Hellenic Exchanges Athens Stock Exchange Sa

The role of the administrative, management and supervisory bodies

Reference: pages 90-91; business conduct role on page 126.

The Board "holds the responsibility for approving the overall sustainability strategy and making policy decisions on sustainability matters" (page 91). The Strategic Planning Committee, made up of Board members with the CEO as an ex officio member, oversees the sustainable development strategy and sends proposals to the Board. The Sustainability Committee, chaired by the CFO and made up of C-suite executives and the ESG Officer, "holds responsibility for drafting and implementing the sustainability strategy" (page 91).

Board at 31 December 2025 (page 91): 1 executive and 10 non-executive members; 90.9% independent; 72.7% male and 27.3% female. The Group "does not have formal employee representation on the Board".

Expertise: "All Board and Executive Committee members possess knowledge of sustainability". FY 2024 training covered CSRD and the ESRS, and outside experts are used. The Board is assessed each year through the Nomination and Compensation Committee, with an external review every two years (page 91).

Disclosures on the Board's business conduct role and member expertise are incorporated by reference from the Corporate Governance Statement (page 90).

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: page 92.

The Sustainability Committee runs the sustainability strategy day to day and has five stated functions: manage matters under the Sustainability Policy; develop and approve the action plan; oversee data collection by the Sustainability Data Owners; monitor progress against targets; and supervise the annual sustainability report. Cross-functional working groups, a Corporate Sustainability Team of senior executives and the Group ESG Officer support it.

The Board and its committees "receive frequent updates on sustainability matters" (page 92). In 2024 the Board "received information about all material impacts, risks and opportunities identified through the Group's first materiality assessment process", and the Sustainability Committee updated the material IROs in 2025 (page 92). The statement does not say how many times the Board met on sustainability in 2025.

Integration of sustainability-related performance in incentive schemes

Reference: page 92; climate point on page 109.

The Group "has established a Long-Term Incentive Plan (LTIP) that incorporates ESG-related performance criteria in executive compensation arrangements, in accordance with the Remuneration Policy" (page 92). The statement gives no criteria, weights or percentages. It sends readers to the Remuneration Policy and remuneration reports on the Group's website.

For climate specifically, the E1 chapter says: "The Group has not established climate-related performance criteria for executive compensation arrangements" (page 109).

Statement on due diligence

Reference: pages 92-93.

The Group says its due diligence approach "is embedded within the governance structures, strategy, and business model" and rests on "continuous engagement with affected stakeholders" through 1-to-1 meetings, client and employee satisfaction surveys and performance reviews (page 92). Within the double materiality assessment, due diligence informed the identification and scoring of adverse impacts.

Page 93 maps the five core elements to sections of the statement:

• Embedding in governance, strategy and business model: GOV-1, GOV-2 and SBM-3.
• Engaging affected stakeholders: SBM-2 and S1-1.
• Identifying and assessing adverse impacts: GOV-2, G1-1 and S1-1.
• Taking action: E1-3 and S1-3.
• Tracking effectiveness and communicating: G1 governance (G1.GOV-1) and S1-3.

The table points to policies and processes by topic; it does not describe a single group-wide due diligence process or give results.

Risk management and internal controls over sustainability reporting

Reference: pages 93-94.

The risk approach rests on "likelihood of occurrence and the potential impact". Risk categories named for the reporting process: incomplete information, errors in data capture or processing, inaccurate measurement or estimates, regulatory non-compliance and operational disruption (page 93).

Controls (page 93): segregation of duties, with collection, validation and review done by separate people; reconciliation of reported data to source documents; analysis of material differences against the prior period; training for staff in the reporting function. Sustainability risks sit inside the internal risk management system, and the Internal Audit Division reports to the Audit Committee.

The risk catalogue (page 94) ranks data quality and availability first, especially Scope 3 data where supplier information is hard to get, followed by regulatory compliance risk (including unclear sector guidance for financial market infrastructure) and process risks around manual data entry and deadlines. The statement gives no scoring results and does not report test results for the controls.

Strategy, business model and value chain

Reference: pages 94-96; basis of preparation on pages 89-90.

The Group's business model "is centered on providing an integrated suite of services that support capital markets" (page 94). Activities: listing; trading (including the Alternative Market, EN.A); clearing, with ATHEXClear as central counterparty; settlement and registry, through ATHEXCSD; data services; IT, digital and other services; and ancillary services such as education and rents (pages 94-95).

Upstream: securities issuers, IT, data, hardware, software and cloud providers, and consultancies. Downstream: financial intermediaries, data users, media and research firms (page 95). No headcount or revenue split by activity is given in this section.

Sustainability strategy (pages 95-96): four pillars set after the 2024 double materiality assessment: Our People, Information Security & Data Privacy, Sustainable Markets and Climate Change. Page 96 carries a KPI table with 2025 results and 2025-2029 and 2030-and-later targets.

Basis: the Group "is not within the scope of the Corporate Sustainability Reporting Directive (CSRD)" and reports voluntarily; strategy and governance information may not fully reflect the position after the Euronext acquisition (page 89).

Interests and views of stakeholders

Reference: pages 96-97.

The Group lists six stakeholder groups with channels for each: employees (intranet, surveys, performance reviews, CEO town halls); investors and shareholders (general meetings, conferences, results calls); clients and market participants (satisfaction surveys, meetings, workshops); regulators and competent authorities; suppliers and business partners; and society (CSR initiatives, seminars, partnerships) (pages 96-97).

In FY24 a stakeholder questionnaire sat inside the first double materiality assessment so stakeholders could rank topics (page 97). Results: corruption and bribery prevention was the top-rated concern across groups; work-life balance rated high among employees, civil society and suppliers; whistleblower protection ranked high with investors, clients and suppliers; "Climate change mitigation received moderate attention across groups" (page 97).

The feedback feeds three routes: the prioritization matrix, the Sustainability Committee's work program, and product development. The Committee passes thematic summaries to the Board (page 97). The statement gives no response counts for the questionnaire.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: page 98; IRO tables on pages 109, 116, 126, 130 and 132.

Material sub-topics (page 98): E1 climate change mitigation and adaptation; S1 equal treatment and opportunities for all, and working conditions; G1 corporate culture, and corruption and bribery; two entity-specific topics, contribution to the market (financial literacy; market-facing ESG initiatives) and cybersecurity.

The individual IROs "are presented at the beginning of each respective section" (page 98). Counted from those tables: 2 climate impacts (both negative, actual), 5 workforce items, 2 business conduct items and 7 entity-specific items, 16 in all.

Link to the business model: continuously running data centers and offices drive electricity use and emissions, "inseparable from the business model"; the position as a facilitator of sustainable capital markets drives positive impacts through the ATHEX ESG Reporting Guide, ESG Index, ESG Data Portal and Bonds GREENet (page 98). Climate resilience analysis has not been done (page 109).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 98-101.

The first double materiality assessment (DMA) was done in 2024 and "reassessed" in 2025 (pages 98-99). Stakeholders were consulted through a survey in FY24 (page 99, note 8).

Ten steps (pages 99-100): (1) topic identification from sector context and business model; (2) the ENCORE framework to map the value chain and nature-related impacts; (3) an IRO repository, filtered for relevance; (4) data owners per theme; (5) validation by the Corporate Sustainability Team; (6) scoring workshops; (7) scoring on scale, scope and irreversibility for negative impacts, likelihood for potential impacts, and magnitude and likelihood for risks and opportunities; (8) score validation; (9) cut-offs; (10) final validation by the Sustainability Committee.

Cut-offs (page 100): the 50th percentile (median) of scores for impacts and the 60th percentile for risks and opportunities.

Link to risk management (page 101): DMA results feed the Enterprise Risk Management framework through data owners, the Corporate Sustainability Team, the Sustainability Committee, then the Executive Committee and Board.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 135-141 (Appendices [IRO-2]).

The content index maps ESRS 2, E1, S1 and G1 disclosure requirements to sections of the statement (pages 135-137). It marks E1-7, E1-8, E1-9 and S1-7 "Not applicable" (page 136) and G1-2, G1-5 and G1-6 "Not material" (page 137). E2 to E5 and S2 to S4 have no entries in the index. The list of datapoints derived from other EU legislation marks the E2, E3, E4, E5 and S2, S3, S4 datapoints it covers "Not material" (pages 139-141).

The statement is voluntary: the Group "is not within the scope of the Corporate Sustainability Reporting Directive (CSRD)" but "elected to voluntarily align" with it (page 89). Phase-in reliefs are marked "Not applicable, as this Statement is prepared on a voluntary basis" (page 90), although the note on page 115 omits E1-9 under ESRS 1 Appendix C.

Transition plan for climate change mitigation

Reference: pages 108-109; EU Taxonomy chapter pages 103-107.

The Group has no transition plan. "The Group has not developed a formal climate transition plan. As at the reporting date, the Group's approach to climate change mitigation is supported by a set of ad hoc initiatives implemented across the organization" (page 108).

Levers named (page 108): fleet electrification, renewable energy sourcing, and efficiency work in the data centers (efficient hardware, advanced cooling). Recycling programs are described as part of its environmental management system. None is quantified.

Paris alignment (page 109): "The Group closely monitors Paris Agreement requirements and implements alignment measures in due course." No 1.5°C pathway or external validation is named.

Executive pay (page 109): "The Group has not established climate-related performance criteria for executive compensation arrangements".

Locked-in emissions (page 109): the Group says it has no "carbon-intensive physical assets or products that would create locked-in emissions"; the main sources are data center and office electricity, the vehicle fleet and commuting.

CapEx and OpEx: "addressed in detail in the EU Taxonomy chapter" (page 109), which reports 9.12% of CapEx and 4.80% of OpEx as eligible and none aligned (pages 103, 106-107).

Identification of climate-related risks and scenario analysis

Back-filled from the E1 Impact, risk and opportunity management section (E1.IRO-1) and E1.SBM-3, where this content is disclosed in the FY2025 report (pages 109-110). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No scenario analysis has been done. "Climate scenario analysis has not been conducted to inform financial planning or risk assessment processes" (page 110). No scenario, temperature pathway or time horizon is named.

Physical risk (page 110): identified "through a preliminary assessment of potential hazards to the Group's operational infrastructure". The primary exposed asset base is the technology infrastructure, including data centers, and the hazards named are "extreme temperatures, flooding, or other weather-related events". The financial exposure described is emergency repairs, capital expenditure for resilience upgrades and revenue losses (page 109). The step was "conducted without formal climate-related scenario analysis or screening across defined time horizons".

Transition risk (page 110): identified "at a preliminary level"; policy, technology and market events are acknowledged, "though formal screening of asset and business activity exposure to these transition events has not been completed".

Resilience in relation to climate change

Back-filled from E1.SBM-3 (Climate resilience analysis, page 109) and E1.IRO-1 (page 110), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group states it has not performed a resilience analysis. "While the Group acknowledges the importance of resilience and scenario analyses in understanding potential environmental and climate-related impacts to its strategy and business model, these analyses have not yet been conducted" (page 109). The IRO-1 section adds that it "has not yet performed a resilience analysis or Task Force on Climate-related Financial Disclosures (TCFD) assessment" (page 110).

A future analysis "will assess the Group's ability to adjust or adapt its strategy and business model to climate change", considering fleet electrification, renewable energy sourcing and data center efficiency (page 109). No date is given.

Elsewhere the statement says the resilience of its strategy is "demonstrated through its integrated approach" and that the business model responds to material effects through its Enterprise Risk Management system (page 98). That is a qualitative claim, not an analysis.

Policies related to climate change mitigation and adaptation

Reference: pages 110-111; strategy pillars on page 95.

The E1 policy section names two instruments. First, the Sustainability Policy: "In 2021, the Board approved the Group's Sustainability Policy, which is publicly available on the Group's website." It applies to all subsidiaries and direct partners, and the Group "encourages subcontractors, suppliers, partners, consultants, and other professional associates, as well as listed companies, to respect and adopt the principles set out in this policy" (page 110).

Second, the sustainability strategy set after the 2024 double materiality assessment, with a Climate Change pillar (page 95). The Strategy, with the Policy, "provides the strategic foundation for managing climate-related impacts, risks, and opportunities" (page 111).

The section names no separate climate policy and says nothing about policy content on adaptation. It states that since 2018 the Group has "undertaken significant initiatives to promote non-financial transparency and the proper management of environmental, social and governance issues" (page 111).

Actions and resources in relation to climate change policies

Reference: page 111; resources pointer on page 109.

The Group lists four action areas, "aligned with its environmental management system and sustainability strategy, but not yet in alignment with the ESRS requirements" (page 111):

• Data center efficiency: efficient hardware and advanced cooling, plus LED lighting across its buildings, to cut energy per unit of computing output.
• Environmental management programs: recycling programs for eco-efficiency and awareness.
• Fleet electrification: "a primary action" to reduce emissions from the vehicle fleet and employee commuting. No fleet size, share or date is given.
• Renewable energy sourcing: the Group is "developing strategies" to use more renewable energy, and cites the Green Pass from its electricity vendor as "tangible progress".

No action has a quantified emissions effect, a timeline or a stated budget. The statement points to the EU Taxonomy chapter for CapEx and OpEx planning (page 109).

Targets related to climate change mitigation and adaptation

Reference: pages 111 and 96; emissions data on page 112.

The Group "has committed to a 50% reduction in total Scope 1 and Scope 2 (location-based) GHG emissions by 2030, using 2022 as the baseline year (1,663 tnCO2eq)" (page 111). It is the only climate target: "specific targets for other climate-related impacts, risks, and opportunities have not yet been established" (page 111).

The KPI table on page 96 shows a 48% reduction against the 2022 baseline as 2025 progress, a 50% reduction by 2030 as the later target, and no interim 2025-2029 target. Cross-check from the E1 tables: Scope 1 of 207 tCO2 plus location-based Scope 2 of 660 tCO2 gives 867 tCO2 in 2025 (page 112), about 48% below 1,663.

No Scope 3 target or adaptation target is set. The statement does not say the target was externally validated or tied to a named pathway.

Energy consumption and mix

Reference: page 112.

Total energy consumption in own operations was 2,461 MWh in 2025 (2024: 2,958).

All renewable consumption is purchased electricity, heat, steam or cooling. The energy intensity datapoint for high climate impact sectors is marked "Not applicable" in the datapoint list (page 138).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 112-115.

Intensity per million of net revenue: 54 location-based (2024: 198) and 46 market-based (183) (page 115). Market-based Scope 2 is near zero because "Starting in 2021, the Group consumes green electricity under a contract signed with its supplier"; the 12 tCO2 is the Thessaloniki building (page 112).

Scope 3 (pages 113-115): purchased goods and services 2,095 tCO2e, capital goods 1,007, fuel- and energy-related activities 387, investments 50, employee commuting 110, business travel 70, downstream leased assets 43. The fall from 9,274 is attributed mainly to "the update of emission factors applied under the spend-based approach" (EXIOBASE v3.11 against v3.8.2), page 113.

Policies related to own workforce

Reference: pages 117-119.

Six instruments are described. Four are Board-approved and monitored by the Human Resources and Administrative Support Division: the Human Resources Policy (talent, training, performance, fair remuneration, health and safety, harassment prevention, diversity, employee representation), the Voluntary Benefits Policy, the Health and Safety Policy (covers employees, management, Board members, visitors and third parties on the premises; run with an Occupational Safety Engineer and a workplace doctor) and the Anti-harassment Policy (aligned with Greek law and ILO Convention No. 190). The Human Rights Statement sets commitments tied to the UN Guiding Principles, the Universal Declaration of Human Rights, OECD Guidelines and ILO Conventions. A Gender Equality Plan is in place, and the Group received the SHARE Equality Label in March 2022.

Gaps the Group states itself (page 119): it "does not maintain a standalone Human Rights Remedy Framework", and no standalone policy covers human trafficking, forced labor or child labor. The Code of Business Conduct, Procurement Policy and Anti-Fraud Policy are used instead.

Taking action on material impacts on own workforce

Reference: pages 120-121.

Health and well-being (page 120): early identification and management of psychosocial risks; a group life and health insurance scheme; the "Axizo" program, with a 24/7 helpline run by psychologists for employees and family members plus online counseling on mental health and nutrition; a voluntary blood donation program; and an Occupational Pension Fund (TEA), operating since 2020, that receives regular and ad hoc employer contributions.

Learning (pages 120-121): financial support for postgraduate studies, professional certifications, seminars and conferences, built on a 70/20/10 development model (on-the-job learning, mentoring, formal training) plus annual mandatory training. The annual Excellence Awards and Scholarship Program funds university studies for employees' children (page 121).

The Group links its approach to the Great Place to Work® certification. The statement gives no budget, headcount reached or effect measured for these actions, and does not describe how it checks that actions avoid creating negative impacts.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 121; same table on page 96.

The targets are "formally approved by the Board" and informed by the double materiality assessment, in which employees took part through working groups and the stakeholder questionnaire (page 121).

The 2025-2029 female employee target is printed as above 40% on page 121 and as at least 40% on page 96; the 2030 target is at least 45%. The gender pay gap here excludes the CEO. The S1-16 table prints 19% for 2025 including the CEO (page 124). The tables carry targets but no base year or description of how progress is tracked.

Characteristics of the undertaking's employees

Reference: pages 121-122.

Headcount at 31 December 2025: 245 (2024: 254), all in Greece (page 122). Interns are excluded: 5 in 2025, 0 in 2024 (page 121).

By gender: 138 men and 107 women (2024: 141 and 113), none recorded as other or not reported (page 122).

Turnover: 22 employees left in 2025 (2024: 13), a rate of 9% (2024: 5%) (page 122). The statement gives no explanation of the rise.

Collective bargaining coverage and social dialogue

Reference: page 122; union representation on page 119.

100% of employees are covered by collective bargaining agreements, in both 2025 and 2024 (page 122). All employees are in Greece (page 122).

On social dialogue, the S1-2 section says the workforce "is also represented by a formally established employees' union", which supports collective representation and dialogue (page 119). The S1 impact table lists "freedom of association, social dialogue, union representation, worker representation bodies" among the practices behind a positive working conditions impact (page 116).

Diversity metrics

Reference: page 122; Board diversity on page 91.

Age (31 December, page 122): under 30: 20 employees (8.2%; 2024: 18, 7.1%); 30 to 50: 116 (47.3%; 126, 49.6%); over 50: 109 (44.5%; 110, 43.3%).

Top management (page 122): 13 people, of whom 7 men (54%) and 6 women (46%), unchanged from 2024. The same 46% share appears in the S1-5 target table, where the group is labeled the Executive Committee (page 121).

Board (page 91): 72.7% male and 27.3% female, unchanged from 2024.

The statement does not report a gender split across all management levels beyond top management.

Adequate wages

Reference: page 123.

The Group "ensures that employee wages meet or exceed relevant labor benchmarks by complying with national legislation, applicable collective agreements, and recognized industry standards" (page 123). It describes "structured internal remuneration processes" and periodic reviews "to assess alignment with market practices and living-wage expectations".

The disclosure is narrative. It gives no benchmark name, no wage level and no percentage of employees paid above or below the benchmark, and it does not say whether any employees earn less than an adequate wage. All employees are in Greece (page 122).

Social protection

Reference: page 123.

All employees are enrolled in the national social security system, which gives protection against income loss from "sickness, unemployment, work-related injury, disability, parental leave, and retirement" (page 123). The Group adds a private medical insurance plan. The arrangements "apply for the entire workforce, with no exclusions for any employee group in relation to the risks covered".

The Group also runs an Occupational Pension Fund (TEA), operating since 2020 (page 120).

Persons with disabilities

Reference: page 123.

1% of employees were persons with disabilities at 31 December 2025, and 1% in 2024, "subject to legal restrictions on collection of data" (page 123). On a headcount of 245 (page 121), the rounded 1% corresponds to only a handful of people.

The S1 impact table lists "employment and inclusion of persons with disabilities" among the practices behind a positive equal-treatment impact (page 116). No target for employment of persons with disabilities is set in the S1-5 table (page 121).

Training and skills development metrics

Reference: page 123.

Average training hours fell by 8 for men and 9 for women. The statement gives no reason for the drop and no training hours by employee category.

The qualitative side sits under S1-4: a 70/20/10 development model, financial support for postgraduate study and certifications, and annual mandatory training (page 120).

Health and safety metrics

Reference: pages 123-124.

The tables give counts only. No accident rate is printed, and the statement does not describe the one recordable accident in 2025 or explain why it produced no lost days.

The Health and Safety Policy is Board-approved and run with an Occupational Safety Engineer and a workplace doctor (page 117).

Work-life balance metrics

Reference: page 124.

100% of employees are entitled to family-related leave (2024: 100%). 3% of entitled employees took it in 2025 (2024: 2%) (page 124).

The note explains that parental, maternity and paternity leave come through the social security schemes and company policies, that the Group "provides enhanced leave entitlements and family-support measures that go beyond the minimum legal requirements", and that the Group's Equality Plan promotes equal access. The statement gives no split of leave taken by gender.

Compensation metrics (pay gap and total compensation)

Reference: page 124; related target on page 121.

The remuneration ratio is the highest-paid individual's annual total remuneration divided by the median annual total remuneration of all employees, excluding the highest-paid individual (page 124).

The S1-5 target table shows a gender pay gap of 13% for 2025, which excludes the CEO (pages 96 and 121), against targets of below 12% for 2025-2029 and below 10% from 2030. The two figures use different scopes and the statement does not reconcile them. The ratio rose from 13 to 20 with no explanation given.

Incidents, complaints and severe human rights impacts

Reference: pages 124-125.

All values are zero in both 2025 and 2024:

• incidents of discrimination: 0
• complaints filed through channels for the own workforce to raise concerns: 0
• complaints filed with OECD National Contact Points: 0
• fines, penalties and compensation for discrimination incidents: EUR 0
• severe human rights issues and incidents connected to the own workforce: 0, including cases of non-respect of the UN Guiding Principles and OECD Guidelines: 0
• fines, penalties and compensation for severe human rights incidents: EUR 0

The EU Taxonomy minimum safeguards section also says: "As indicated by the DMA during the reporting period no human rights violations occurred" (page 104). Channels are described under S1-3 (page 120).

Business conduct policies and corporate culture

Reference: pages 126-128.

The Board "approves and oversees the entire business conduct framework" (page 126). Instruments (pages 126-128):

• Code of Business Ethics: approved by the Board, reviewed by Human Resources with the Compliance Unit, published on the Group's website.
• Anti-Fraud Policy: covers all organizational units and binds shareholders, employees and persons acting under the Group's control; extends to suppliers, consultants and other partners. The Compliance Unit drafts and trains; Internal Audit audits.
• Conflict of Interest, Gifts & Hospitality, Anti-bribery, market abuse and confidential information policies: Board-approved, with a Board Secretary register of Board members' conflicts.
• Whistleblowing Policy: for employees and associated third parties, with confidential or anonymous channels; Internal Audit manages cases under the Audit Committee's authority, citing Law No. 4990/2022 on protection of persons reporting violations of EU law (page 128).
• A Board policy on education and continuous development of Board members, executives and employees.

The statement describes the policies in detail but sets no target for them. This section gives no count of whistleblowing reports; complaints through own-workforce channels are reported as 0 under S1-17 (page 124).

Targets related to business conduct

Back-filled from the business conduct chapter (pages 126-129), where effectiveness is tracked through monitoring rather than a stated target. G1-3 became a standalone DR only in the 2025/2026 ESRS; no numbered G1 targets section exists under the 2023 ESRS this report applies.

No quantified business conduct target is set. Effectiveness is tracked in other ways:

• The Board "monitors adherence to the framework, reviews significant incidents or allegations of misconduct, and requires corrective or disciplinary actions where necessary" (page 126).
• Internal Audit "conducts regular and ad hoc audits to monitor its effective implementation" of the Anti-Fraud Policy, and regularly audits the procedures under the Conflict of Interest policy (page 127).
• Compulsory annual training ends with understanding tests that feed the individual assessment (page 128).
• Outcomes are reported as zero convictions and zero fines for corruption and bribery in 2025 and 2024 (page 129).

The statement does not say how often the Board reviews these results or who owns the outcome measures.

Incidents of corruption or bribery

Reference: pages 128-129; minimum safeguards on page 105.

The EU Taxonomy minimum safeguards section adds: "During the reporting period no bribery or corruption incidents occurred" (page 105).

The G1-4 text lists the mechanisms that prevent, detect and investigate incidents: the Anti-Fraud Policy, conflict of interest rules, whistleblowing mechanisms and the Code of Ethics (page 128).