Impresa SGPS

The role of the administrative, management and supervisory bodies

Composition of administrative, management and supervisory bodies

Board of Directors composition (2023-2026 term)

The Board of Directors consists of eight permanent members:

• Chairman: Francisco José Pereira Pinto de Balsemão
• Deputy Chairmen:
  • Francisco Maria Supico Pinto Balsemão
  • Pedro Simões de Almeida Bissaia Barreto
• Chief Executive Officer: Francisco Pedro Presas Pinto de Balsemão
• Members:
  • Manuel Guilherme Oliveira da Costa
  • Maria Luísa Coutinho Ferreira Leite de Castro Anacoreta Correia
  • Ana Filipa Mendes de Magalhães Saraiva Mendes
  • Catarina do Amaral Dias Duff Burnay

Executive vs. non-executive split

• Executive members: 1 (12.5%) - Francisco Pedro Presas Pinto de Balsemão (Chief Executive Officer)
• Non-executive members: 7 (87.5%)

Independence

Among the seven non-executive members, four are considered independent (57.14%) based on criteria in point 18.1 of Annex I of CMVM Regulation 4/2013 and article 414(5) of the Commercial Companies Code:

• Manuel Guilherme Oliveira da Costa
• Ana Filipa Mendes de Magalhães Saraiva Mendes
• Pedro Simões de Almeida Bissaia Barreto
• Catarina do Amaral Dias Duff Burnay

Gender split

The Board of Directors includes:

• Male: 4 members
• Female: 4 members (50%)

Audit Committee

The Audit Committee, elected for the 2023-2026 term, consists of three non-executive members of the Board of Directors:

• Chairman: Manuel Guilherme Oliveira da Costa
• Members:
  • Maria Luísa Coutinho Ferreira Leite de Castro Anacoreta Correia
  • Ana Filipa Mendes de Magalhães Saraiva Mendes

The majority of Audit Committee members, including its Chairman, are considered independent under paragraph 5 of Article 414 of the Commercial Companies Code and recommendation IV.2.4 of the Corporate Governance Code endorsed by the IPCG (revised in 2023).

Board activities and frequency of meetings

Audit Committee meetings

During 2024, the Audit Committee held 13 meetings, always attended by all its members. These meetings were also regularly attended by the Impresa Group's Statutory Auditor, the Managing Director and CFO of its executive team, and the Coordinator of the Risk Committee.

Specific roles assigned

At the meeting of the Board of Directors held on 2 July 2012, the position of Chief Executive Officer was created with responsibility in all areas, which is maintained in the 2023-2026 term by deliberation of the Board of Directors elected in 2023, at its meeting of 30 May 2023. This position is held by Francisco Pedro Presas Pinto de Balsemão.

Sustainability-related expertise and oversight

Francisco Pedro Presas Pinto de Balsemão (Chief Executive Officer) has professional experience in Human Resources, Legal and Sustainability:

• Director of Human Resources (September 2009 to September 2011)
• Director of Human Resources and Legal Affairs (October 2011 to September 2012)
• Human Resources, Legal and Sustainability COO (October 2012 to March 2016)

Independence and effectiveness arrangements

Statutory Auditor

Deloitte & Associados, SROC, S.A. ("Deloitte"), ROC number 43, registered at the CMVM under number 20161389, represented by Luís Miguel Baptista da Costa, ROC number 1602, registered at the CMVM under number 2016121, was elected by the General Meeting of Shareholders, on the proposal of the Audit Committee, as the Statutory Auditor of Impresa, SGPS, S.A. for the 2023-2026 term of office.

The Audit Committee represented the company in dealings with the Statutory Auditor and ensured adequate conditions for provision of its services. In 2024, the Audit Committee held eight meetings with Deloitte to regularly monitor the work of the Group's statutory auditor. In 2025, the Committee met with the external auditor 5 times up to the date of signing the report.

Audit Committee regulations

In May 2023, the Audit Committee approved its Regulations for the 2023-26 term of office. At the end of 2024, it reassessed the need to revise it, but no new changes were made.

Related party transactions policy

At the end of 2024, the Audit Committee assessed the Policy for the Assessment and Control of Transactions with Related Parties and the Prevention of Conflicts of Interest, and made no changes to it.

In compliance with this policy, the Audit Committee verified in 2024 that transactions with related parties reported to it were made within the scope of Impresa's normal business activity and under normal market conditions.

Qualifications and experience of board members

The company considers that the diversity, essence and comprehensiveness of the profiles of the members of these bodies are suitable to the sound performance of their duties, ensuring effective follow-up, supervision, oversight and assessment of the company's activity and management.

Board members include individuals with:

• Law degrees and legal expertise
• Engineering degrees (Electrotechnical, Computer Engineering, Telecommunications)
• Business Management and Economics qualifications
• PhD and academic positions in Communication Sciences and Management/Accountancy
• Extensive experience in media, banking, telecommunications, and corporate management
• Professional qualifications as Statutory Auditor (ROC)
• International experience and board positions across multiple sectors

Integration of sustainability-related performance in incentive schemes

Information on the remuneration policy, approved at the General Shareholders' Meeting under the terms of the Remuneration Committee's proposal, is detailed in chapter "D. REMUNERATIONS" of the Corporate Governance Report.

Remuneration structure and performance period

The remuneration policy for the management bodies based on a multiannual variable remuneration model with payment deferred over 3 years, seeks to ensure the pursuit of strategic objectives and to align the long-term vision for the Group with the interests of management.

Multi-annual variable remuneration is based on the following cumulative criteria for achievement during a given Assessment Period (corresponds to a financial year of the company):

• a) Positive assessment of performance, conducted by the Corporate Governance Committee;
• b) Achievement of a consolidated value of Net Remunerated Debt;
• c) Achievement of a consolidated value of EBITDA.

Performance criteria

The Corporate Governance Committee assesses the performance based on the following criteria: Communication, Improvement and Innovation, Responsibility, Collaboration and Teamwork, Decision Making, Leadership and Orientation towards the future, Meeting Budget and Strategic Plan Objectives.

Integration of sustainability KPIs

In this sense, performance is not evaluated based on specific objectives and/or impacts directly related to the social and environmental pillars.

Strategy, Business Model and Value Chain

Impresa is the holding company of a group consisting of Impresa and its subsidiaries ("Group"). The Group operates in media, namely through the broadcasting of television shows and the edition of publications in paper and in digital format.

The Group has already initiated several strategic initiatives aimed at achieving sustained improvements in its operating margin. These initiatives focus on enhancing technological efficiency and organizational structure, simplifying and optimizing internal processes, reducing content production costs, and permanently lowering overhead expenses. As part of this new cycle, the Group is implementing a plan to redefine its cost base, aiming for a reduction of approximately 10% over the next four years.

In a second focus area, Impresa will concentrate on specific revenue streams, enhancing its client offerings with targeted advertising tools. The company will also continue to develop partnerships and strategic collaborations to capitalize on commercial opportunities. This approach will expand your market reach, enhancing the distribution and monetisation of your content.

Business Segments

Television SIC recorded total revenues of €157.5m and operating costs fell by 0.2% to €139.2m. EBITDA amounted to €18.2m corresponding to an EBITDA margin of 11.6%.

Publishing Impresa Publishing's revenues decreased by 5.1% in 2024, reaching €23.4m. Operating costs fell by 6.3%, due to the reduction in production costs of the Expresso newspaper. Impresa Publishing's EBITDA was €2m.

Others (Infoportugal) Infoportugal recorded revenues of €1.6m, representing a growth of 4% compared to 2023.

Interests and views of stakeholders

Impresa maintains close relations with its stakeholders, which include the players in the value chain mentioned above, as well as the Group's employees, investors and financial entities, industry associations, local communities and public authorities.

Stakeholder engagement process

Information on how Impresa integrates the interests and points of view of stakeholders into the company's strategy and business model is detailed in chapter 1.11. "Description of the processes for identifying and assessing material impacts, risks and opportunities".

The way the Group manages its vast and complex value chain is fundamental to maintaining the continuity of its companies' activities and guaranteeing the quality of its products and services.

Frequency and channels of engagement

The frequency of interaction varies depending on the stakeholder and the needs of each moment, and can be daily, periodic or one-off. In this sense, the administrative, management and supervisory bodies can receive information directly from stakeholders or through the results of surveys and studies carried out by Impresa or external entities.

Communication channels

We should also mention the transversal channels of permanent communication that make up the media outlets owned by the Group, as well as Impresa's institutional website (www.impresa.pt) and the websites of the various brands.

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

Overview

In 2025, Impresa launched the 'Impresa 2028' project, marking a new cycle aimed at sustainably addressing the latest changes in media consumption habits and the global competitive landscape.

The impacts, risks and opportunities identified are intrinsically linked to the strategy and business model, having been substantiated through the operational context and knowledge of the dynamics of the sector.

In 2024, a materiality analysis of the topics relevant to Impresa Group was carried out for the first time in alignment with the European Sustainability Reporting Standards (ESRS) and, for this reason, it is not possible to make a direct comparison of the material topics with those of the previous reporting period.

The process of identification of the material topics and subsequent consultation was accompanied and approved by the Executive Committees of the operating subsidiaries and the Chief Executive Officer of Impresa.

Given its dynamic and changeable nature, the list of material topics and the DMA process may be revisited and adjusted in future years in order to ensure that the Impresa Group's strategy continues to evolve according to the needs and expectations of its stakeholders.

Result of materiality analysis

As a result, 12 material IROs were identified: seven positive impacts and two negative impacts, two financial opportunities and one financial risk, which resulted in the identification of 10 material topics for the Impresa Group. The nine material impacts are real, so no potential impacts were identified as material.

List of material IROs

Interaction with strategy and business model

Social pillar

In the social pillar, the focus on strengthening relationships and promoting positive impacts on its readers, viewers, listeners and other consumers stands out, in addition to the commitment to improving conditions for its employees and attracting and retaining talent.

Within the scope of their journalistic activity, SIC and Expresso scrupulously comply with the principles on which the quality of their content is based and the trust placed in them by the public, such as editorial responsibility, ethics and pluralism, which are set out in their Editorial Statutes and Journalistic Codes of Conduct and are ensured by their respective Editorial Directions and Editorial Boards. This pillar also prioritises fact-checking and projects to continuously improve the accessibility of content, in favour of a more informed and less unequal society.

The important contribution made by media companies to public visibility and debate on sustainability, and to raising public awareness of issues with social and environmental impacts, examples of which, in the case of Impresa, are the various award-winning journalistic reports by SIC and Expresso, as well as projects such as the SER (Sustainable. Ecological. Responsible.) initiative, area of Expresso dedicated exclusively to sustainability, as well as the publicising of various social solidarity actions through SIC Esperança, the Private Social Solidarity Institution whose work cuts across the Impresa Group.

Environmental pillar

On the environmental front, Impresa actively promotes and adopts a series of measures, particularly in terms of improving the energy efficiency of its facilities, renewable energy production and purchasing policy, aimed at reducing the impact of its activities on the environment, with a focus on the sustainable use of resources, monitoring greenhouse gas emissions and gradually reducing its carbon footprint.

Governance and digital transition

As part of the digital transition, Impresa continues to focus on monitoring information security risks, promoting training and the adoption of cybersecurity and data protection procedures.

Concerning corporate governance, Impresa seeks to follow the best practices, guidelines and recommendations established in the law and in the Corporate Governance Code of the Portuguese Corporate Governance Institute (IPCG), particularly with respect to the Group's remuneration policy, which is primarily governed by principles of meritocracy, reasonableness, sustainability, consistency and utility, in order to stimulate the improvement of the Impresa Group's economic and financial conditions, ensuring that remuneration, namely variable remuneration, is an instrument for implementing long-term business strategy.

Sustainability-indexed financing

In 2024, SIC, a subsidiary of the Group, announced its commitment to two sustainability targets. These objectives, related to the increase in the number of annual hours of content with Portuguese sign language and reducing greenhouse gas emissions, were formalised in the Sustainability-Indexed Financing Framework, which sought to align the objectives of diversifying SIC's funding sources and pursuing its strategy of extending the average maturity of the debt with its commitment to sustainability. The SIC ensured independent external verification of the KPIs values for the base year considered for both targets.

Board of Directors oversight

The 12 material impacts, risks and opportunities identified in the double materiality analysis (DMA) process are a coherent picture and aligned with the group's strategic objectives, with the global risk analysis and with the objectives previously assumed, as well as with the reality of the sector.

The Board of Directors reviews and approves the sustainability report annually, which includes information on key metrics and initiatives undertaken during the previous financial year. Decisions regarding policies, actions, goals and commitments are taken on a timely basis, whenever relevant, by the Board of Directors and/or Executive Committee of the operating subsidiaries, when applicable.

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

Methodology

The double materiality analysis (DMA) exercise was conducted at the level of the Impresa Group, providing an integrated perspective of the various business areas (top-down approach), following the guidelines of the Corporate Sustainability Reporting Directive (CSRD) and associated standards (ESRS). Guidelines set out in the EFRAG IG 1 Materiality Assessment implementation manual (final version May 2024) have also been taken into account.

The process followed these steps:

1. Peer benchmarking and analysis of relevant internal and external information to understand the context of the Impresa Group and its value chain and to define the list of potentially relevant sustainability topics to be used as a basis for the mapping of IROs;
2. Definition of environmental, social and governance IROs for analysis, taking into account the basic reference and with the addition and adjustment of sub-themes and sub-sub-themes specific to the Impresa Group;
3. Valuation of IROs based on the parameters defined in the CSRD directive;
4. Clearance of material topics that have associated at least one IRO with valuation above the materiality threshold established in the impact and/or financial materiality.

Inputs to the assessment

The following inputs were used in the assessment:

• Peer benchmarking
• Analysis of relevant internal and external information
• ESRS guidance and EFRAG IG 1 Materiality Assessment implementation manual (final version May 2024)
• Information sources from sustainability reports from representatives of the value chain, with special emphasis on the supply chain and first-tier suppliers
• Internal actors (primarily)

Scoring criteria for impact materiality

The valuation factors used for the double materiality assessment were defined as established in the CSRD directive and associated cross-sectional ESRS standards.

For actual negative impacts:

• Materiality is based on the severity of the impact
• Severity is based on: scale, scope, and irremediability of the impact

For potential negative impacts:

• Materiality is based on the severity and probability of the impact
• Severity is based on: scale, scope, and irremediability of the impact
• In the case of a potential negative impact on human rights, the severity of the impact takes precedence over its likelihood

For actual positive impacts:

• Materiality is based on: scale and scope of impact

For potential positive impacts:

• Materiality is based on: scale, scope, and probability of impact

Scoring criteria for financial materiality

The materiality of financial risks and opportunities was assessed on the basis of a combination of:

• Likelihood of the risk or opportunity occurring
• Size of the potential financial effects (magnitude)

Threshold for materiality

Material topics are those that have associated at least one IRO with valuation above the materiality threshold established in the impact and/or financial materiality.

IROs analyzed

The following table shows the distribution of the IROs that were analysed under the DMA, by thematic pillar and by typology:

Material IROs identified

12 material IROs were identified: seven positive impacts and two negative impacts, two financial opportunities and one financial risk, which resulted in the identification of 10 material topics for the Impresa Group. The nine material impacts are real, so no potential impacts were identified as material.

Stakeholder involvement

With regard to stakeholder involvement, the exercise focused primarily on internal actors. Obtaining information along the value chain was based on consulting information sources, such as sustainability reports, from representatives of the value chain, with special emphasis on the supply chain and first-tier suppliers.

Integration with risk management

ESG risk management, in particular cybersecurity risk, is integrated into Impresa's Risk Management System and Risk Management Policy, described in points 50 to 55 of the Corporate Governance Report. Although the process of identifying material IROs does not exactly coincide with the global risk assessment model, it was accompanied by the Group's Risk and Sustainability Director, ensuring alignment and consistency between both processes and results.

Governance and validation

The process of identification of the material topics and subsequent consultation was accompanied and approved by the Executive Committees of the operating subsidiaries and the Chief Executive Officer of Impresa.

As part of the identification of sustainability impacts, risks and opportunities (IROs), the process of identifying material topics was monitored and validated by the Executive Committees of the operating subsidiaries and by Impresa's Chief Executive Officer.

Changes from previous period

The materiality assessment process has changed due to the adoption of the European Sustainability Reporting Standards (ESRS). Previously, materiality analysis followed the parameters of voluntary standards, such as the GRI, and differed in the identification methodology. Even so, in general, the topics identified as material are in line with previous analyses.

Dynamic nature

Given its dynamic and changeable nature, the list of material topics and the DMA process may be revisited and adjusted in future years in order to ensure that the Impresa Group's strategy continues to evolve according to the needs and expectations of its stakeholders.

ESRS Coverage

The Company did not provide a comprehensive ESRS content index or mapping table. Based on the report content, the main sustainability disclosures relate to governance and business conduct practices. The company has mentioned sustainability statements are included in section IX of the report, though detailed ESRS coverage mapping is not explicitly provided.

Business Conduct Policies and Corporate Culture

Corporate Governance Framework Impresa operates under a corporate governance framework detailed in the Corporate Governance Report included in section VIII of the annual report. The company has established a Board of Directors structure with both executive and non-executive members, including an Audit Committee.

Board Composition:

• Francisco José Pereira Pinto de Balsemão (Chairman of the Board of Directors)
• Francisco Maria Supico Pinto Balsemão (Deputy Chairman)
• Pedro Simões de Almeida Bissaia Barreto (Deputy Chairman)
• Francisco Pedro Presas Pinto de Balsemão (Member and Chief Executive Officer)
• Manuel Guilherme Oliveira da Costa (Member and Chairman of the Audit Committee)
• Maria Luísa Coutinho Ferreira Leite de Castro Anacoreta Correia (Member and Audit Committee)
• Ana Filipa Mendes de Magalhães Saraiva Mendes (Member and Audit Committee)
• Catarina do Amaral Dias Duff Burnay (Member)

Quality and Editorial Standards The Impresa brands are recognized for their quality on both national and international stages, emphasizing competitiveness of programming lineup and editorial excellence. They prioritize quality and differentiation of information and entertainment content, offering various formats tailored to different audiences.

Corporate Recognition Impresa moved up in the Merco Empresas ranking taking 22nd place among the 100 companies with the best corporate reputation. The Group once again stood out as No. 1 in the sector for Corporate Reputation and ESG Responsibility.

Trust and Reputation According to the Digital News Report 2024 by Reuters Institute and Oxford University, SIC and Expresso were among the media outlets whose news content the Portuguese trust the most, with Impresa being the only Portuguese media group with two brands to exceed 75% trust threshold. The respondents assigned confidence percentages of 76% to Expresso and 78% to SIC.

Prevention and detection of corruption and bribery

Impresa has anti-corruption and anti-bribery policies in place, in line with the United Nations Convention, implemented as part of its compliance programme. The following policies are applicable in the context of prevention and detection of corruption and bribery:

Risk Management Policy

Risk management is a process aimed at identifying, analysing, and mitigating risks that may expose Impresa to acts of corruption and related offences.

Key content:

• Identification of abstractly probable risks with reference to a macro perspective of the activity of all relevant entities
• Risk analysis using metrics of probability of occurrence, impact and level of risk, comprising three phases: analysis of inherent risk, identification of existing control and mitigation measures, and analysis of residual risk
• Risk mitigation through promotion and effective implementation of additional preventive and corrective measures

Plan for the Prevention of Risks of Corruption and Related Offences

Governance:

• A Regulatory Compliance Officer was appointed by the Board of Directors under Decree-Law 109-E/2021 and Council of Ministers Resolution 37/2021, who is responsible for executing, controlling and reviewing the Plan
• The Audit Committee (consisting of three non-executive directors, two of whom, including its chairman, are independent) monitors, supervises and evaluates the effectiveness of the internal control system, including matters inherent to the prevention of corruption and related offences

Key content - General preventive and corrective measures:

• Wide dissemination of the Regulatory Compliance Program
• Training sessions held every 24 months under the terms of the Training Plan
• Monitoring the implementation of the Regulatory Compliance Program
• Reinforcing the importance of hierarchical authorisation models and segregation of duties
• Reinforcement of the importance of complying with the duty of archiving
• Periodic assessment of the degree of knowledge of the Regulatory Compliance Program
• Periodic review of the Regulatory Compliance Program
• Preparation of the annual evaluation report on the implementation of the Regulatory Compliance Program

Risk assessment: Departments with an essentially internal support scope with little access to privileged information (including the Institutional Relations Department and Intelligence and Research Department) were assessed as having lower probability of corruption and related infractions. In the remaining departments, given ongoing relationships with external entities and higher volume of activities, the likelihood of corruption and related offences was considered more complex.

Monitoring:

• Preparation in October of an interim assessment report for situations identified as high or maximum risk
• Preparation in April of the year following the execution period of an annual assessment report, which includes the quantification of the degree of implementation of the identified preventive and corrective measures, as well as the forecast for their full implementation
• Monitoring is reported in the periodic Execution Reports of the Plan for the Prevention of Risks of Corruption and Related Offences

Public availability:

• The Plan for the Prevention of Risks of Corruption and Related Offences and the aforementioned reports are published on Impresa's website

Code of Conduct

Scope: All managers, employees and trainees

Key content:

• Regulations for the prevention of corruption and related infractions
• Most relevant concepts about ethics and the Code of conduct
• How employees should act in the exercise of their functions
• Procedures for reporting and handling irregularities

Training: Internal training programs ensure all managers, employees and trainees know and understand the regulations included in the Code of Conduct and the policies and procedures for the prevention of corruption and related infractions implemented.

Public availability: Approved by the Board of Directors and made available on Impresa's website

Regulation on Procedures to Follow in Reporting Irregularities

Public availability: Approved by the Board of Directors and made available on Impresa's website

Policy for the Assessment and Control of Transactions with Related Parties and Prevention of Conflicts of Interest

Public availability: Approved by the Board of Directors and made available on Impresa's website

Training Plan

Scope: All managers, employees and trainees

Key content:

• Training sessions held every 24 months
• Ensures employees know and understand the regulations that are part of the Code of Conduct and the policies and procedures for the prevention of corruption and related infractions
• Training covers the procedures for reporting and handling irregularities

Alignment with international standards

Impresa's anti-corruption and anti-bribery policies are in line with the United Nations Convention.

Incidents of corruption or bribery

Confirmed incidents

Impresa SGPS explicitly disclosed that there were no confirmed incidents of corruption or bribery during the 2024 reporting period.

As stated in section 4.1.5 of the sustainability statements:

"There were no convictions for breaches of anti-corruption and anti-bribery laws, nor were violations of anti-corruption and anti-bribery procedures and standards detected."

Convictions and fines

No convictions or fines were reported for the period.

Disciplinary actions

No employees were dismissed or disciplined for corruption or bribery-related matters.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery.

Investigation procedures and speak-up mechanisms

Impresa has established comprehensive mechanisms for the prevention, detection, and reporting of corruption and bribery:

Whistleblowing system: In 2023, the Board of Directors approved a new version of the Regulations on Procedures to be Adopted for Reporting Irregularities, published on the Impresa website. The system includes:

• Secure channels for submission and follow-up of complaints
• Guarantee of completeness, integrity and preservation of complaints
• Confidentiality of whistleblower identity or full anonymity
• Confidentiality of third parties mentioned in complaints
• Prevention of unauthorized access to reports

Oversight: The Audit Committee is responsible for receiving and processing reports of suspected irregularities occurring in Impresa Group companies, ensuring independence, impartiality, confidentiality, anonymity where necessary, data protection, and absence of conflicts of interest.

Reports received: As stated in the Corporate Governance Report: "Over the course of 2024, there were no communications under these Regulations."

Monitoring: Information on the monitoring of corruption-related matters is published in the periodic implementation report of the Plan for the Prevention of Risks of Corruption and Related Offences, available on Impresa's website.

Training and compliance framework

The Group maintains a comprehensive anti-corruption compliance programme including:

• Code of Conduct
• Plan for the Prevention of Risks of Corruption and Related Offences
• Regulation on Procedures to Follow in Reporting Irregularities
• Policy for the Assessment and Control of Transactions with Related Parties
• Mandatory training programmes for all managers, employees and trainees on ethics, Code of Conduct, and procedures for reporting irregularities (at least once every two years)

Political influence and lobbying activities

Political engagement approach

The Chairman of the Board of Directors is responsible for coordinating institutional relations, and the Institutional Relations Department reports to him.

The curriculum information and details regarding positions held simultaneously in other entities by the members of the Board of Directors and the Audit Committee are set out in sections 19 and 26 of the Corporate Governance Report.

Impresa maintained normal relations with the various regulatory and self-regulatory bodies, taking part in the debates on the topics of greatest interest and impact on the sector. At the same time, it monitored domestic and/or European Union legislative production, as well as government initiatives related to the media market.

Trade association memberships

To this end, the Group continues to be present on the governing bodies of the organisations mentioned below, having confirmed its position in the elections of the Portuguese Press Association and Visapress:

• AEM – Associação de Empresas Emitentes de Valores Cotados em Mercados [Association of Companies Issuing Securities Listed on Markets] (Chairman of the General Council)
• AIP/CE – Associação Industrial Portuguesa/Confederação Empresarial [Portuguese Industrial Association/Corporate Confederation] (Deputy Chairman of the Board of Directors)
• AMD – Associação de Marketing Direto [Direct Marketing Association] (Board of Directors)
• APCT – Associação Portuguesa para o Controlo de Tiragem e Circulação [Portuguese Edition and Circulation Control Association] (Deputy Chairman of the Board of Directors)
• APDC – Associação Portuguesa para o Desenvolvimento das Comunicações [Portuguese Association for the Development of Communications] (Board of Directors)
• APDSI – Associação para a Promoção e Desenvolvimento da Sociedade de Informação [Association for the Promotion and Development of the Information Society] (General Council)
• API – Associação Portuguesa de Imprensa [Portuguese Press Association] (Chairman of the General Meeting)
• CAEM - Media Analysis and Studies Committee
• ERC – Entidade Reguladora para a Comunicação Social [Social Communication Regulatory Entity] (Advisory Board)
• Fórum para a Competitividade [Competitiveness Forum] (Advisory Board)
• GEDIPE – Associação para a Gestão Coletiva de Direitos de Autor e de Produtores Cinematográficos e Audiovisuais [Association for the Collective Management of Copyrights and Cinematographic and Audiovisual Producers] (Chairman of the General Meeting)
• ARP – Auto Regulação Publicitária [Advertising Self-Regulation] (Chairman of the General Meeting)
• MAPINET – Movimento Cívico Anti Pirataria na Internet [Internet Anti-Piracy Civic Movement] (Board)
• NP – Auto Regulação Publicitária [Advertising Self-Regulation] (Chairman of the General Meeting)
• OBERCOM – Observatório da Comunicação [Communication Observatory] (Board of Directors)
• PMP – Plataforma de Media Privados [Private Media Platform] (Chairman of the General Council)
• VISAPRESS – Cooperativa de Gestão de Conteúdos [Contents Management Cooperative] (Chairman of the General Meeting)

Main activities and focus areas

AMD – Associação de Marketing Direto [Direct Marketing Association]

In 2024, AMD carried out several initiatives, including changing its name, rebranding the Association, launching its new website, blog and social media presence (LinkedIn, Facebook, Instagram and YouTube).

The Statutes and Code of Conduct were also revised and reassociated with FEDMA - (Federation of European Data and Marketing), allowing AMD members, of which Impresa is a part, to benefit from an influential advocacy platform that acts directly in the regulation and policies that affect Direct and Digital Marketing in Europe.

APCT – Associação Portuguesa para o Controlo de Tiragem e Circulação [Portuguese Edition and Circulation Control Association]

The APCT continues to present quarterly data on traffic, duly certified and audited by BDO Binder. Over the course of 2024, 24 audits were carried out on the Print Circulation and Digital Circulation of the main titles.

As in recent years, special attention has been paid to the control and certification of the traffic of digital editions, which is growing, and to promotional pricing practices.

ARP – Auto Regulação Publicitária [Advertising Self-Regulation]

ARP's Activity Plan for 2024 was based on three strategic pillars, namely, influencer Marketing, Service rendering and Representativeness, and in five areas subject to continuous development, Digital, Environmental marketing, Regulations, Training, and Intervention at the International Level. SIC continued to chair the Board of the General Meeting.

There was an increase in litigation of approximately 20% and an increase in preventive activity of 2% compared to the same period last year, with a total of 510 pieces of advertising analysed.

CAEM - Comissão de Análise e Estudos de Meios [Media Analysis and Studies Committee]

In 2024, four meetings of the Media Analysis and Studies Committee (CTC TV) were held, during which topics such as the overall management of the television audience panel, the analysis of actions proposed by GFK to reduce potential errors from Simulcast, and the presentation by GFK of the Router Meter solutions available in the different markets they are present in were discussed.

MAPINET – Movimento Cívico Antipirataria na Internet [Internet Anti-Piracy Civic Movement]

The year 2024 was a year of modernisation, of betting on platforms that interconnect, targeting the needs and operational improvement of MAPINET in order to increase blocking requests and know-how about the evolution of piracy in Portugal.

Removals:

• 447 cases on Social Media relating to: Posts (306); Profiles (42); Private Groups (8); Pages (1); Public Groups (5). These cases amount to 3.7 million views, 425,000 members and 179,000 followers
• 129 Groups or Channels on Telegram (59 for books; 44 for newspapers and magazines; 25 for films and series and 1 for music. These groups amount to 1,532,555 identified members and 1,212,683 impacted, which correspond to 234,134 book files, 42,476 magazines, 47,301 newspapers and 10,398 films and series.

Monitoring:

• 4,634 websites monitored

Blocks:

• 3,822 live event links
• 700 requests for websites to IGAC - General Inspection of Cultural Activities

OBERCOM – Observatório da Comunicação [Communication Observatory]

In 2024, the Observatório (OBS*) magazine continued its activity by ensuring the regular and timely publication of its 4 annual volumes and two special issues.

Since 2015, OberCom has collaborated with the Oxford Reuters Institute and is the partner entity for the annual "Digital News" survey in Portugal funded by the Reuters Institute.

In 2024, OberCom continued to be an active and engaged member of the activities of the Informal Group on Media Literacy (GILM), having participated in 30 working meetings within this group.

Payment practices

Impresa is committed to sustainable and responsible business practices. As part of this commitment, Impresa defines in its procedures that, in the case of commercial transactions, the payment term should not exceed, as a rule and on average, 60 days from the date of receipt of the invoices.

This procedure, which applies across the board, is without prejudice to the possibility of the parties expressly agreeing to a different deadline, taking into account the existence of contracts or partnerships with specific characteristics, regulatory requirements by sector or geography, strategic services and/or critical situations.

Standard contractual payment terms

60 days from the date of receipt of invoices (as a general rule and on average for commercial transactions)

Average time to pay invoices

These statements do not report the average time it takes for Impresa Group to make payments, nor the percentage of payments in line with the general payment conditions. The materiality of these indicators is being analysed, as well as the possibility of inclusion in future reports.

Legal proceedings for late payment

As a reflection of the fulfilment of the contractual deadlines established with the partners, Impresa does not face, to date, any lawsuit for late payment.

Number of lawsuits for late payment: 0