Guerbet Sa
Material Topics
Sustainability statement, in full
The complete text of Guerbet Sa’s FY2025 sustainability statement is held here – 103 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
The role of the administrative, management and supervisory bodies
Reference: page 116; see also chapter 2 (page 39).
For the CSRD, Guerbet treats the Board of Directors and its specialized Committees as its administrative, management and supervisory bodies. Governance rests on "two main bodies: the Board of Directors and the Executive Committee" (page 116).
At December 31, 2025 the Board had nine members, one of them a Director representing the employees, and 38% of Directors were independent (chapter 2, page 39). CSR training was offered to Directors in 2025 (pages 39, 117).
Division of roles (page 117): the Audit Committee reviews the material matters and IROs, which are updated annually or after a significant event; the Board validates the double materiality assessment; the Executive Committee and the Board approve the objectives set for the IROs. Climate results go to the Executive Committee and to the Ethics, Governance and CSR Committee (page 130).
Operationally, the HSE & CSR Department reports to the Technical Operations Director and the Human Resources Director, both Executive Committee members. A CSR network was created in each department in 2025 (page 117).
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reference: page 117 (section 5.1.2.2).
Guerbet states that its governance bodies "ensure regular and structured monitoring of CSR information" (page 117). The items it lists:
- progress on roadmaps, in particular water and decarbonization trajectories
- review of the material matters and IROs by the Audit Committee, with the assessment updated annually or if there is a significant event
- validation by the Board of Directors under the double materiality assessment methodology
- a review of the financial and strategic arrangements tied to the IROs at least twice a year, in line with the annual budgets and Medium-Term Plans
Other flows to the governance bodies: the carbon trajectory is updated and presented annually to the General Manager, the Technical Operations Director and the Ethics, Governance and CSR Committee (page 130), and a report on the whistleblowing system goes to the Ethics Committee and the Board annually (page 118). The section does not say how many times the Board met on sustainability topics or list the specific IROs discussed.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: page 117 (section 5.1.2.3); see also pages 137, 139.
The variable compensation of the Chief Executive Officer and of the Executive Committee "includes CSR objectives, monitored monthly, defined by the relevant Committees" (page 117).
Mechanisms listed for other employees (page 117):
- individual variable compensation linked to carbon, water and safety objectives for managers, and a specific CSR objective for certain key contributors
- a profit-sharing agreement on safety objectives for employees in France
- share allocation plans linked to carbon objectives for certain employees and managers
- an awards system built on the behavioral principles
Climate-specific detail: the CEO, the Technical Operations Director and the Director of Purchasing hold individual objectives tied to the Group's climate performance, and carbon criteria sit in the bonus share plan (page 137). Reduced relative energy consumption at industrial sites is a criterion in the variable compensation of the CEO and employees concerned (page 138), and the water target feeds the variable compensation of the employees concerned (page 145). The section gives no weighting for CSR criteria.
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 124 (section 5.1.5).
Guerbet says it "has implemented due diligence processes to identify, assess and remedy impacts related to its activities". Rather than a single narrative, the section is a map from the five elements of due diligence to the places in the statement where each is covered (page 124):
- integration into governance, strategy and business model: 5.1.2 CSR governance and 5.1.3 core policies
- engagement with stakeholders: 5.1.2, 5.1.3, 5.1.4 and the policies and dialogue processes in each thematic chapter
- identifying and assessing negative impacts: 5.1.6 impacts, risks and opportunities
- actions on negative impacts: the "Management of negative impacts and channels for raising concerns" paragraphs of S1 to S4, plus the whistleblowing system (5.1.3.2)
- tracking effectiveness and communicating: the "Metrics and targets" paragraphs of E1, E2, E3, E5, S1 to S4 and G1
The Group's due diligence reference points are the UN Guiding Principles and the ILO fundamental conventions (pages 152, 163).
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: page 114 (section 5.1.1); pages 14-15 and 125.
Guerbet describes its offer as "a complete range of contrast media, medical devices, and digital and AI solutions for Diagnostic Imaging and Interventional Radiology" (page 4). Its business lines are Diagnostic Imaging, Interventional Radiology and Digital & AI (page 15).
The strategic roadmap that the CSR strategy supports has four priorities (page 114): strengthen leadership in MRI; develop Interventional Radiology around Lipiodol; enhance operational excellence; explore new growth drivers.
Scale: products marketed in 114 countries, 2,746 employees at year end, 8 production plants and 4 R&D centers, and 9.6% of revenue spent on R&D (pages 4, 14, 169). Consolidated revenue for 2025 was EUR 786,443 thousand (page 209).
Value chain (page 125): upstream means suppliers, carriers, subcontractors and innovation partners; own operations means activities under direct control; downstream runs up to the end of life of the products. The report points to chapter 1 for the full business model and to 1.3.2 for markets (page 116).
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 121-123 (section 5.1.4).
Guerbet says it "maintains an open and transparent dialogue with its stakeholders" and takes expectations into account "through CSR questionnaires, sector reports and benchmarks" (pages 121, 123). A table on page 123 sets out how it engages each group:
- employees: manager reviews, induction, the Guerbet Inside social network
- staff representatives: social dialogue between social partners and Management
- healthcare stakeholders and patients: conferences, symposia, expert committees, surveys
- Board of Directors: regular dialogue with Management, including an Employee Director and a staff representative
- shareholders, institutions, investors and rating agencies, professional societies (LEEM, France Chimie, G5 Santé, MedTech In France, French Healthcare)
- local communities, partners and innovation partners
Customer expectations are also gathered through CSR questionnaires received in tenders and an internal survey (pages 132, 134). Employee views are collected in the Guerbet Listens survey, run since 2022 (page 151). External ratings cited are EthiFinance Gold level, EcoVadis Silver, CDP Climate B and Water B, and CAHPP A++ (pages 121-122). The section does not say how stakeholder views changed the strategy or the IRO list.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: pages 125-127; IRO summary tables on pages 134, 142, 144, 146, 150, 163, 165, 167 and 172.
The material IROs are presented as a table at the head of each topical chapter: E1 (page 134), E2 (page 142), E3 (page 144), E5 (page 146), S1 (page 150), S2 (page 163), S3 (page 165), S4 (page 167) and G1 (page 172). Each row gives the IRO type, scope (upstream, own operations, downstream) and time horizon. The nine tables hold 30 rows; seven are marked both as a risk and as a negative impact, which makes 37 typed IROs.
What changed in the 2025 update (page 126): six issues material in 2024 are now non-material: patient safety in clinical trials, personal data, substances of concern, microplastics, pollution of living organisms, and biodiversity and ecosystems. The update identified two new items: an opportunity for market share gain and investor attraction through the climate transition, and a positive impact from reducing the health system's environmental footprint.
On financial effects, the report says: "The current and expected financial effects of impacts, risks and opportunities are not reported this year" (page 127). It adds that the policies and actions presented "attest to the strategy and resilience of the Group's business model" (page 127). Ratings are gross, with a net rating that includes existing controls (page 127).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 125-127 (section 5.1.6.1); climate risk identification on page 133.
Method: in 2024 the HSE and CSR team ran the double materiality assessment with an external firm; in 2025 the update used a sector benchmark and internal analysis (page 125). IROs were identified from "the 37 challenges defined in the CSRD standards" plus sector-specific ones such as product quality, product compliance and patient safety (page 125). Time horizons: short term 1-3 years, medium term 3-5, long term 5 or more (page 125).
Impact materiality scores characterization, probability and severity (extent, irreversibility, magnitude). Pre-rating used ENCORE and SHDB data and internal studies (page 125). Financial materiality uses the Group's risk process: probability, financial risk, HSE importance, reputational, regulatory and organizational scale (page 126). Ratings are gross, ignoring existing controls (page 125).
Governance: the HSE and CSR team updates the assessment annually, the Executive Committee and the Board review it, and the Statutory Auditors audit the stages (page 125). Section 5.1.6.3 says the main CSR risks were integrated into the overall risk management process (page 127). Climate-specific screening is on page 133.
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: page 127 (section 5.1.6.4); content index on pages 185-189; Appendix B datapoint table on pages 190-191.
Section 5.1.6.4 points to section 5.6.6 for the list of requirements covered: "Publications targeted by IRO-2, see 5.6.6" (page 127). That section is titled "IRO-2 - Disclosure requirements in ESRS covered by the undertaking's sustainability statement" and is a table of requirement, section of the statement and page (pages 185-189), grouped as ESRS 2, E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1.
Index entries marked as not applicable: E2-5, the E4 requirements and G1-5 ("N/A, non-material"); E5-6 and S1-7 ("N/A, transitional provision"). The index does not list GOV-5 or E3-5. It lists E2-6 against "5.2.2.2 Actions". It labels the two E3 water datapoints "E2-4". It lists requirements whose body text gives a nil figure or no target, such as E1-7, E1-8 and E5-3.
The Appendix B table maps SFDR, Pillar 3, Benchmark Regulation and Climate Law datapoints to pages (pages 190-191); several are marked "Not relevant to Guerbet" or "Transitional provision".
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: page 130 (section 5.2.1.2); pages 130-132 and 138.
Guerbet has a transition strategy, not yet a transition plan under the CSRD: it "has developed a transition strategy and plans to formalize a transition plan, within the meaning of the CSRD, within one to three years" (page 130).
The strategy rests on SBTi targets. Since 2021 the Group has been committed to a "Well-below 2°C" trajectory by 2032, which "has been validated by an external body, the SBTi". Targets cover 100% of Scope 1 and 2 and 85% of Scope 3 (purchased goods and services, fuel and energy activities, upstream transport, waste, downstream routing). The reference year is 2021 (pages 130-132).
Resources: planned capital expenditure over five years to support the Scope 1 and 2 strategy is EUR 15.3 million, updated annually (page 132). On locked-in emissions: "Locked-in emissions from the consumption of assets have not been treated separately from other emissions" (page 132).
Oversight: the carbon trajectory is presented annually to the General Manager, the Technical Operations Director and the Ethics, Governance and CSR Committee (page 130). The Appendix B table marks the Paris-aligned Benchmark exclusion datapoint "Not relevant to Guerbet: Guerbet has SBTi targets" (page 190).
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from ESRS 2 IRO-1 and section 5.2.1.3, where this content is disclosed in the FY2025 report (pages 133-134). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Reference: page 133; pages 133-134.
In addition to the DMA, "the Group carried out a study on its main physical and transition risks in 2022" (page 133). It used "low (+1.5 °C) and high (+4 °C) warming scenarios by 2030 and 2040-2050, based on IPCC reports". It covered a transition risk analysis (scarcity of resources, market requirements, regulations, reputation) and a physical risk analysis for industrial sites and key suppliers (page 133).
Hazards analyzed include change in temperature, heat waves, cold waves, forest fires, changes in wind patterns, cyclones, sea level rise, water stress, dryness, heavy rainfall and flooding. A set of other hazards, such as permafrost thawing, avalanches and glacial lake overflow, was not analyzed "as they are less relevant to Guerbet's activities and the locations of its sites" (page 133).
The Group made an initial estimate of financial consequences using site values and the cost of a day of production; the exercise was on gross risks (page 133). The sites most exposed to water stress are Dublin, Lanester and Rio (page 134). The text names the scenarios only as low (+1.5 °C) and high (+4 °C) warming cases based on IPCC reports.
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from ESRS 2 SBM-3 and the climate chapter, where this content is disclosed in the FY2025 report (pages 127, 133, 135, 145). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Reference: page 127; pages 127, 133, 135 and 145.
The report presents no stand-alone resilience analysis with results. What it does say:
- The policies and actions in the chapter "attest to the strategy and resilience of the Group's business model in relation to the material IROs" (page 127).
- The Group built a net rating that includes existing control measures, so that it can set a roadmap that "will strengthen Guerbet's resilience" (page 127).
- The areas of the climate strategy (adaptation, mitigation, energy efficiency, renewables, supplier and carrier partnerships) aim "to preserve business continuity and strengthen the Group's resilience" (page 135).
- Business continuity plans with emergency procedures for physical risks exist, covering identified short-term risks (page 133).
- The 2028 water consumption target is described as aiming "to strengthen the Group's resilience to climate change" (page 145).
The climate IRO table lists an IRO on the consequences of extreme weather events on the supply chain and workers (page 134). The report does not discuss uncertainty in a resilience assessment.
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 135 (section 5.2.1.4).
Guerbet has "defined a transition strategy incorporating decarbonization. This is not a dedicated climate policy, as this area is integrated into the People & Planet commitment and into the HSE policy" (page 135). The CEO and the Technical Operations Director are responsible for deploying it, and employees are made aware of it.
The Climate Strategy covers upstream, downstream and own operations, in these areas (page 135):
- adaptation to climate change, for example water-cooling systems during heat waves
- climate change mitigation through a decarbonization trajectory
- energy efficiency, with less energy-intensive technologies
- deployment of renewable energies, with solar panels
- partnerships with suppliers and carriers to reduce emissions
Monitoring: climate challenges and progress against objectives go to part of the Executive Committee and the Board (page 135). The Group reports on its Climate Strategy to CDP and scored B in 2025 (pages 135, 138). The HSE policy is due for an update in 2026 (page 119).
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 135-137 (section 5.2.1.5); resources on page 132.
Levers already activated (page 135): monthly monitoring of energy-related emissions at industrial sites, a carbon criterion in investment reviews over the year and a five-year horizon, quarterly performance reviews with site Executive Committees, and regular exchanges among trained employees.
2025 site actions (pages 135-136):
- Lanester: launch of an evapo-concentrator project (EUR 7 million, 32% subsidized, expected to cut 3,700 tCO2e, "25% of the Group's target in scopes 1 & 2"), a waste-heat feasibility study, and a stronger energy management system with a view to ISO 50001 certification
- Dublin: authorization and study application for an on-site wind turbine
- Marans: a project to cut use of a solvent in a chemical intermediate synthesis
- Raleigh: steam network maintenance that reduced gas use
- Aulnay-sous-Bois: metering plan and insulation of steam condensate pipes
Value chain: strategic suppliers accounting for about 88% of raw material and packaging emissions were assessed in 2025; transport is 9% of emissions, with a trajectory showing more than 30% lower carbon intensity per ton transported by 2029 (page 136). In France, 66% of the vehicle fleet is hybrid or electric (page 137).
Resources: EUR 15.3 million of planned five-year capital expenditure for Scope 1 and 2 (page 132).
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: page 138 (section 5.2.1.6); see also pages 130 and 132.
SBTi-validated targets, with a 2021 reference year and a 2032 target year (page 138):
- Scopes 1 and 2 (100% of emissions): 49,780 tCO2e in 2021, 50,203 in 2024, 45,350 in 2025, against a target value of 36,091. The table shows 32% of the target reduction achieved; the text on page 138 says 31%.
- Scope 3 (85% of emissions): 190,570 tCO2e in 2021, 189,691 in 2024, 165,655 in 2025, against a target value of 164,843. The table shows 97% achieved.
Scope 1 and 2 emissions fell 10% in 2025, helped by green electricity at Dublin and a better steam system at Raleigh. Scope 3 fell 12.7%, which the company links to transport actions and to "the fall in the Group's activity" (page 138). A 2025 project to digitize the carbon footprint led to methodological reviews, and the changes were also applied to 2021 and 2024 (page 138).
ESG-financing target: Scope 1 and 2 energy emissions at industrial sites with constant emission factors, down 6.0% in 2025 against a 4.9% target, with a 9.0% reduction targeted for 2028 (page 138). The company calls its "Well-below 2°C" objective aligned with the Paris Agreement commitments; the report does not state a 1.5°C alignment (page 130).
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: pages 139-140 (section 5.2.1.6).
Scope: industrial sites only; administrative and sales units and the Lyon plant are outside the environmental data scope (pages 129, 184).
Total energy consumption was 178,993 MWh in 2025, down 5% from 188,364 MWh in 2024 (pages 138-139). The mix (page 139):
- fossil: 129,519 MWh, 72% of the total (143,950 MWh and 76% in 2024), of which natural gas 121,816 MWh
- nuclear: 23,823 MWh, 13%
- renewable: 25,651 MWh, 14% (21,953 MWh and 12% in 2024)
- decarbonized sources (renewable plus nuclear): 28% of total energy and 87% of electricity (78% in 2024)
The table shows no coal, crude oil or petroleum product consumption in either year. Self-produced renewable non-fuel energy rose from 1,389 MWh to 2,035 MWh (page 140). Energy intensity was 228 MWh per EUR million of net revenue in 2025 against 224 in 2024; the company attributes the rise to revenue falling faster than energy use (page 140). All energy produced on site is self-consumed (page 140).
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: page 141 (table headed "Total Group GHG emissions (E1-6)"); intensity on page 140.
2025 against 2024 (tCO2e), from the table on page 141:
- Scope 1: 37,133 (38,286); 19.7% from regulated emissions trading systems
- Scope 2 location-based: 6,967 (8,595); market-based: 8,217 (11,917)
- Scope 3: 165,655 (189,691), down 12.7%
- Total location-based: 209,755 (236,572)
- Total market-based: 211,005 (239,894), down 12%
Scope 3 categories reported: purchased goods and services 115,482 (the largest share), capital goods 2,604, fuel and energy activities 5,347, upstream transport and distribution 19,028, waste 7,687 (up 38.5%), business travel 6,047, employee commuting 2,455, downstream routing 2, use of products sold 2,901, end-of-life treatment 4,047, and investments 55. Other categories show no figure.
GHG intensity was 268 tCO2e per EUR million of net revenue location-based and 269 market-based, down 4.8% and 5.8% (page 140). The 2021 reference-year figures were restated after a methodology review in 2025 (page 138). The statutory auditor reviewed the GHG inventory process (page 206).
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon creditsReported
GHG removals and GHG mitigation projects financed through carbon credits
Reference: page 138 (section 5.2.1.6); listed in the company's index (page 186).
The company's index points E1-7 to section 5.2.1.6, and the answer there is a nil return: "The Group has not implemented any projects aimed at absorbing or storing greenhouse gases. Guerbet does not purchase carbon credits" (page 138).
Guerbet describes its renewable electricity as coming from an on-site solar farm at Dublin and green electricity bought through guarantees of origin (page 138).
No GHG removals, storage projects or mitigation projects financed through carbon credits are reported, and no plan to start them is described.
E1-10(was E1-8)Internal carbon pricingReported
Internal carbon pricing
Reference: page 138 (section 5.2.1.6); listed in the company's index (page 186).
The company's index points E1-8 to section 5.2.1.6. The body text gives a nil return with a stated plan: "The Group does not use any carbon pricing mechanism but plans to deploy it in the coming years" (page 138).
Related practice: Guerbet applies a "carbon criterion in the review processes for significant and budgetary investments for the year and over a five-year horizon" (page 135), and "incorporates environmental and climate criteria into its significant industrial investments" (page 130). The report does not describe this criterion as a price per ton of CO2e and gives no shadow price. No date for introducing carbon pricing is given.
E2 – Pollution
E2-1Policies related to pollutionReported
Policies related to pollution
Reference: page 142 (section 5.2.2.1).
Guerbet states that "the impacts, risks and opportunities relating to the control of discharges are covered by the ethics charter and the five areas of commitment. The Group and its sites apply HSE policies covering the control of discharges" (page 142). "Control of discharges" is one of the five environmental areas of commitment (page 129).
All commitments and policies on discharges are deployed at the industrial sites under the responsibility of the Site Directors (page 142). Each site's HSE policy covers prevention and control of industrial risks, controlling environmental impacts day to day and in an accident, and industrial safety culture (page 142). Sites run HSE management systems based on the principles of ISO 14001 and ISO 45001; the Dublin active ingredient plant is ISO 14001 certified (page 118).
The material E2 IROs are the consequences of water, air and soil contamination after an industrial incident, and changes in regulations (page 142). The section states that sub-topics such as substances of concern are not material (page 143).
E2-2Actions and resources related to pollutionReported
Actions and resources related to pollution
Reference: pages 142-143 (section 5.2.2.2).
The three active ingredient production sites, Dublin, Lanester and Marans, are subject to prefectural orders that set technical and operational provisions and require an intervention plan in an incident. Sites face internal and external inspections. Hazard studies are revised every five years for the Seveso upper tier sites, with risk control actions covering the management and reduction of discharges (page 142). "No major incidents requiring operational expenses occurred in 2025" (page 142).
Site actions (page 143):
- Dublin: monitoring program for the wastewater treatment plant
- Lanester: biological treatment for biodegradable effluents, nanofiltration to cut incinerated effluent, internal iodine recycling, and a gas washing system capturing volatile organic compounds
- Marans: continued work to cut chemical oxygen demand through its treatment plant, with effluents separated and some solvents recovered externally
- Programs to detect and repair fugitive VOC emissions are being put in place in 2025 and 2026
Resources: "With respect to the resources allocated to the management of material impacts and risks, Guerbet will not publish this type of information" (page 142).
E2-3Targets related to pollutionReported
Targets related to pollution
Reference: page 143 (section 5.2.2.3); listed in the company's index (page 186).
The targets the report names are regulatory limits, not voluntary reductions: API production sites "declare their discharges into water, air and soil each year. These discharges are monitored and measured in accordance with local regulatory requirements and are the targets for the sites" (page 143). The sites "comply with the thresholds set in consultation with the environmental authorities" (page 143), and the report names the Industrial Emissions Directive and the Water Framework Directive as the source of the release thresholds applied by the active ingredient sites (page 142).
Alert thresholds below the release limits allow quick detection of fluctuations (page 142). The report adds that discharges from the API sites were below the locally applicable regulatory thresholds in 2025 (pages 143-144).
The report states no quantified reduction target, base year or target year for water, air or soil pollution. The company says it will not publish the resources allocated to managing the material impacts and risks (page 142).
E2-4Pollution of air, water and soilReported
Pollution of air, water and soil
Reference: pages 143-144 (section 5.2.2.3).
Scope: the metrics are consolidated for the API production sites (Dublin, Lanester, Marans) (page 143).
Water: total organic carbon emissions (calculated as chemical oxygen demand divided by 3) from the API sites were 66 tons in 2025 against 63 tons in 2024. The company attributes the rise to a change in the mix of effluents treated at the Dublin wastewater plant (page 143).
Air: nitrogen oxides (NO and NO2) from the API sites were 33 tons in 2025 against 30 tons in 2024 (page 144).
Soil: "Guerbet does not directly track soil pollution indicators as this is not material for its sites", because the sites do not spread or inject waste into the soil and local licenses do not require such reporting. Marans and Lanester monitor groundwater quality, with no threshold breach noted; Dublin monitors the integrity of its buried pipelines; and no spill incidents leading to pollution of the soil occurred in 2025 (page 144).
Discharges from the API sites are reported as below the thresholds set by applicable local regulations (page 144).
E3 – Water
E3-1Policies related to water and marine resourcesReported
Policies related to water and marine resources
Reference: page 144 (section 5.2.3.1).
"The Ethics Charter and the HSE policy reflect the Group's commitment to minimize the environmental impact of its activities." The policy applies to own operations and is deployed at the industrial sites under the Site Directors. It covers water consumption, particularly at the sites exposed to the risk of water stress (Lanester, Dublin and Rio de Janeiro) (page 144). Actions to control discharges into water are cross-referenced to the E2 section (page 144).
Water is a material topic: the IRO table lists supply chain disruptions in the event of restrictions on water consumption, and pressure on water resources (page 144). The company used the ENCORE database to assess impacts on ecosystems and relied on site monitoring committees and local authority exchanges for local views (page 144).
Preserving natural resources such as water is one of the five environmental commitments, and water consumption reduction is one of the Group's targets (pages 120, 129). Water is covered through the Ethics Charter and the HSE policy, not a separate water policy document (page 144).
E3-2Actions and resources related to water and marine resourcesReported
Actions and resources related to water and marine resources
Reference: pages 144-145 (section 5.2.3.2).
The sites run 3R (Reduce, Reuse and Recycle) programs, including at the sites exposed to water stress (page 145).
Site actions (page 145):
- Lanester: a working group sets the roadmap to cut consumption, with studies on purified water production and internal water recycling. Reuse of water to cool the incinerator won the Loire-Bretagne water trophy. A waste-heat recovery study "could reduce the site's water consumption by up to 20%".
- Rio de Janeiro: the cleaning and preparation of production lines was revised in 2025, which reduced the associated water consumption.
- Raleigh: water meters were installed and the equipment wash cycle was revised to cut water use.
- Marans: changes to the water-for-manufacturing production systems "reduced water consumption by 20%".
Water recycled and reused rose to 28,080 m3 in 2025 (page 145). Lanester also participates in a regional working group on diagnostics and good practice (page 145).
Resources: "For resources allocated to material risk and impact management, Guerbet will not publish this type of information for this year" (page 144).
E3-3Targets related to water and marine resourcesReported
Targets related to water and marine resources
Reference: page 145 (section 5.2.3.3).
"By 2028, Guerbet has set itself a target of reducing relative water consumption by 8.7% compared with 2023, for its own operations." The objective has been written into some of the company's financing, was discussed with investors, applies annually and is included in the variable compensation of the employees concerned (page 145). The company says the target "aims to strengthen the Group's resilience to climate change".
Basis: it was set "taking into account risks for Guerbet, including water stress affecting three of its sites, as well as medium-term production prospects, but not based on scientific evidence" (page 145).
Progress against the 2023 reference year at the end of 2025: water consumption down 8% in intensity, 15% relative to production and 8% in absolute terms (page 145). The table also shows the reduction in relative consumption at -16% in 2024 and -15% in 2025, against an objective entry of -15% and financing targets of 0.0% for 2025 and -8.7% for 2028 (page 145).
E3-4Water consumptionReported
Water consumption
Reference: page 145 (section 5.2.3.3); listed in the company's index (page 186).
The table gives 2023 (reference year), 2024 and 2025 (page 145):
- total water consumption: 1,025,779 m3, 956,145 m3 and 947,108 m3 (down 8% against 2023)
- of which in areas at high water risk: 563,415 m3, 525,930 m3 and 505,737 m3 (down 10%)
- water recycled and reused: 20,785 m3, 23,935 m3 and 28,080 m3 (up 35%)
- water stored and change in storage: shown as dashes or not applicable
- water consumption per net revenue: 1,305, 1,137 and 1,204 m3 per EUR million (down 8% against 2023)
Scope: water, energy and waste are consolidated for the Group's industrial sites; administrative sites, commercial subsidiaries and distribution or R&I centers are excluded as negligible (page 184). The sites most exposed to water stress are Lanester, Dublin and Rio de Janeiro (pages 134, 144). The report notes that "the indicators presented above have not been validated by an external body" (page 145).
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: page 146 (section 5.2.4.1).
"Resource use and circular economy IROs are covered by several commitments and policies" (page 146):
- the Ethics Charter
- the HSE policy, which aims in particular to reduce environmental impacts from the start of any project
- the Planet commitment centered on eco-design and five areas, "four of which favor the circular economy": life cycle analysis, resource conservation, control of discharges and sustainable partnership
"These commitments aim to reduce Guerbet's impact on the environment and increase the resilience of our activities." They are implemented at industrial sites under the Site Directors (page 146).
The three material E5 IROs are market share gain through the circular economy and eco-design, contribution to reducing the environmental footprint of the health system, and supply disruptions and rising resource costs (page 146). The materiality of the waste theme was assessed using existing production processes and historic waste data (page 146).
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: pages 146-148 (section 5.2.4.2).
Innovation at the active ingredient sites rests on substituting solvents with lower-impact ones, using regenerated solvents and recycling internally (page 146). Examples (pages 146-147):
- Dublin recycles 80% of solvents internally
- Lanester recycles more than 800 tons of production effluent instead of incinerating it, cutting the site footprint by 1,000 tons of CO2e, and the evapo-concentrator project will recycle up to 3,200 tons of ethanol distillates
- Lanester and Dublin recover iodine and iodinated active substances; Raleigh, Aulnay-sous-Bois and Rio de Janeiro recover iodine through recovery channels
- a life cycle analysis of several key products began in 2025, with results expected in 2026
- in São Paulo, 93 injectors were refurbished, avoiding more than two tons of waste
- end of life: a shift from single to multi-patient use, support for the MeGadoRe gadolinium recycling chair, and a pilot to recover and recycle non-injected iodinated products with hospitals and clinics
Resources: the iodine recycling facility at Lanester cost EUR 2.5 million (page 148); the evapo-concentrator is a EUR 7 million investment (page 136).
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: pages 147-148 (section 5.2.4.2); listed in the company's index (page 187).
The company's index lists E5-3 against the resource inflow and outflow sections, and the text there sets no target. On inflows: "To date, Guerbet has not defined objectives relating to the use of resource inflows and wishes to deepen the analysis conducted in the short term to better understand its impacts in terms of resource inflows and, if necessary, define an objective" (page 147). On outflows: "As part of its CSR roadmap, the Group plans to study the implementation of a waste management objective in 2026" (page 147).
What the report tracks without a stated target: the rate of iodine recycled internally at Lanester (95.8% in 2024, 96.4% in 2025) and the rate of solvents recycled internally at Dublin (80% in both years) (page 147). The water consumption target sits in the E3 section (page 145), and the report says a packaging mapping to identify recycled and recyclable content began in 2025 (page 147).
E5-4Resource inflowsReported
Resource inflows
Reference: page 147 (section 5.2.4.2, "Resource inflow metrics and targets"); listed in the company's index (page 187).
The resource inflows considered are raw substances and chemical, mineral and natural raw materials, packaging, and electronic equipment (page 147). Water consumption is cross-referenced to section 5.2.3 (page 147).
The two E5-4 quantity metrics in the table are published as "Confidential" for both 2024 and 2025: the total weight of technical and biological products and materials used, and the percentage of organic materials from sustainable sources used to produce company products and services, including packaging (page 147). No weight or share is therefore disclosed.
What is given: 96.4% of iodine in effluents recycled internally at Lanester (95.8% in 2024) and 80% of solvents recycled at Dublin, in both years (page 147). The company has set no resource inflow objectives (page 147).
E5-5Resource outflowsReported
Resource outflows
Reference: pages 147-148 (section 5.2.4.2, "Resource outflow metrics and targets"); listed in the company's index (page 187).
Products and packaging: in 2025 a packaging mapping project began to identify the proportion of recycled and recyclable materials for the main product references. "This mapping is still to be completed, and a consolidated indicator cannot yet be established at Group level" (page 147). The company's table of reporting gaps lists the share of recyclable content in products and their packaging under E5-5 and says the work will be developed once the revised ESRS clarifications are known (page 128).
Product durability: Guerbet injectors have a service life of seven years, comparable with other injectors on the market. They have no repairability index, but a São Paulo project refurbished 93 injectors in 2025 (page 147).
Waste data are covered under the separate Waste entry (page 148). End-of-life actions for products are a shift to multi-patient use, recovery of unused gadolinium through the MeGadoRe chair, and a pilot to recycle non-injected iodinated products (page 147).
E5-5(was E5-5-Waste)WasteReported
Waste
Reference: page 148 (section 5.2.4.2.4, "Type of waste and recovery" table).
Waste generated by the industrial sites and treated externally was 18,772 tons in 2025 against 15,211 tons in 2024, up 23% (page 148). Of the 2025 total, 13,424 tons were hazardous and 5,349 tons non-hazardous.
Recovery and disposal, 2025 against 2024 (page 148):
- recovered: 10,283 tons against 8,891, of which recycling 6,603 tons (5,051) and other recovery 3,680 tons (3,840)
- disposed of: 8,489 tons against 6,320, of which incineration 7,127 tons (4,402)
- recovery rate 55% against 58%; recycling rate 35% against 33%
- landfill: 3.8% of waste against 5.0%
- radioactive waste: no quantity shown
The company explains the increase by higher production and by more waste treated externally at Dublin to run its wastewater treatment plant better. The recovery rate fell mainly because of more waste at Lanester, the largest contributor by volume (page 148). Main waste types are organic waste, solvents and packaging waste. All industrial sites have programs for waste handling, recovery and recycling (pages 147-148). The company plans to study a waste management objective in 2026 (page 147).
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 152-153 (section 5.3.1.2) and 118-119 (HSE policy).
Guerbet has two HR policies, a general policy and a social policy, "both aligned with international standards, in particular the United Nations Guiding Principles on Business and Human Rights" (page 152). They apply Group-wide, are overseen by the Human Resources Department and adapted by each entity locally (page 152).
The responsible social policy has five areas: diversity and inclusion, prevention, recognition, commitment and responsibility (page 152). The HSE policy sets six commitments covering all employees and external contractors, and the CEO, the Technical Operations Director and the Human Resources Director are responsible for it (pages 118, 152). The Ethics Charter, based on five pillars, includes respect for employees and applies to all employees, including temporary employees (pages 117-118).
Policy gaps the company states: "A policy on diversity and inclusion will be formalized over the next one to two years" (page 159), and the HSE policy will be updated in 2026 (page 119). Skills development and compensation policies are set at Group level (pages 156-157).
S1-2(was S1-2 + S1-3)Engagement with own workforce and workers' representatives, existence of channels for own workforce to raise concerns or needs and approaches to remedyReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: pages 150-151 (section 5.3.1.1.2).
Dialogue runs between managers and employees day to day and in annual performance and development reviews (page 151). Channels named:
- the Guerbet Listens engagement survey, run since 2022 across 13 categories; the 2024 survey had a 79% response rate, up 2 points (page 151)
- a quarterly video conference with the Executive Committee for all employees (page 151)
- the Guerbet Inside internal social network (page 151)
- three levels of social dialogue: elected staff representatives at entity level, trade unions, and the Board, where an Employee Director has the same rights as any other Director and an employee representative attends without voting rights (page 151)
Health and safety is a regular topic with employee representative bodies, and routine safety visits and discussions are used for field staff (pages 150-151). Collective bargaining coverage and social dialogue coverage are both 100% in France; in the United States the table shows a dash instead of a percentage for collective bargaining coverage (page 151).
Processes to remediate negative impacts and channels for own workforce to raise concerns
Reference: page 163 (section 5.3.1.10); whistleblowing system on pages 117-118.
Employees can report inappropriate behavior or actions contrary to ethical principles to a manager, Human Resources contacts, the Legal or Ethics Department, or through the GuerbetEthicsAlertLine whistleblowing platform, supplemented by feedback channels at the sites (page 163). The platform is independent of the IT network, collects alerts confidentially and anonymously if wished, and is handled by two Group contacts who coordinate analysis, admissibility, investigations and corrective actions, including sanctions (page 118).
Results for 2025: 22 reports related to human resources issues were received through the system, a figure that "includes possible cases of incidents of discrimination, including harassment", and no serious human rights issues were reported via the hotline (page 163). An annual report on escalations goes to the Ethics Committee of the Board (page 163).
To address negative health and safety impacts, Guerbet offers employees social protection (page 163). The report does not describe remediation steps taken in individual cases or the time taken to close a report.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 152-160 (sections 5.3.1.3 to 5.3.1.7); resources on page 150.
The company states that the actions it presents "are long-term" in each section. Main actions by material issue:
- health and safety (pages 153-154): safety leadership routines and site visits, a HSE network with safety ambassadors, procedures for critical operations, response and crisis plans, risk assessment, training, and the annual People & Planet Week with over 1,900 participants, or 65% of employees
- quality of life at work (pages 155-156): right to disconnect, a teleworking agreement, psychological and social risk training for managers, a 24-hour external psychological hotline and listening ambassadors
- skills (pages 156-157): training on good manufacturing practices, succession plans, a mentoring program, language learning, internal mobility
- compensation and attractiveness (pages 157-158): performance shares, pay transparency preparation, a wage increase budget to reduce the gender pay gap
- diversity and inclusion (pages 159-160): zero tolerance of discrimination, disability support in France, measures for seniors and young people
Resources: "With respect to the resources allocated to the management of material impacts and risks, Guerbet will not publish this type of information" (page 150).
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 154, 155 and 157-158 (the "Metrics and targets" paragraphs of section 5.3.1).
Health and safety: Guerbet sets two objectives, an internal one to reduce the Total Recordable Incident Rate (TRIR) and an external target for investors to reduce the 2-year average accident severity rate (page 154). The table on page 155 shows TRIR at 0.48, 0.41 and 0.25 for 2023 to 2025 beside a "2025 target: 0.7 (Guerbet-specific)", and the 2-year average severity rate at 0.09, 0.083 and 0.124 against a 2025 target of 0.095 and a 2028 target of 0.065. Management systems cover 71% of employees (100% at industrial sites) and Guerbet aims to cover 100% by 2026 (page 154).
Skills development: "Although the Group does not set a quantitative target in this area, it is committed to actively promoting the development of its employees' skills" (page 157).
Compensation: the Group "does not have a quantified objective" for the monitored pay metrics (page 158). Diversity: Guerbet reports having long met the aim of at least 40% women in management positions and on the Executive Committee, and aims for balanced representation at all levels (page 160).
Safety results are monitored through an annual objective for all Group employees, and for eligible employees fewer accidents feed variable compensation or profit-sharing (page 152).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 150 and 160 (section 5.3.1 and 5.3.1.7.3).
At December 31, 2025 Guerbet had 2,746 employees (2,905 a year earlier), counted as headcount on full-time, part-time, permanent or temporary contracts and excluding interns (page 150). By region: Europe 1,740, North America 443, Latin America 303 and Asia-Pacific 260 (page 150). France has 1,299 employees and the United States 443 (page 150).
Contracts: 96% of the workforce is permanent (2,637 permanent, 109 temporary), and Guerbet "does not hire employees under contracts with unguaranteed hours" (page 150). Full-time employees number 2,653 and part-time 93 (page 150). By gender, 1,176 are women and 1,570 are men, with none recorded as other (page 160).
Turnover (page 158): 573 employee departures and a turnover rate of 20.3% in 2025 (537 and 18.5% in 2024); for permanent staff 455 departures and 16.1% (440 and 15.9%). The report says these figures include temporary staff moving to permanent contracts and the end of internships and work-study programs. Guerbet markets in more than 114 countries with teams in more than 30 (page 150).
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: page 151 (section 5.3.1.1.2, "Rate of coverage of collective bargaining and social dialogue"); listed in the company's index (page 188).
The table covers countries with more than 50 employees representing more than 10% of the total workforce, which means France and the United States (page 151):
- France: 100% of employees covered by collective labor agreements and 100% covered by employee representatives
- United States: collective bargaining coverage shown as a dash instead of a percentage, and social dialogue coverage shown as not applicable
In France, the Social Relations Director ensures constructive social dialogue within each institution or entity. In the United States, "collective bargaining is not legally mandatory" and Guerbet "promotes social dialogue with trade unions" to build a collaborative work environment (page 151). The Group says it ensures that trade union rights are recognized and respected in every country where it operates (page 151). An Employee Director sits on the Board (page 151).
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: pages 159-161 (section 5.3.1.7.3).
Gender: at the end of 2025 there were 1,176 women and 1,570 men (page 160). Guerbet has "44% women on the Executive Committee" (page 159) and says that for several years it has met its aim of at least 40% women in management, middle management or senior management positions and at least 40% women on the Executive Committee (page 160). The company ties this to a French law target of 30% women among senior managers by 2026 and 40% by 2029 (page 159).
Age (page 161): under 30 years, 304 employees (11%); 30 to 50 years, 1,460 (53%); over 50 years, 980 (36%); age not communicated, 2.
Other measures: 75 nationalities in the workforce, of which 37 include someone in a managerial position (page 162). In France, the professional equality index is reported (page 161). Employees with disabilities are covered in S1-12.
S1-10(was S1-11)Social protectionReported
Social protection
Reference: page 159 (section 5.3.1.6.3, "Social protection"); listed in the company's index (page 188).
"The Group's social protection covers loss of income due to one of the major life events, which are illness, unemployment, workplace accident, acquired disability, parental leave and retirement." The report adds: "All Group employees have social protection in accordance with the local rules in force" (page 159).
Related benefits named in the compensation section (page 158): personal protection, health and retirement cover, with regular audits of health benefits to check that employees receive a good level of cover, and insurance against major personal risks. To address negative health and safety impacts that could affect employees, Guerbet offers social protection (page 163).
The report does not break social protection down by country or by life event, and does not list any country or employee category without cover for one of the events.
S1-11(was S1-12)Persons with disabilitiesReported
Persons with disabilities
Reference: page 161 (section 5.3.1.7.3, "Employment of persons with disabilities"); listed in the company's index (page 188).
Employees with disabilities in France made up 4.2% of the workforce in 2025 (4.4% in 2024): the table also shows 2.8% for women and 3.4% for men in 2025, without stating the bases for those sub-rates (page 161). The report adds that Guerbet S.A.'s employment rate for workers with disabilities, calculated in 2025 for 2024, is 5.2%, a rate that includes indirect jobs (page 161).
Scope: the percentage "is consolidated only for France due to certain legislative and regulatory specificities internationally", and Intrasense is excluded because it is not covered by the same HR information system (pages 161, 184). The figure covers Guerbet employees only and not supplier employees (page 161).
Actions in France include bonuses at first application for and renewal of disabled worker status, training for managers, paid leave for disability-related appointments, and job modifications or redeployment with the occupational health department (page 159).
S1-12(was S1-13)Training and skills development metricsReported
Training and skills development metrics
Reference: pages 157 and 184 (section 5.3.1.5.3, "Metrics and targets").
Result: "94% of employees received training" and "a performance assessment was carried out for 98% of employees" (page 157). The table gives 2025 training of 94% for women and 93% for men, and an average of 12.7 training hours per employee, with 10.9 hours for women and 14.0 for men; the 2024 average is marked non-consolidated. The performance assessment share is 98% in both 2024 and 2025 (page 157).
Scope: the performance assessment and training data are not consolidated for Intrasense, which is not covered by the same HR information system (page 184). The company's table of reporting gaps lists the share of employees who took part in the performance assessment and says the Group chose to consolidate an indicator on a limited scope, for employees on permanent contracts who arrived before September 15 (page 128).
The Group "does not set a quantitative target in this area" (page 157). Training effectiveness is assessed at the year-end review and, in some cases, through in-situation assessment by the trainer or a questionnaire (page 157).
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: pages 154-155 (section 5.3.1.3.3).
Employees, 2023, 2024 and 2025 (page 155):
- TRIR: 0.48, 0.41 and 0.25
- deaths: none in any year
- workplace accidents reported: 14, 12 and 7
- lost-time work accidents: 11, 10 and 7
- days lost to workplace accidents: 269, 498 and 605
- frequency rate of lost-time accidents: 2.56, 2.14 and 1.59; severity rate: 0.06, 0.11 and 0.14
The company says the number of reported accidents "has continued to fall for several years" and that 2025 shows a more marked decrease, while the severity rate "increased slightly due to two accidents leading to long stoppages" (page 154).
Other workers (non-employees): no deaths are shown in the table (page 155). Coverage by the health and safety management system is 71% of employees, which is 100% of industrial site employees and the French sites outside Intrasense (page 154). The metrics tracked are TRIR and an aggregated indicator of the frequency of reported accidents, and the report also tracks action indicators such as field safety visits and safety dialogues (page 154). The report gives no figure for recordable work-related ill health.
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: pages 155-156 (section 5.3.1.4); listed in the company's index (page 188).
The company's index maps S1-15 to section 5.3.1.4. That section describes measures but gives no percentage of employees entitled to or taking family-related leave.
Measures in France (page 155): the right to disconnect and a teleworking agreement, a guide to good practice for working from home and on screen, an annual interview on managers' workload, one hour granted on the first day of school, time granted for absence for single-parent families and parents of sick or disabled children, specific teleworking measures for pregnant women, caregivers and employees with disabilities, childcare places, and, from 2026, three days of paid leave per year for caregivers. Telehealth and support programs are available in Dublin, Asia-Pacific and the USA (page 155).
Effectiveness: "Annual manager/employee reviews, dialogue with employee representatives and internal surveys make it possible to measure the effectiveness of the quality of life at work and working conditions policy and action plans" (page 156).
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: page 158 (section 5.3.1.6.3, "Pay gap and compensation ratio").
The table on page 158 gives:
- gender pay gap: 8.6% in 2024 and 7.02% in 2025
- annual compensation ratio: 19.4% in 2024 and 29.41% in 2025
The company explains the 2025 change in the compensation ratio by two things: a methodological change that "now includes shares held by employees and by the Chief Executive Officer", and a transition period in which the Chief Financial Officer served as CEO (page 158). It adds that "This payment is aligned with the Group's objectives and was validated by the General Meeting" (page 158).
The company notes that its equality index "takes into account the structure of the workforce by country, business lines and seniority and thus differs from the compensation calculation proposed by the CSRD" (page 158). The equality index is the measure of equal pay the company uses (pages 158, 161). Guerbet "does not have a quantified objective" for these metrics (page 158). A standardized approach to pay transparency is being prepared for 2026 (page 158). The report does not state the gender pay gap by employee category.
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: pages 162-163 (sections 5.3.1.8 and 5.3.1.10).
Guerbet states: "To date, Guerbet has not been subject to any convictions, fines or penalties related to human rights" (page 162). It reports 22 whistleblowing reports related to human resources issues in 2025, a count that "includes possible cases of incidents of discrimination, including harassment", and says "no serious human rights issues were reported via the hotline" (page 163).
The human rights commitments cover the ILO fundamental conventions: freedom of association and collective bargaining, elimination of discrimination, elimination of forced or compulsory labor, and abolition of child labor (page 162). They are built into the Ethics Charter, HR policies, the whistleblowing platform and the responsible purchasing policy (page 162). The whistleblowing system is open to anyone and an annual report on escalations goes to the Ethics Committee of the Board (page 163).
The report does not split the 22 reports by outcome, does not state how many were substantiated, and gives no amount of fines or compensation.
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Policies related to value chain workers
Reference: page 164 (section 5.3.2.2.1); responsible purchasing approach on pages 119-120.
Through its responsible purchasing policy and supplier code of conduct, Guerbet "promotes its ethical, social and environmental values to its suppliers and asks them to do the same to their own business partners" (page 164). The first six of the code's 11 principles deal with social issues: human rights protection; no complicity in human rights abuses; workers' rights, health and safety; elimination of forced or compulsory labor; abolition of child labor; and combating discrimination in employment (pages 119, 164).
Suppliers must apply the code, including prohibiting all forms of modern slavery (forced labor, child labor, illegal workers), and the code is included in each contract (page 119). Guerbet commits to working only with suppliers that respect human rights and labor law under the ILO fundamental conventions and the UN Guiding Principles (page 163). Responsible purchasing is sponsored by the Director of Purchasing at the Executive Committee, and a responsible purchasing unit was created in 2025 (page 119).
S2-2(was S2-2 + S2-3)Engagement with workers in the value chain, existence of channels for workers in the value chain to raise concerns or needs and approaches to remedyReported
Processes for engaging with value chain workers about impacts
Reference: page 163 (section 5.3.2.1.2).
The report describes dialogue with suppliers and subcontractors, not with the workers themselves. The procurement teams "ensure that regular and transparent discussions are held with subcontractors and strategic suppliers". There is "a formalized dialogue process with key suppliers, through performance reviews that incorporate CSR aspects" (page 163). Those reviews discuss suppliers' sustainability commitments and priorities, and social issues such as workplace safety are included. The frequency "is defined on a case-by-case basis according to needs" (page 163).
Business reviews are held annually with key suppliers (page 120). Strategic suppliers and subcontractors are assessed with the "PESTEL" method, which also fed the double materiality assessment (pages 119, 163). Guerbet works with a few suppliers whose production sites are in countries more exposed to labor and human rights risks (page 163).
The report does not describe any consultation of workers or their representatives, and does not say who in the company is responsible for the dialogue beyond the purchasing function.
Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reference: page 164 (section 5.3.2.3).
If negative impacts occur, "the buyer and the business contact are the preferred points of contact for suppliers and partners to raise questions or concerns". Guerbet expects suppliers to remedy any non-compliance with the supplier code of conduct and encourages them to tell Guerbet about difficulties applying its principles or violations that could compromise the relationship (page 164).
The whistleblowing platform is open to all internal and external stakeholders, including suppliers, subcontractors and their workers, and is mentioned in the code of conduct. The company admits a limit: "Given the large number of suppliers with which Guerbet works, the Group does not have the means to ensure that its suppliers communicate the existence of a whistleblowing platform to their employees" (page 164).
Guerbet plans a CSR assessment tool whose results will define improvement goals for supplier practices, particularly on social issues, and measure the effectiveness of dialogue (page 164). In 2025 no human rights report involving workers in the value chain was recorded (page 164).
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
Taking action on material impacts on value chain workers
Reference: pages 164 and 119-120 (sections 5.3.2.2.2 and 5.1.3.4).
The material S2 IRO is the consequence of an industrial incident on workers and supply (page 163). Actions (page 164):
- supplier HSE risk analysis with the "PESTEL" method for strategic suppliers and subcontractors, with a second supplier qualification process for strategic raw materials where possible
- with one major partner in Asia, a progress plan based on a process safety audit carried out in 2023 and renewed in 2025 to measure the effectiveness of actions
- in 2024, participation in a LEEM sector initiative that produced a responsible purchasing kit, including a supplier charter, for LEEM members
The wider responsible purchasing process covers selection, risk analysis, performance review and engagement, and CSR criteria account for 10% of the weight in supplier comparisons (pages 119-120). An internal tool assesses strategic suppliers' CSR performance and an external platform is planned (page 120). Buyers receive responsible purchasing training (page 119).
Resources: Guerbet "will not publish this type of information" on resources for managing material impacts and risks (page 163).
S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: page 164 (section 5.3.2.2.3); listed in the company's index (page 188).
The company's index points S2-5 to section 5.3.2.2.3, and the answer is that no targets exist yet: "Guerbet does not yet have specific targets and metrics on social issues for its upstream value chain. The Group will work on this in 2026 in connection with the rollout of a CSR assessment tool" (page 164).
The only measure given is an outcome: "In 2025, the Group did not record any human rights reports that would involve workers in the value chain. This is a measure of the effectiveness of policies and initiatives" (page 164).
Supplier-related indicators sit in the business conduct chapter: 141 suppliers had signed the code of conduct on a cumulative basis, shown as 80%, and 137 had a cumulative CSR assessment over two years, shown as 78%, for strategic suppliers (page 173). Those indicators cover all CSR topics for strategic suppliers and are not specific to social issues in the upstream value chain.
S3 – Affected Communities
S3-1Policies related to affected communitiesReported
Policies related to affected communities
Reference: page 165 (section 5.3.3.2).
Local communities are material for Guerbet. The one material IRO is the consequence of an industrial incident on local populations, linked to the risks in control of discharges and safety of operations, in own operations and upstream (page 165).
Policy: "Guerbet's strategy is adapted to address the material risk relating to local communities, in particular by integrating the consideration of affected communities into its HSE and purchasing policies" (page 165). At the API sites, HSE policies aim to ensure the health and safety of people, "especially local communities", through major accident prevention processes and control of environmental impacts (page 165). The Group monitors community IROs through regular dialogue, including annual commissions at Seveso-classified sites, and supplier performance reviews (page 165).
The report presents no separate community policy document; community considerations sit in the HSE and purchasing policies (page 165).
S3-2(was S3-2 + S3-3)Engagement with affected communities, existence of channels for affected communities to raise concerns or needs and approaches to remedyReported
Processes for engaging with affected communities about impacts
Reference: page 165 (section 5.3.3.1.2).
Guerbet says it attaches "particular importance to the quality of dialogue with local communities and authorities". Engagement is the responsibility of the site Directors, working with the Public Affairs and Communication Department (page 165).
Channels named (page 165):
- Marans and Lanester: annual site monitoring commissions with five colleges, namely state administration, local authorities, the operator, local residents and environmental associations, and the operator's employees; they exist to prevent environmental risks, monitor the activity of safety-classified plants and promote public information
- Dublin: a commission that meets annually with all residents of the industrial zone and the local authority
- sites in France: regular interactions with the municipality, the regional environment directorate (DREAL), service providers and local residents
- membership of working groups and networks such as France Chimie
Guerbet also runs an economic study, since 2018, of the national and local effects of its activity in France (page 166). The report does not say how input from residents changed any decision.
Processes to remediate negative impacts and channels for affected communities to raise concerns
Reference: page 166 (section 5.3.3.5).
For an accident, "depending on its severity, the site would trigger its emergency response plan. External assistance would be called upon if necessary. Local authorities would be notified if the effects of the accident were outside the site boundaries", and they could then activate the external intervention plan. The two plans work together to organize emergency services and inform the public, and the Group would also activate its crisis management procedure (page 166).
Channels: "the whistleblowing platform allows anyone to report incidents" (page 166). The annual site monitoring commissions at Seveso-classified sites and the residents' commission at Dublin also give local people a regular forum (page 165).
Seveso sites implement emergency response plans that include measures to inform and protect local communities (page 165). The report states no number of community complaints and no remediation case. In 2025 "no material incidents were reported" (page 165).
S3-3(was S3-4)Taking action on material impacts on affected communitiesReported
Taking action on material impacts on affected communities
Reference: pages 165-166 (section 5.3.3.3).
Actions (page 165-166):
- preventing industrial risks: the three Seveso-classified sites (Dublin, Marans, Lanester) are subject to prefectural requirements and regularly carry out hazard studies; internal procedures and staff training keep skills current
- Technological Risk Prevention Plans (PPRT) are being put in place at Marans and Lanester; they provide emergency measures and control urbanization within risk-based perimeters, restricting new construction in high-risk areas
- Dublin, with local authorities, has chosen to keep certain Seveso requirements from its former upper tier classification, covering emergency response planning and the safety management system (page 166)
- Lanester: an initiative to control and prevent olfactory pollution (page 166)
- supporting employment: an economic study since 2018 of the effects of the activity on the French economy in jobs and investments, updated in 2025 (page 166)
The effectiveness of the actions is measured "in particular through monthly reporting and performance reviews implemented as part of the HSE policy" (page 166). Resources: Guerbet will not publish the resources allocated to managing material impacts and risks (page 165).
S3-4(was S3-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: page 166 (section 5.3.3.4); listed in the company's index (page 189).
Guerbet states no community-specific target. For industrial risks it "relies on the monitored targets and metrics, presented in the sections Control of discharges (regulatory compliance target) and Health and safety (metrics and target beyond the regulatory requirements)" (page 166). It adds that "exchanges with local communities and the lack of material reporting make it possible to ensure the effectiveness of the measures in place" (page 166).
A second set of metrics comes from the economic study of the Group's activity, whose results are shown in an illustration. The text says that between 2011 and 2024 Guerbet's growth in added value increased slightly more than the industry average (page 166). The numeric results sit in the illustration and are not set out in the text.
The report states no target for incidents affecting local populations, and notes that in 2025 no material incidents were reported (page 165).
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 167-172 (policy paragraphs of section 5.3.4).
For Guerbet, consumers and end-users are patients and healthcare professionals, including clinical trial participants (page 167). Policies named:
- responsible promotion: the Group disseminates "objective, non-misleading information that supports the rational use of its products", all promotional materials are verified and approved, and contrast media promotion is reserved for healthcare professionals and not advertised to the general public (page 167). The Group Compliance Officer manages the policy (page 167)
- innovation: R&D strategy built around diagnostic imaging, interventional radiology and artificial intelligence (page 168)
- clinical trial safety: compliance with the Declaration of Helsinki, ICH recommendations, Good Clinical Practice and Regulation (EU) No 536/2014 (page 169)
- quality: a Quality policy with six fundamental points, placing patient safety first, implemented by the Quality and Technical Operations Department (page 170)
- access: a market access strategy validated by Management, aiming at public reimbursement and equity of access (page 171)
S4-2(was S4-2 + S4-3)Engagement with consumers and end-users, existence of channels for consumers and end-users to raise concerns or needs and approaches to remedyReported
Processes for engaging with consumers and end-users about impacts
Reference: pages 167-168 (section 5.3.4.1.2). The company's index points S4-2 to the "Management of negative impacts and channels for raising concerns" section (page 171).
Guerbet engages with healthcare professionals and patient stakeholders through procedures governed by its ethics charter and local regulations. Mechanisms named:
- feedback from healthcare professionals to meet their needs; in 2025 Guerbet France ran a customer satisfaction survey (page 168)
- scientific or medical questions from healthcare professionals handled by the Medical Affairs team, with a regional and global network and an internal database of questions and answers (page 168)
- interactions that need a response from healthcare professionals are formalized in a contract to avoid corruption or conflict of interest risk, and are published on the French Transparence-Santé website and equivalents elsewhere (page 168)
- the Guerbet France sales subsidiary is certified by AFNOR for its promotional practices and is audited (page 168)
The effectiveness of these interactions is monitored by "various internal metrics" (page 168); the report names none.
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reference: page 171 (section 5.3.4.5); counterfeit procedure on page 170.
"Guerbet has suitable standards and processes for managing all types of requests, in accordance with the regulations in force. The ethics whistleblowing system is accessible to healthcare professionals and patients" (page 171). Healthcare professionals can also put scientific or medical questions to the Medical Affairs team (page 168).
For counterfeit or suspected counterfeit products, Guerbet "takes all reports of counterfeits seriously" and has a procedure to manage risks to patients and inform at-risk parties, including health authorities, with the aim of removing suspected counterfeit products from the supply chain. It applies to all Group entities in manufacturing, packaging, import, distribution, marketing and sales, and employees must report any proven or suspected counterfeit product to their manager (page 170).
Quality deviations lead to action plans that are monitored until resolved (page 170). The report does not give counts of patient complaints, pharmacovigilance reports or resolved cases in this section.
S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actionsReported
Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reference: pages 167-171 (action paragraphs of section 5.3.4).
Material IROs (page 167) cover reputation gained through research, the positive contribution of products to patient health, training of healthcare professionals, non-compliant or counterfeit products, access to products worldwide, supply discontinuity for medicinal products of major therapeutic interest, and the balance between health-system sustainability and innovation.
Actions (pages 168-171):
- innovation: Elucirem, a macrocyclic gadolinium-based contrast agent with a gadolinium dose "less than half that of other macrocyclic gadolinium-based contrast media for comparable efficacy"; AI software with Intrasense, including CE certification for the Myrian 2.12 platform with prostate AI; EUR 5.9 million of Bpifrance funding for Liflow
- quality: a roadmap on batch release time, investigations, quality control laboratories and cost of non-quality; periodic audits; counterfeit prevention
- supply: Guerbet keeps a safety stock of medicinal products of major therapeutic interest and produces annual management plans to control shortage risk (page 171)
Effectiveness is followed through quality metrics and the "right the first time" goal (page 171). No resource figure is given beyond the Bpifrance funding.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: pages 169 and 171 (the "Metrics and targets" paragraphs of section 5.3.4).
Targets and metrics named in the report:
- Innovation and contribution to health: 9.6% of Group revenue is dedicated to Innovation, Research & Development, supported by the strategic roadmap to strengthen leadership in MRI and develop Interventional Radiology around Lipiodol (page 169)
- Quality: "Guerbet monitors various quality metrics at its industrial sites with associated objectives", including a "right the first time" product improvement goal that covers quality and availability of products and process efficiency (page 171)
- Access: the strategic roadmap has four priority areas, three of which promote access to products: Interventional Radiology and Lipiodol, operational excellence to deliver ordered products on time, and new growth drivers (page 171)
The report gives no target value, base year or target year for the quality objective, and no on-time delivery figure. The only quantified metric in this section is the R&D share of revenue (page 169).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 172-173 (sections 5.4.1 and 5.4.2); Ethics Charter on pages 117-118.
The Ethics Charter, HR policy and HSE policy "form the foundation of the corporate culture" (page 172). Through the Charter, shared with all employees, "Guerbet promotes fair competition and commits to combating all forms of corruption, influence peddling, conflicts of interest" and practices that do not fit its integrity (page 173). The Charter has five pillars (page 118) and a multilingual e-learning module rolled out to all employees in 2025 (page 117).
Culture: a transformation program launched in 2021 involved nearly 200 volunteers and produced five behavioral principles: Customer Centricity, Focus, Audacity, Responsibility and Cooperation (page 172). They are written into individual objectives and reviewed at annual performance reviews, with an awards system (page 172). In 2025 Guerbet defined its employee value proposition (page 172).
Whistleblowing: the GuerbetEthicsAlertLine is open to employees and external stakeholders, and an annual report on its functioning goes to the Ethics Committee and the Board (page 118). The Audit, Risk, Internal Control and Ethics Director coordinates Charter updates (page 117). Whistleblower protection is described as not material under the DMA (page 175).
G1-2(was G1-2 + G1-3)Actions related to business conductReported
Management of relationships with suppliers
Reference: page 173 (section 5.4.2.1); responsible purchasing on pages 119-120.
The responsible purchasing policy "seeks to cultivate collaborative, balanced, and healthy relationships" with suppliers, and selection criteria rely on "open and fair competitive bidding rules" (page 173). Its main principles include a long-term purchasing strategy, integrating ethics and CSR into purchasing, fair competition and long-term supplier relationships (page 173). CSR criteria weigh 10% in supplier comparisons, and the Group states it will avoid economic dependence and abusive commercial practices (page 119).
Actions: selection, risk analysis, assessment and audits, and a planned CSR assessment tool (page 173). Strategic suppliers: 141 had signed the code of conduct cumulatively (80%), and 137 had a cumulative CSR assessment over two years (78%) (page 173).
Payment: the target standard is 60 days from invoice date, with local rules where they apply; Days Payable Outstanding was 70 days on average in 2025 (page 173). The material IRO on supplier relations is the consequences of non-responsible purchasing practices (page 172).
Prevention and detection of corruption and bribery
Reference: pages 174-176 (section 5.4.2.2).
Guerbet states that it "does not tolerate any form of corruption or influence peddling" and runs a program under the French Sapin II Act, the US FCPA and the UK Bribery Act (page 174). The policy applies to the Board, the CEO, the Executive Committee, managers and all employees, including occasional staff and third-party intermediaries. The anti-corruption policy is set under the Audit, Risk, Internal Control and Ethics Department, and an anti-corruption officer implements it (page 174).
Prevention and detection (pages 174-176): a corruption and influence-peddling risk map built on the French anti-corruption agency (AFA) recommendations; a third-party evaluation procedure with contractual anti-corruption clauses for commercial intermediaries; a conflicts of interest procedure with an annual questionnaire for Global Leaders; the whistleblowing platform, which received 29 messages in the year (page 175); e-learning in seven languages for the most exposed staff, refreshed every three years, with 69% of functions at risk trained cumulatively over two years (pages 175-176).
Controls and conclusions are summarized periodically for the Executive Committee and the governance bodies (page 175).
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.
Reference: page 173; pages 173 and 176.
Guerbet sets targets and tracks effectiveness for parts of the business conduct chapter (page 173 and following):
- strategic suppliers: the "Strategic supplier target" table tracks signing of the supplier code of conduct (141 suppliers, 80%, cumulative) and CSR assessment over two years (137 suppliers, 78%), without stating a target level (page 173)
- corruption: a cumulative e-learning rate over two years of 69% for functions at risk, a 30-minute module repeated every three years (page 176)
- outcomes tracked: no convictions, fines or corruption cases in 2024 and 2025, and no competition proceedings or complaints in 2025 (page 176)
- payment practices: the 60-day standard payment target, Days Payable Outstanding of 70 days in 2025, and an initial on-time payment estimate of 79% for strategic suppliers (page 173)
No target level, base year or target year is stated for any of these (pages 173, 176).
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: page 176 (section 5.4.2.2, "Metrics and targets"); listed in the company's index (page 189).
The report says the table "specifies the cases of corruption occurring during the reporting year". For both 2024 and 2025 it shows no convictions for violations of anti-corruption legislation, no fines, no corruption cases (passive or active), no cases leading to dismissal or punishment of workers, and no contracts with business partners terminated or not renewed because of corruption-related offences (page 176).
A nil return is the disclosure. Related facts: 29 messages were received through the whistleblowing system in the year, which the report does not break down by subject (page 175); a separate count of 22 human resources reports is given in the S1 chapter (page 163). In competition law, the Group "was subject to no competition proceedings or complaints" in 2025 (page 176).
The report does not describe how reports of corruption are investigated or how outcomes are reported to the Board beyond the annual report on the system (pages 175-176).
G1-6Payment practicesReported
Payment practices
Reference: page 173 (section 5.4.2.1, "Payment terms and average payment time"); listed in the company's index (page 189).
The target standard payment time is 60 days from invoice date, except where local rules apply. In France the company applies the payment times in the LME Act of August 4, 2008. For SMEs there are no specific payment terms unless required by law (page 173).
Metrics: Days Payable Outstanding was 70 days on average across the Group in 2025. An initial estimate of the share of invoices paid on time, run on strategic suppliers accounting for 30% of expenditure, shows a DPO of 51 days and 79% of invoices paid on time (page 173). No legal proceedings for late payment are pending (page 173).
Method: the company says the payment period is calculated by comparing trade payables including VAT with purchases for the year excluding VAT, which "leads to a slight overestimation of the indicator" (page 128). Its gap table adds that the on-time payment work will continue "in the coming years" (page 128). The report does not give a split by supplier size.