-127). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk types (page 119): physical (acute: floods, heatwaves, storms; chronic: rising temperatures, water scarcity) and transition (policy and legal, mainly higher energy prices). Coverage is offices in 17 cities in Poland, Ukraine and Germany, EEA data centers and cloud services.

Scenario (pages 119-120): one scenario, "RCP 8.5", using Klimada 2.0 climate projections for Poland from the Institute of Environmental Protection - National Research Institute, compared with 2011-2020, with a horizon to 2050. Sites outside Poland were assessed from public hazard databases (page 121). The Group "did not consider a 1.5°C global warming scenario", saying that threshold has already been exceeded several times (page 120).

Method and limits (pages 120-121): qualitative and expert-based; location is the only differentiating factor; no quantified likelihood and no financial modeling; the text states no global average temperature projection. Transition risks were assessed for the Group as a whole, not by asset.

Outcome (page 122): heatwave and drought exposure in Poznań, Wrocław and Bydgoszcz; more precipitation in Bielsko-Biała and Kraków; river flood risk in Kyiv, Warsaw, Kraków, Wrocław and Frankfurt am Main; coastal and flash flood risk in Gdańsk.

Reference: pages 123-127 (also 116).

Back-filled from ESRS E1 IRO-1 and the climate resilience analysis, where this content is disclosed in the FY2025 report (pages 116, 123-127). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group calls its 2025 resilience analysis "the preliminary first step towards a comprehensive assessment". It rests on expert qualitative judgment, with no scoring scale and no quantified exposure or financial loss (pages 123-124).

Results (page 125): operations show "relatively high resilience to the direct physical impacts of climate change" because there is no manufacturing and sites are dispersed. Key vulnerabilities are the continuity of office and IT infrastructure during heatwaves, local flooding and power outages. Identified physical risks "do not threaten the stability of the Group's business model", but the model is "materially exposed to transition risks".

Uncertainty (page 124): limited consistent location data, no data to estimate the likelihood or size of losses, and dependence on external data centers and cloud providers whose resilience the Group cannot see.

Capacity to adjust (page 125): the Group points to its ability to "flexibly adapt its operating models, select appropriate suppliers and implement lower-carbon technological solutions". It plans to deepen the analysis and build it into the risk management framework (page 123).

Reference: pages 127-128.

In 2025 the Group developed an Environmental and Climate Policy, "seen as a key element of the implementation of its sustainable development strategy in the environmental area". It has been adopted across all Group companies except Kadromierz, where adoption is planned for the first half of 2026 (page 127).

The Policy commits the Group to decarbonizing its operations (Scope 1 and 2, including fleet modernization and more renewable energy), supplier evaluation standards that take decarbonization targets and product carbon footprints into account, managing climate-related risks, energy efficiency in IT, offices and fleet, building environmental awareness, complying with environmental rules, and monitoring and reporting progress. It covers direct activities and "selected elements of its value chain" (page 127).

The Management Board has declared support for the Policy and resources for it, and company management teams put it into practice (page 128). It is public on the Group's website, and the Group has committed to annual sustainability statements that report progress (page 128).

Reference: pages 128-129.

Actions in 2025 (page 128):

• developed a decarbonization plan for Scope 1 and 2 emissions up to 2030 (set out under E1-4)
• carried out a climate risk assessment using climate scenarios
• implemented supplier evaluation standards covering the carbon footprint of products and services and environmental compliance
• adopted energy standards, including energy-efficient IT equipment and energy criteria in procurement
• ran awareness initiatives for employees and non-employee personnel

Planned actions (page 129): reducing Scope 1 and 2 emissions through "gradual electrification of the vehicle fleet", energy efficiency in leased offices and IT procurement, and "100% renewable electricity in the consumption mix by 2030"; replacing secondary Scope 3 data with supplier data; covering more suppliers with the Supplier Due Diligence process; and annual review of the policy and targets.

The renewable share of energy rose from 8.4% to 14.2%, through guarantees of origin (page 130). The climate chapter gives no capital or operating expenditure amounts for these actions. It says the Management Board is "ensuring the allocation of appropriate resources" (page 128).

Reference: page 129.

The Group targets a 42% reduction in Scope 1 and Scope 2 emissions by 2030 against a 2024 base year. The report says the target "has been defined on a net basis", meaning it would be met through direct reductions and "measures supporting emissions balancing, such as the use of certified emission reduction units (ERUs)", with the role of each mechanism to be monitored and reported.

The target "has been calculated in accordance with the standards of the Science Based Targets initiative (SBTi)". Emissions use the market-based method under the GHG Protocol and are "not subject to regulated emissions trading schemes". Progress is tracked through automated energy data collection, annual disclosure in the sustainability statement, and adjustment of processes based on the data.

The report sets no Scope 3 target, although Scope 3 is 92.7% of the footprint (page 133).

Reference: page 130.

Total energy use in 2025 was 2,649.4 MWh (2024: 2,665.5 MWh, down 0.6%). Fossil sources supplied 2,273.4 MWh (85.8%) and renewable sources 376.0 MWh (14.2%). Purchased electricity and heat are most of the total, with the rest from fuels.

Coal, nuclear and self-generated renewable energy are zero. The 67.3% rise in renewable energy "was driven by an increased share of electricity sourced from renewables, based on renewable energy certificates (guarantees of origin)". The Group "does not use energy from nuclear sources and does not generate renewable energy internally."

Reference: pages 130-135.

Total 2025 emissions were 9,089.7 tCO2eq market-based (2024: 9,304.5, down 2.3%) and 9,215.6 location-based (9,332.5). Scope 3 is 92.7% of the market-based total, Scope 2 4.3% and Scope 1 3.0% (page 133). Scope 3 is 8,423.9 tCO2eq (page 134). Intensity is 11.2 tCO2eq per PLN million of net revenue market-based, against 12.1 (page 135).

Method (pages 130-133): GHG Protocol, 2024 base year, operational control. Categories 8, 9, 10, 12 and 14 were not calculated, with reasons given. Biogenic emissions of 16.4 tCO2eq are reported separately (page 135). Page 134 gives Scope 1 and 2 market-based emissions as 666.8 tCO2eq, but the table figures sum to 665.8.

Reference: page 135 (index entry on page 111).

The Group reports a nil return: "In 2025, the Group did not implement any GHG removals and storage projects in its own operations or the upstream and downstream value chain." E1-7 is listed in the company's ESRS content index (page 111), and the Appendix B datapoint for removals and carbon credits is mapped to E1-7 (page 113).

The chapter reports no carbon credit purchases for 2025. The 2030 Scope 1 and 2 target is set on a net basis and may use certified emission reduction units (ERUs) (page 129).

Reference: page 135 (index entry on page 111).

The Group reports a nil return: "With reference to disclosures prescribed by paragraph 62 of ESRS E1-8, the Group does not apply internal carbon pricing schemes." E1-8 is listed in the company's ESRS content index under the title "Determination of internal carbon pricing" (page 111).

The climate risk analysis reaches budgeting only indirectly: its results "are indirectly reflected in budget planning, mainly through potential impact on the costs of energy, office maintenance and business continuity" (page 125).

Reference: pages 147-151.

The Group's workforce policies rest on "the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the conventions of the International Labour Organization (ILO)" (page 147). Named documents: Code of Ethics, Non-Discrimination and Anti-Bullying Policy, Diversity Policy, work rules, remuneration rules, social benefit fund rules, Personal Data Protection Policy, the whistleblowing procedure and e-nform reporting system, and recruitment, onboarding, offboarding and career development rules. Management Boards of Group companies own them and HR departments put them into practice.

• Code of Ethics (pages 147-148): prohibits child labor, forced labor, human trafficking and modern slavery, and binds all staff including non-employees.
• Non-Discrimination and Anti-Bullying Policy (pages 148-149): protects against bullying and discrimination, including sexual harassment.
• Diversity Policy (pages 150-151): equal opportunity in hiring, diversity training and monitoring of goals. Grupa Pracuj S.A. is a Diversity Charter signatory.
• Health and safety (pages 149-150): work is office-based and the Group's activities "are not associated with work performed in hazardous conditions"; an OHS management system is in place across the Group.
• Work rules and remuneration rules cover employees only and exist at Grupa Pracuj S.A., eRecruitment Solutions and Robota (page 149).

Reference: pages 152-153.

To address actual negative impacts on the workforce the Group lists these actions (page 152): flexible work (hybrid model and flexible hours), part-time work where the law allows, regular meetings between employees and the Leadership Team, annual work environment surveys, review of remuneration policies, clear pay and raise principles based on market benchmarks, equal access to training for all genders, and a formal training-access procedure at Robota International TOV.

Effectiveness is monitored through yearly surveys, open feedback channels, monitoring of reported misconduct through the compliance system, and annual non-financial reporting to the Management Board and investors (pages 152-153).

The Group says its sales targets are set with teams "to ensure they are realistic and aligned with team capacities", to avoid pressure and burnout (page 153). Resources named: HR teams in every company, the ESG team, the OHS Committee, spending on training and psychological support, and the policy set and whistleblowing channels (page 153). Actions for each risk and opportunity are in the table on page 146.

Reference: pages 153-154, 94, 161.

The Group says it "defined short-, medium- and long-term targets" for its own workforce in 2025 and points to the ESRS 2 strategy table (page 153). Items in the social pillar of that table (page 94) are: increasing "the share of women in top management roles to 30%" and harmonizing pay practices and DEI training by 2027; and for 2030 pay equity, "closing the adjusted gender pay gap (<5%)", plus career progression pathways across all teams. The table's columns are interleaved in the text, so the exact period of each item is not always clear.

The adjusted gender pay gap was 2% in 2025, "within the range consistent with the Group's strategic target, according to which the adjusted pay gap should not exceed 5% in absolute terms" (page 161). Women are already 49% of top management (page 157).

For 2026 the Group plans talent management tools, performance and leadership potential assessments, succession planning, work environment surveys in Poland, Germany and Ukraine, and a standardized onboarding process (pages 153-154).

Reference: pages 154-156.

No employees are recorded as other gender or not disclosed. Non-guaranteed hours employees were 0 in 2025 (1 in 2024). Departures were 155 (148 in 2024), new hires 149 (154) and turnover 14% (15%) (page 156). The report attributes the increase in head count to the addition of Kadromierz sp. z o.o. and growth in the segments, and describes the structure as stable (page 156).

Reference: pages 156-157 (also 145).

At 31 December 2025 the own workforce included 156 non-employees (2024: 132, up 18.2%): 36 women and 120 men. 146 worked under business-to-business contracts (121 in 2024), 7 under civil-law contracts (6) and 3 were provided by temporary employment agencies (5). B2B contractors are 93.6% of the group and the report says the rise "reflects current operational needs and demand for flexible workforce support across organisational units" (page 157). The figures are head counts.

Reference: page 157.

The report states: "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.

Social dialogue is otherwise through the annual elections of representatives, minuted meetings and the OHS Committee described under SBM-2 (pages 142-143). At the other Group companies employees raise feedback through general communication channels (pages 142-143).

Reference: pages 157-158.

Top management means managers and directors. At 31 December 2025 it had 99 women (49%) and 104 men (51%), against 96 women and 98 men in 2024 with the same 49/51 split. No one is recorded as other gender or not disclosed.

The report calls the age structure "broadly unchanged" and attributes the changes to operational factors (page 158).

Reference: page 158.

"In 2025 and 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 share of employees paid below the adequate wage was 0.0%.

The report does not give the benchmark amounts by country.

Reference: page 158.

All employees, meaning people with employment contracts, were covered in 2025 by social protection through public programs in the countries where Group companies operate. Grupa Pracuj S.A. also runs a Company Social Benefits Fund from which employees can apply for non-wage support in hardship, such as serious illness, accidents or the death of a close relative.

Robota International TOV continued its support and reintegration program for war veterans, with legal advice, psychological counselling and financial assistance, awareness training for teams, and company-wide training titled "How to communicate during wartime". It also continues salary payments and adds financial help for employees still serving in the armed forces.

Reference: pages 158-160.

The Group follows a 70/20/10 learning model: 70% from experience, 20% from others and 10% from formal activities such as training, conferences, courses, coaching and mentoring (page 158). It runs annual career development sessions based on 270- and 360-degree evaluations (page 159).

In 2024 the review shares were 84% (women) and 77% (men) and average training hours were 31 and 34 (page 159). The report links the lower hours to limited comparability of data and to the war in Ukraine, which "constrained the delivery of some planned development initiatives" (page 160).

Reference: page 160.

All employees in Poland, Ukraine and Germany are entitled to family-related leave (100% of women and 100% of men). The share of entitled employees who took it in 2025 was 26% of women and 16% of men, up from 12% and 6% in 2024.

The report attributes the rise mainly to "growing awareness of available entitlements" supported by internal communication campaigns, to a culture in which taking parental and caregiving leave is "viewed as a natural element of career development", and possibly to the workforce's age profile (page 160).

Reference: pages 160-161.

The unadjusted gender pay gap was 30% in 2025 (32% in 2024). The Group says it is shaped by the employment structure: about one-third of the workforce are IT experts, a mostly male group with higher pay, and top management posts are mostly held by men. The calculation covers the whole workforce, including people on long sickness absence or parental leave whose pay is not indexed (page 160).

In 2025 the Group built a method for an adjusted gap that compares people in comparable job categories and grades. The adjusted gap was 2%, against a strategic target of no more than 5% in absolute terms (page 161).

The ratio of the highest-paid individual's total annual remuneration to the median for other employees was 17 (16 in 2024) (page 161).

Reference: page 161.

The Group monitors complaints raised on employee matters. In 2025 it recorded one confirmed case of workplace misconduct involving discrimination, at softgarden e-recruiting GmbH, and dismissed the person responsible. No discrimination cases were identified at the other Group companies. Fines, penalties and compensation for damages from the incidents and complaints disclosed came to PLN 0.

The report adds that no serious incidents were reported in 2025 that would breach 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.

Reference: pages 169-170 (also 162, 165).

The Group says it has no consumers as the ESRS define them; its end-users are employers and HR consulting agencies, their HR staff, and job seekers, plus employees of Kadromierz customers who use its time and attendance system (page 162).

Every company has terms and conditions of service covering access to and use of platforms, purchasing, complaints and contract termination, written to meet legal requirements and the Data Protection and Information Security policies (page 169). Job postings are reviewed for breaches of content rules or the law; 41 non-compliant postings were removed in 2025 (page 169). On Grupa Pracuj's e-commerce channel, an AI-based tool screens postings for discriminatory wording, irrelevant personal requirements and unjustified requests for criminal record certificates (page 169).

For AI, the Group adopted a Code of Ethics for AI Development in 2025, with principles including human oversight, fairness and non-discrimination, transparency and data protection. Its formal implementation is planned for 2026 at Grupa Pracuj S.A. and eRecruitment Solutions, then other companies (pages 169-170).

Reference: pages 172-174.

The Group says it "has not identified any material actual negative impacts affecting end-users". For the potential negative impacts (misleading or false job offers, and personal data leakage or unlawful use) it describes these measures (pages 172-173):

• Data privacy and security: access controls and monitoring of IT systems, vulnerability identification, and incident procedures covering identification, analysis, classification, remedy and prevention of recurrence.
• Satisfaction: surveys, interviews and Net Promoter Score tracking.
• Transparency: terms of use, user guides and manuals.
• Complaints: confidential channels with prompt response.
• Job posting review: every posting is checked against legal and ethical standards.

Education covers customers (webinars, labor market reports, e-books) and job seekers (CV and interview workshops, career guides, university partnerships) (pages 173-174). Management methods for each material risk and opportunity are in the table on pages 164-165. The report gives no outcome metrics for these actions beyond the survey and posting-removal counts under S4-1 and S4-2.

Reference: pages 174, 94-95.

The Group says it "defined targets related to its relationships with end-users under the sustainable development strategy" and refers to the ESRS 2 strategy table (page 174). The only end-user item in the social pillar of that table is "Development of a consistent approach to surveying customer satisfaction to monitor and understand diverse expectations and experiences" (page 94). The governance pillar covers data protection and information security, the AI Act, supplier due diligence and Disaster Recovery procedures (page 95).

None of these carries a numeric end-user target; the one numeric figure in the governance pillar is supplier coverage (90% of eligible suppliers by 2030). The table's columns are interleaved in the text extraction, so the period for each item is not always clear.

Reference: pages 175-181.

Corporate culture "has been a cornerstone of the Group's operations for over 25 years" and is set out in the Code of Ethics and the Code of Ethics in Business Relationships (page 175). An 11-member Leadership Team meets monthly and supports the Management Board (page 176). Six values: customer in focus; courage to act and learn from mistakes; responsibility for commitments, actions and outcomes; agility in learning and adapting; respect for diversity; positive vibe at work (page 177).

The Compliance Officer at Grupa Pracuj S.A. runs compliance risk mapping and sets standards for the Group. A compliance risk assessment covered four entities in early 2025 (page 178). The Code of Ethics, Anti-Corruption Code, Gift Policy, Non-Discrimination and Anti-Bullying Policy and whistleblowing documents apply at Grupa Pracuj, eRecruitment, softgarden and Robota; a Compliance Policy was adopted at the first two in 2025 and a Conflict of Interest Management Policy in January 2026 (pages 178-181).

Onboarding compliance training was completed by 98.7% of new staff in 2025 and ethics training had an 86% completion rate (pages 179-180). At Robota and softgarden "no dedicated training has yet been conducted specifically for management staff in relation to the Anti-Corruption Code" (page 181).

Reference: pages 95, 178, 182.

Back-filled from the governance pillar of the ESRS 2 strategy table and the G1 chapter, where business conduct targets sit under MDR-T rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

The governance pillar of the table sets one numeric end-point, as the Group's ambition for 2030: "Value chain security: covering at least 90% of eligible suppliers with the Supplier Due Diligence process". The same pillar lists implementing the Supplier Due Diligence process across all Group companies, Group-wide regular compliance training standards including Code of Ethics training, implementing the AI Act, and updating risk management procedures to cover climate-related risks (page 95). Its columns are interleaved in the text, so the period for each item is not always clear.

Progress and tracking: the process runs at Grupa Pracuj S.A. and eRecruitment Solutions, with rollout to softgarden and Robota planned by the end of 2027 (page 182). The G1 chapter sets compliance objectives for the coming year, including AI Act compliance and a Human Rights Policy (page 178).

Reference: pages 185, 183-184.

The Group reports: "In 2025, there were no incidents of corruption or bribery at any Group company." No fines or convictions for corruption or bribery are mentioned in the G1 chapter.

Related facts: Grupa Pracuj S.A. had two whistleblowing reports in 2025, which led to one combined investigation with no irregularities found; softgarden had no reports and Robota recorded three, all resolved (page 184). An independent external audit of fraud, corruption and conflict of interest risks was carried out in 2025 (page 184).

Reference: page 185.

The Group is committed to timely payment, particularly for small and medium-sized enterprises, "but it does not have a formal policy specifically aimed at preventing payment delays". It is analyzing options for one. No company groups suppliers into predetermined categories.

• Grupa Pracuj and eRecruitment Solutions together: average 16 days to settle payables; invoices for services and goods settled in an average of 14 days.
• Kadromierz: standard payment term 7 days, weighted average 6 days.
• Polish entities: 82% of payables settled by the agreed deadline.
• Robota: about 97% of payments within 30 days; 96% of payables settled on time.
• softgarden: 64% of invoices (recruitment service providers) on a 30-day average term; about 10% on a 13-day average; the remaining 26% on a 19-day average.

No court proceedings were pending or started over payment delays in 2025.