Inditex

Inditex has a Corporate Governance System that fully complies with Spanish law and the CNMV Good Governance Code, and in 2024 obtained the highest score in AENOR's Good Corporate Governance Certification. The General Meeting of Shareholders sits above the Board of Directors, which is the highest decision-making, supervisory and monitoring body. At year end the Board had ten members: one executive director (CEO Oscar Garcia Maceiras) and nine non-executive (four proprietary, five independent), chaired by non-executive Chair Marta Ortega Perez. Independent directors represent 50% and women hold 50% of Board seats. There is no direct worker representation, which is not mandatory under Spanish law. The Board has committees composed only of non-executive directors: Audit and Compliance, Nomination, Remuneration and a Sustainability Committee (created 2019). Advisory bodies include the Cybersecurity Advisory Committee and the Social Advisory Board. A Management Committee, chaired by the CEO, includes the Chief Sustainability Officer. The Board oversees strategy, targets, risks and opportunities, supported by a Board Skills Matrix, diversity policies and the ITX Board Academy training programme. The Audit and Compliance Committee oversees financial and non-financial risks and the Risk Map, and the Internal Audit function reports to it.

Sustainability is integrated at the highest level. The Board of Directors approves the sustainability strategy, supported by executive bodies (CEO, Management Committee, Chief Sustainability Officer and the Sustainability Operating Committee) and advisory bodies (Sustainability Committee, Audit and Compliance Committee, Social Advisory Board and Ethics Committee). The CEO reports at least quarterly to the Board. The Chief Sustainability Officer is part of Senior Management, sits on the Management Committee, chairs the Sustainability Operating Committee, and reports quarterly on human rights, social, environmental and product health and safety targets. The Sustainability Committee monitors strategy and practices and supervises preparation of regulated and non-regulated sustainability information, coordinating with the Audit and Compliance Committee, which has ultimate oversight of integrity and independent verification. A double materiality assessment is carried out annually and its findings are reported to the Sustainability Committee. In 2024 the Board addressed matters including approval of action plans and roadmaps (Fibres Plan, Cotton Strategy, Climate Transition Plan toward net-zero), supply chain and cluster analysis, the new regulatory framework on reporting and due diligence, and innovation. The Audit and Compliance Committee reviewed the scenario-based Risk Map (2025 update), work-related, geopolitical, third-party and logistics risks, information security, compliance, criminal risk prevention, the Ethics Line and data protection.

Inditex's Directors' Remuneration Policy for 2024, 2025 and 2026 was approved at the AGM on 11 July 2023. Directors' remuneration in their capacity as such is entirely fixed. The CEO also receives remuneration for executive duties, comprising a fixed component and short-term (annual) and long-term (multi-year) variable components payable in cash and/or shares, both linked to sustainability targets. For 2024, sustainability, corporate governance, diversity and compliance criteria had a total weight of 15% in the CEO's annual variable pay, with performance criteria covering recycled fibres, supply chain transformation (water, energy, waste, chemicals), strategic partnerships, traceability, renewable energy, paper bag charging and fibre innovation. In the long-term incentive plans in force, sustainability metrics weight 25%, above the 20% market median, measured over at least three years across a sustainability index (fibre consumption, water, decarbonisation of scope 3 emissions and social criteria). Considering achievement, the weight of sustainability targets over the CEO's total variable remuneration was approximately 20%, and 72% over fixed remuneration. Sustainability targets are also a component of Senior Management and other key personnel variable pay. The AGM, Board, Remuneration Committee and Sustainability Committee each have defined roles in approving the incentives system.

Inditex's due diligence process identifies and prioritises potential sustainability-related negative impacts, including human rights and environmental aspects, throughout the value chain, incorporating findings into activities and designing tools to prevent and mitigate impacts. It is based on the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Due diligence is the second cornerstone of Inditex's human rights strategy, alongside the Human Rights Policy and grievance mechanisms. Given its importance, nature and scale, the supply chain is treated as a priority area, managed through a compliance programme that includes social and environmental audits, corrective action plans and training, accompanied by the Workers at the Centre social strategy. Grievance mechanisms help identify potential negative impacts so the Company can react and mitigate risk. The disclosure includes a table mapping the core elements of due diligence to their location in the Report: embedding in governance, strategy and business model (ESRS 2 GOV-1); identifying and assessing adverse impacts (ESRS 2 IROs); engaging affected stakeholders and taking and tracking actions across the topical standards S1 to S4, E1 to E5 and G1.

Inditex operates an Internal Control System on Sustainability Reporting (ICSR) to ensure the quality, accuracy and transparency of the information in the Report, in compliance with Act 11/2018 and the new CSRD framework. The system was developed using synergies with the Internal Control over Financial Reporting System (ICFR) and both follow the COSO international standard for internal control, with the ICSR equipped with more comprehensive controls to match new regulatory frameworks. The ICSR covers the control environment, risk assessment related to drafting the report, specific control activities, supervision of the main indicators, and information and communication. The Board of Directors holds ultimate responsibility for the existence and maintenance of an adequate ICSR. Risks are understood as the absence or insufficiency of stable, defined processes that can lead to errors, incompleteness and unreliable information. Controls include tools that automatically analyse regulatory compliance, governance layers and automated workflows, indicator manuals with construction methodology and measurement criteria, a reporting model, consistency and completeness checks, and secure supplier management systems. Each year the ICSR area assesses control execution, identifies improvements and compiles a report for management and Internal Audit. Internal Audit may perform operational reviews, and the Statement is subject to external auditor verification.

Industria de Diseno Textil, S.A. is the parent of the Inditex Group, listed on all four Spanish stock exchanges. Its main activity is the distribution and sale of fashion and household products through seven retail concepts: Zara, Pull&Bear, Massimo Dutti, Bershka, Stradivarius, Oysho and Zara Home, each operating an integrated online and store model, mostly directly owned with franchises in certain markets. The Group is present in 214 markets and in 2024 generated revenue of 38,632 million euros. At year end it employed 162,083 people across 56 markets and 170 nationalities. Its main sphere is retail sale of textiles, accessories, footwear and jewellery, and it does not significantly operate in fossil fuel, chemicals, weapons or tobacco sectors. The business model spans design through sale in stores and online, built on four drivers: fashion proposal, shopping experience, sustainability and talent, with proximity manufacturing in Spain, Portugal, Morocco and Turkiye. The value chain covers upstream design, raw materials, manufacturing (a supply chain of 6,615 factories in 50 markets, non-owned suppliers organised into 10 clusters), logistics and distribution, and downstream store and online sales, product use and end of life. Levers of change include the Climate Transition Plan, Supply Chain Transformation Plan and Fibres Plan, with a Roadmap toward net-zero by 2040.

Inditex's stakeholders are entities or groups related to the Company throughout its value chain and in the communities where it operates, with the capacity to influence the Company. Its relationship with them is based on transparency and permanent dialogue, guided by the Sustainability Policy, the Code of Conduct, the Code of Conduct for Manufacturers and Suppliers, the Human Rights Policy and the Sustainability Stakeholder Relations Policy approved in 2024. Six main stakeholder groups are identified and mapped to standards: our teams (S1), customers (S4), suppliers (G1), community (S3), environment (E1 to E5) and shareholders (Consolidated Directors' Report). The relationship is organised into identification of topics and stakeholders, classification and prioritisation, and definition of a strategy for each group with objectives, commitments and dialogue tools. Tools include alliances with governments, trade unions, academic institutions and civil society, framework agreements with UNI Global Union, IndustriALL and the International Apparel Federation, plus the Sustainability Committee (2019), the Social Advisory Board (2002), the corporate website and the annual materiality assessment. Views feed into strategy, targets and due diligence. There were no significant changes to strategy or business model during the year. In 2024 Inditex joined initiatives such as RE100 and Pack4good, and the CEO was appointed co-chairman of The Fashion Pact steering committee.

Through its materiality assessment Inditex identifies material impacts, risks and opportunities (IROs): impacts capture how its own activity and value chain affect the environment and people including human rights, while risks and opportunities capture potential financial implications. In 2024 the Group identified 47 material impacts, risks and opportunities, providing greater detail than prior years and continuing the ESRS-based review begun in 2023. The material IRO table covers all ten topical standards with material items under each: E1 climate change, E2 pollution, E3 water resources, E4 biodiversity and ecosystems, E5 resource use and circular economy, S1 own workforce, S2 workers in the value chain, S3 affected communities, S4 consumers and end-users, and G1 business conduct. Examples span GHG emissions, chemical use, water withdrawal and discharge, ecosystem degradation, circularity and waste, quality employment and adequate wages, working conditions and value chain worker rights, community investment, personal data and product safety, and grievance mechanism effectiveness, corruption and supplier relations. Each IRO has its own identification code. Company-specific topics beyond the ESRS, such as cybersecurity, are also covered. IROs are assessed across short, medium and long term. Anticipated financial effects are currently disclosed only for climate change (E1), with methodology being developed for E2 to E5. No risks or opportunities were identified that would trigger a material change in balance sheet valuations next year.

In 2024, for the fourteenth consecutive year, Inditex conducted its materiality assessment applying a methodology based on the European Sustainability Reporting Standards (ESRS), IG1 Materiality Assessment Implementation Guidance and EFRAG recommendations, also following GRI 3: Material Topics. The assessment uses a double materiality focus, examining both impacts on people and the environment (impact materiality) and risks and opportunities for the Company (financial materiality). Internal and external stakeholders play a key role through a Materiality Advisory Network including universities (Leeds, Oxford), ZDHC, Conservation International, the Pacific Institute, ECODES, the Climate Group, the UN Global Compact, the IOE, the ETI and UNI Global Union, plus workshops and specialists Risilience (with the University of Cambridge Centre for Risk Studies) and Shift. The process has three main phases: identification of IROs (drawing on due diligence results, the risk map, stakeholder dialogue, the ESRS 1 AR16 topic list and the LEAP approach); assessment of impact materiality (scale, scope, remediability, likelihood, with human rights probability assumed 100%) and financial materiality (magnitude of financial effect and probability, aligned with the Risk Map and Integrated Risk Management System); and validation by management, the Sustainability Committee, the Social Advisory Board and ultimately the Board. The methodology was updated in 2024 for full accommodation to EFRAG guidance, moving stakeholder engagement from surveys to interviews.

IRO-2 is presented jointly with IRO-1 under the disclosures on the materiality assessment process. Inditex includes a table of contents in the Annex presenting the disclosure requirements covered in the Report and their location. In keeping with CSRD disclosure requirements, the Company has also identified those paragraphs of ESRS 2 General Information, Appendix B that are material according to its assessment, along with their location in the Report. Readers are directed to the annexes, including the Table of contents required by Directive 2013/34/EU and the Table of contents of information deriving from other EU legislation. This content index reflects the outcome of the double materiality assessment, under which 47 material IROs were identified and all ten topical ESRS standards (E1, E2, E3, E4, E5, S1, S2, S3, S4 and G1) are material, with no topical standard assessed as not material. The materiality results form the basis of the Report, which was prepared by the Board of Directors following favourable reports from the Audit and Compliance Committee and the Sustainability Committee.

Inditex published its Climate Transition Plan in 2023, consistent with its science-based targets (SBTs) and the Paris Agreement 1.5C pathway. In 2024 the SBTi approved Inditex's new SBTs, including a global net-zero emissions target by 2040 that entails cutting scope 1, 2 and 3 emissions by 90% versus 2018, with the remaining 10% neutralised per SBTi guidelines. Near-term goals are to reduce scope 1, 2 and 3 emissions by 53% by 2030 versus 2018 (scope 1 and 2 by 95%, scope 3 by 51%), with an intermediate milestone of 20% by 2027. The plan uses the 'announced policies' emissions scenario and sets decarbonisation levers of Reduction, Neutralisation and Mitigation beyond the value chain (self-consumption, PPAs, sustainable building, Supply Chain Environmental Transformation Plan, Fibres Plan). The CEO is responsible for defining and approving the strategy, which the Board of Directors approved; the plan was presented to the Social Advisory Board and Sustainability Committee. The Group is not excluded from EU Paris-aligned benchmarks.

Inditex updated its Sustainability Policy and published a new Energy Policy, both approved in February 2025 (the Energy Policy approved by the Board of Directors on 4 February 2025). It also approved a new Water Policy and Ecosystems and Biodiversity Policy. The Sustainability Policy sets the commitment to continuous improvement in climate change adaptation and mitigation and a fair transition. The Energy Policy commits to responsible energy sourcing and management to reduce GHG emissions in own operations and the value chain, promotes energy efficiency, the transition to alternative and renewable energy sources, and the gradual elimination of fossil fuels, and includes measures to improve energy infrastructure resilience. Its scope covers the entire Group, the Board of Directors, and people who provide services or collaborate with the Group, and promotes alignment of suppliers and factories. The Sustainability department and its chief officer are accountable for implementation. Third-party standards referenced are the Paris Climate Agreement and the TCFD. Other listed policies include the Sustainability Stakeholder Relations Policy.

Actions centre on the Supply Chain Environmental Transformation Plan 2024-2027, the Fibres Plan, and circularity and efficiency programmes. In own operations Inditex reduced more than 434,000 tonnes of scope 1 and 2 GHG versus 2018, and since 2022 has sourced 100% of the electricity at its own facilities from renewable sources. Self-consumption photovoltaic plants and a wind turbine with combined installed capacity above 5 MW produced 9,962 MWh in 2024; virtual power purchase agreements (VPPA) of 10 and 12 years totalling 136 MW installed capacity are in development for 2025. The supply chain plan reduced more than 560,000 tonnes of scope 3 GHG in the purchased goods and services category versus 2018, with an estimated 4.9 million tonne reduction by 2030. A new Green to Wear requirement obliges manufacturers to design decarbonisation plans meeting at least 4.2% average annual carbon footprint reduction (scope 1 and 2). Self-consumption investments in 2024 were 2.3 million euros (Outer Port Wind Facility, A Coruna) and 1.4 million euros (photovoltaic at Laracha and Zaragoza). The Group recorded 411 million euros of Taxonomy-aligned CapEx in environmentally sustainable activities.

Targets are aligned with the Paris Agreement 1.5C ambition and approved by the SBTi. The 2040 target is net-zero GHG emissions across the value chain, reducing scope 1 and 2 emissions by 95% and scope 3 by 90%. The 2030 target is to cut total emissions by at least 53% versus 2018, reducing absolute scope 1 and 2 by 95% and scope 3 by 51%, with an intermediate 20% reduction across all scopes by 2027. Base year is 2018. Total emissions were 10,528,872 t CO2eq (2018), 9,962,965 t CO2eq (2024), with targets of 4,941,090 (2030) and 1,028,108 (2040) t CO2eq. Scope 1 and 2 were 495,584 (2018) and 60,912 (2024) t CO2eq, targeting 24,779 for both 2030 and 2040. Scope 3 was 10,033,288 (2018) and 9,902,054 (2024) t CO2eq, targeting 4,916,311 (2030) and 1,003,329 (2040). In 2024 emissions fell 5% versus 2018 on SBT categories. Other action-line targets include at least 90% alternative fuels in maritime transport by 2025, tripling self-consumption capacity by 2027, 40% of own electricity from self-consumption/PPAs by 2027 (60% by 2030), eliminating coal in the supply chain by 2030, and 50% renewable electricity in manufacturing by 2030 (100% by 2040).

In 2024 Inditex's global energy consumption was 1,670,262 MWh (6,012,942 GJ), of which 1,543,884 MWh came from renewable sources, a 92% renewable share (93% in 2023; 42% in the 2018 base year). This represented a 27% reduction in relative energy consumption per square metre versus 2018 (636 MJ/m2 in 2024). Total fossil energy consumption was 126,377 MWh, an 8% share (58% in 2018). Fossil breakdown: crude oil and petroleum products 21,633 MWh, natural gas 97,288 MWh, purchased electricity/heat/steam/cooling from fossil sources 7,457 MWh, coal 0 MWh. Renewable breakdown: purchased renewable electricity/heat/steam/cooling 1,534,720 MWh, self-generated non-fuel renewable 9,107 MWh, renewable fuel including biomass 57 MWh. Nuclear consumption was 0 MWh. Total relative energy consumption was 177 kWh/m2 and 43 Wh/euro (base year and prior year figures were recalculated). Under NACE the sector falls in group '47.5', considered high climate impact. No non-renewable energy was self-generated during the year.

GHG emissions follow the GHG Protocol. In 2024 gross scope 1 emissions were 59,572 t CO2eq (76,136 in 2018). Gross location-based scope 2 was 433,654 t CO2eq and gross market-based scope 2 was 1,340 t CO2eq (419,448 in 2018). Total gross scope 3 was 13,427,762 t CO2eq. The dominant scope 3 category is C1 purchased goods and services at 6,696,995 t CO2eq, of which 38% relates to raw material extraction (down 21% versus 2018 via the Fibres Plan); other large categories are C11 use of sold products 3,250,659 and C4 upstream transportation and distribution 2,614,230 t CO2eq. Total location-based GHG emissions were 13,920,988 t CO2eq and total market-based 13,488,674 t CO2eq. Across the SBT-covered categories, 2024 emissions fell 5% versus 2018, and scope 1 and 2 emissions fell 88% versus 2018. In 2024 more than 90% of renewable energy certificates met CDP requirements (33% bundled, 67% unbundled). Emissions intensity was 349 g CO2eq per euro (market-based scope 1+2+3), and 6 kg CO2eq per m2 (market-based scope 1+2).

Based on future climate scenario analysis, Inditex estimated short- (0-5 years), medium- (5-10 years) and long-term (more than 10 years) physical and transitional climate-related risks. The impact of each scenario represents a cash flow at risk derived from possible emissions pathways, adjusted by each scenario's probability of occurrence and without yet including mitigation measures. Risks are assessed across five emissions scenarios (No policies over 4C, Current policies 3C, Policies announced 2.5C, Paris Agreement 2C, Paris Agreement ambition 1.5C) for transition risk types (technology, reputation, legal liability, market, regulatory) and physical risk types (disruption of facilities and physical assets, market disruption, drop in raw materials), rated Minor to Strong. Over the next five years the financial impacts of physical risk are relatively limited to disruptions at key facilities, mainly across the value chain, with a low present probability of catastrophic physical tail risks. The most impactful weather events are heatwaves and drought or water stress, followed by coastal flooding. The methodology is based on that of the University of Cambridge's Centre for Risk Studies. Inditex notes the assessment is subject to numerous uncertainties and represents its best estimate.

Inditex frames its pollution policies through five documents: the Sustainability Policy, Ecosystems and Biodiversity Policy, Energy Policy, Water Policy and Sustainability Stakeholder Relations Policy. The aim is to avoid emitting substances of concern across the value chain, most notably in manufacturing. Under the Water Policy the group promotes wastewater management, reduces emissions to soil and freshwater of substances such as nitrogen and phosphorous, and considers microfibre shedding in manufacturing and domestic laundry. To minimise substances of concern, the Green to Wear standard includes a chemical management system (CMS), and suppliers must adhere to the Manufacturing Restricted Substances List of the Zero Discharge of Hazardous Chemicals (ZDHC) foundation before entering a commercial relationship. The List, by Inditex, run through ZDHC's Gateway platform, classifies chemical products to ensure garment safety and improve discharge quality. Other standards include Clear to Wear (finished-product chemical safety, incorporating EU REACH and aligned to AFIRM's RSL), i+Cosmetics and i+Food Contact Materials. Own logistics operations use an ISO 14001 certified Environmental Management System, and the supply chain is covered by environmental audits and Corrective Action Plans.

Inditex implements pollution actions directly, by restricting chemical substances and minimising microfibre shedding, and indirectly, by reducing energy and water use in supply chain production. The core vehicle is the Supply Chain Environmental Transformation Plan 2024-2027. On wastewater treatment, it applies ZDHC Wastewater Guidelines, requiring all wet processing facilities with direct discharge to reach foundational level by July 2025 and progressive level by July 2026. On chemical products, the ZDHC Roadmap to Zero programme targets 95% of chemical inventory certified to ZDHC level 3 by 2026. Compliance verification uses the Picking, APPLABs, Minilabs and Root Cause Analysis (RCA) programmes. In 2024, 67,562 Picking inspections and 831,896 analyses and tests were carried out (60,685 and 821,934 in 2023), with initial compliance of 98.4% (98.2% in 2023) and 99.4% for chemical safety. APPLABs conducted 63 on-site audits, 62 comparison exercises and 7,823 samples; Minilabs performed 3,283 inspections and 28,933 tests; and 31 RCA audits were carried out (36 in 2023). R&D+i programmes include The Colouring, The Materials and The Microfibers by Inditex. Costs are recorded as operating expenses and are not material as CapEx or OpEx.

Inditex states that its pollution-related impacts are located in the supply chain and at the end of life of products, so the group does not have direct contribution targets of its own. Instead it launches collaboration initiatives with its supply chain, materialised through targets related to climate, water consumption, wastewater treatment, chemicals, waste management and raw materials. Management of air pollution generated in the supply chain is described as closely linked to climate change, with commitments set out in the Climate Transition Plan. Through the Supply Chain Environmental Transformation Plan, the group aims to reduce the environmental impact of textile manufacturing and any air, water or soil pollution deriving from production processes. The Fibres Plan contains goals linked to the use of lower-impact raw materials, which reduce impact during cultivation and sourcing, easing pressure on soil and water and also affecting the use and end-of-life phases. Further detail is cross-referenced to the Supply Chain Environmental Transformation Plan (E2-2), the Climate Transition Plan (E1-1) and the Fibres Plan (E5-3).

Inditex reports that impacts from pollutant emissions are located across the value chain, mainly in supply chain manufacturing processes rather than its own operations. It states it is not currently possible to quantify significant emissions to air (non-greenhouse gases), water and soil, citing a lack of robust information and estimation methodologies with firm, contrasted criteria in the textile industry, which precludes science-based or proxy estimates. The group is working to compile this data and disclose it in future reporting periods. On microplastics, the double materiality analysis places identified impacts primarily in the value chain during manufacturing and use of articles. Inditex considers applicable legal restrictions on microplastics and seeks alternatives, but reports no related metrics because of the lack of a robust industry methodology to calculate these emissions and difficulty in obtaining data from the value chain. In qualitative terms it has estimated the group's microfibre emission impacts at various value chain stages and addresses their possible mitigation. Going forward it plans to work with reference organizations to define appropriate measurement criteria enabling future metrics.

Inditex explains that substances of concern can harm the environment and people and may be contained in the formulation of chemical products used in supply chain processes, facilities and products. Safety data sheets (SDS) for chemical products indicate the presence of substances of concern generally above a concentration threshold of 0.1%. The group notes the term 'substances of concern' also covers substances classified by the CSRD as 'substances of very high concern'. Because manufacturers provide limited data on formulated substances, it cannot confirm whether a substance's absence reflects a concentration below thresholds or genuine exclusion, and there is a lack of homogeneous international requirements on classification and SDS format affecting traceability outside the EU. Consequently Inditex cannot quantify the volume of these substances generated or used, and cannot make science-based or proxy estimates. It considers controlling chemicals used in manufacturing the best way to avoid these substances. Initiatives that help minimise their use include The List, by Inditex; the ZDHC Manufacturing Restricted Substances List (MRSL); the Green to Wear chemical product management module; digitalisation of the chemical inventory; and the ZDHC Performance InCheck Report.

Inditex's water policies are led by its new Water Policy, approved by the Board of Directors on 4 February 2025, supported by the Sustainability Policy, Ecosystems and Biodiversity Policy, Energy Policy and Sustainability Stakeholder Relations Policy. The Water Policy enshrines a commitment to water valuation across own operations and the value chain, with key contents covering minimising the water footprint, protecting and restoring ecosystems, promoting access to water, sanitation and hygiene, ensuring good water governance and driving industry transformation. It is accountable to the Sustainability Department and its chief officer, and references the UN High Level Panel on Water's principles on valuing water. Action lines address use and supply (prioritising recycled water and alternative sources, reducing withdrawal and discharge), treatment (exploring innovative technologies and water reuse), pollution prevention (advancing towards prevention, reduction and elimination of discharges into water, with attention to hazardous chemicals), lower-water-impact design across the production chain, and consumption in areas at water risk, including an ambition to set contextualised reduction targets based on geolocation. Inditex aligns with the CEO Water Mandate and supports the Fashion Pact, Alliance for Water Stewardship and Arctic Corporate Shipping Pledge.

Inditex conducts water actions on its own and with stakeholders to reduce impacts located primarily in its supply chain. Water withdrawal is identified as its main impact, especially in high water risk areas, addressed through a strategy that minimises negative impacts (via the Supply Chain Environmental Transformation Plan and the Green to Wear and Care for Water standards) and contributes positive impact (via the CEO Water Mandate). The Supply Chain Environmental Transformation Plan 2024-2027 is structured around five priority environmental impacts: water consumption, wastewater treatment, chemicals, waste management and carbon footprint. To reduce supply chain water consumption, the Care for Water (CFW) consumption standard, part of Green to Wear, provides benchmark values classifying wet processing facilities by consumption level. From November 2024 facilities must reach a 'good' level, and from July 2025 an 'excellent' level. Support mechanisms include the Best Available Techniques (BAT) tool, investment in more efficient machinery and wastewater recycling. Collaborations include WWF, the CEO Water Mandate, the Alliance for Water Stewardship and Water.org (improving access to drinking water and sanitation in Bangladesh, Cambodia and India), plus industrial partners such as BASF, CHT, Pulcra, Jeanologia and DyStar.

Inditex reports water consumption for its supply chain as entity-specific information. It notes the ESRS define water consumption as water withdrawn and not discharged back to the environment (for example evaporated water or water incorporated into articles), which in its business is very low because almost all water withdrawn is discharged at the end of use in supply chain production. Therefore water withdrawal is the most representative metric, though the group uses the term water 'consumption' as it is the most common in the sector. Consumption in own operations is not material given the nature of the activity; it is material in the value chain, especially at the production stage in wet processes such as dyeing, washing, finishing and printing. Water consumption stood at 78 litres/kg garment in 2024, down from 101 litres/kg garment in the 2020 base year, a 22% reduction. In its 2024 materiality assessment Inditex analysed the location of supply chain facilities relative to water stressed areas and found Turkiye, Mainland China and Morocco to be the main markets with wet processing facilities exposed to material water risk.

Inditex reports a water target of reducing relative water consumption in its supply chain by 25% in 2025 compared with 2020, aiming also to reduce emissions associated with managing, handling and heating water during manufacturing. The target is linked to its Sustainability Policy and Water Policy. Progress is measured in litres/kg garment: the 2020 base year was 101, the 2024 current year was 78 (a 22% reduction), and the 2025 target year is 76 (a 25% reduction). The target applies to all geographies where manufacturers operate and is especially relevant in locations deemed to be at water risk, helping address physical risks such as production disruption from water scarcity and transition risks tied to regulatory change. To obtain water for production, suppliers and manufacturers withdraw from various river basins across the group's global footprint. Inditex has located and assessed water-related impacts for both its own operations and supply chain to identify facilities located in water stressed river basins. Further detail on scope, methodology and changes is provided in the Methodological Annex.

Inditex reports its policies related to biodiversity and ecosystems centred on the new Ecosystems and Biodiversity Policy, approved by the Board of Directors on 10 September 2024, which replaces the previous Forest Product Policy and broadens its scope. It is supported by the Water Policy, Sustainability Policy and Sustainability Stakeholder Relations Policy. Key commitments include no deforestation, no degradation or conversion of natural ecosystems, and the betterment of biodiversity and ecosystem health, plus preservation and recovery of ancient and endangered forests. The scope covers the entire Group, people who collaborate with it (including the Board), and product and non-product suppliers posing material risk, plus their supply chain. Accountability sits with the Sustainability department and its chief officer. Third-party standards referenced are the IPBES Global Assessment Report and the Kunming-Montreal Global Biodiversity Framework, developed in consultation with WWF, Conservation International and Canopy. The policy refuses materials linked to deforestation and primary or endangered forests, favours lower-impact sourcing, and addresses impacts on the hydrosphere (rivers, lakes, wetlands, aquifers and oceans) through the Water Policy.

Inditex structures biodiversity actions on the SBTN and TNFD AR3T framework (Avoid, Reduce, Restore & Regenerate, Transform). Avoid: forest raw materials such as wood and pulp must be FSC, PEFC or FLEGT-certified, and it works only with cellulose-pulp fibre suppliers classified as 'green shirts' in Canopy's Hot Button Report (partnership since 2014). Reduce: decarbonisation, pollution reduction and water optimisation in the supply chain, including the Supply Chain Environmental Transformation Plan 2024-2027 and the Fibres Plan/Cotton Strategy. Restore: projects with WWF (Mexico, China, Brazil, Bolivia), Conservation International's Mountains to Mangroves (India, Bhutan, Nepal, Bangladesh), SOS Mata Atlantica and Kew Gardens; in 2024 it reached 622,878 hectares in restoration or restored, 352,484 hectares more than 2023, allocating 7.2 million euros. Regenerate: regenerative agriculture with Organic Cotton Accelerator and the Regenerative Fund for Nature; in 2024 it reached 135,656 hectares in regeneration or regenerated, 10,942 more than 2023, allocating 6.2 million euros. No biodiversity offsets were used.

Inditex's key biodiversity target is to protect, restore, regenerate or otherwise improve biodiversity across five million hectares throughout its value chain and beyond by 2030. Progress reported: 758,534 hectares in the current year 2024 against the 5 million hectare target for 2030. The target is linked to the Sustainability Policy and the Ecosystems and Biodiversity Policy, and falls under the 'Restore & Regenerate' category of SBTN's action framework, adapting the mitigation hierarchy. It is delivered in collaboration with expert organisations such as WWF and Conservation International, and is aligned with the goals of the European Union Biodiversity Strategy for 2030 and the Kunming-Montreal Global Biodiversity Framework. Related commitments highlighted include GHG emission reduction and climate neutrality targets and, in line with the Fibres Plan, fostering use of lower-impact fibres and materials, plus a target of a 25% reduction in water consumption in the supply chain by 2025 under the Water Policy, given water's importance for biodiversity and ecosystems.

For metrics related to biodiversity and ecosystems change, Inditex reports that its materiality assessment identified certain of its own facilities located near biodiversity-sensitive areas, but it has not found any material negative impacts in those areas. It has, however, identified potential impacts related to its value chain. Consequently, Inditex states it is in the process of compiling new information to supplement the measurement of this impact in its reporting for subsequent years, in accordance with the transitional provision in the CSRD set out in ESRS 1, section 10.2. No quantitative biodiversity metrics are provided under this disclosure requirement for the current year; the company cross-references its IRO-1/SBM-3 disclosure on material biodiversity and ecosystem-related impacts, risks and opportunities.

Inditex reports interrelated policies on resource use and circular economy: the Sustainability Policy, the Ecosystems and Biodiversity Policy and the Sustainability Stakeholder Relations Policy. These guide a business model that favours lower-impact raw materials over conventional ones, and promotes recyclability, durability, repairability and proper waste management. The Sustainability Policy enshrines a commitment to circularity from product design through end of life, applying the waste hierarchy, seeking to reconvert waste into new resources and to create secondary raw materials to avoid virgin raw materials. The Ecosystems and Biodiversity Policy promotes best practice in sourcing and using natural materials, prioritising lower-impact materials, inputs and products. This ambition is enshrined in the Fibres Plan, which envisages 100% lower-impact textile fibres versus conventional ones by 2030, with recycled and next-generation fibres playing a key role. The Sustainability Policy also requires that animal products come from animals treated ethically per the internationally accepted 'Five Freedoms' of animal welfare.

Inditex's circular economy actions centre on innovation, product life extension and waste management. The Sustainability Innovation Hub (launched 2020, plan to 2030) in 2024 encompassed more than 300 emerging companies, analysed over 20 new startups and completed more than 40 life cycle analyses, supporting the Fibres Plan target of 25% Next Gen fibres by 2030 en route to 100% lower-impact fibres. Featured investments include INFINITED FIBER (Infinna recycled fibre), GALY (in vitro cotton), EPOCH (enzyme recycling) and Circ; in 2024 it ran pilots for more than 30 innovations, launched a CIRC x Zara collection and purchased the first 2,000 tonnes of Circulose. The Materials by Inditex programme works with BASF, YKK, Velcro and Freudenberg (Loopamid x Zara, Haptex x Tempe). The Cotton Strategy targets 25% organic or regenerative-agriculture fibres by 2030. Use and end-of-life actions include Zara Pre-Owned (repair, resale, donation) available in 17 markets, the Refashion bonus in France, and a clothing collection programme with more than 91 local organisations.

Inditex's main resource-use target is the Fibres Plan: 100% of textile fibres used in products to have a lower environmental impact than conventional fibres by 2030. In 2024, total lower-impact (preferred) fibres reached 73% against the 100% 2030 target, broken down as: next-generation fibres 0% (target 25%), textile fibres from conventional recycling 39% (target 40%), fibres from organic or regenerative agriculture 23% (target 25%), and other preferred options 10% (target 10%). Short-term targets: 100% lower-impact polyester by 2025 (89% in 2024) and 100% lower-impact linen by 2025 (74% in 2024). Autumn/winter 2024 lower-impact fibre shares include organic cotton (OCS/GOTS) 44%, recycled cotton (RCS/GRS) 17%, cotton in conversion 8%, European linen 74%, and recycled polyester (RCS/GRS/Repreve/etc.) 89%. A second target is to provide circularity services such as Zara Pre-Owned in key markets in 2025, now under development in 17 markets after the United States was added in 2024.

In 2024, Inditex consumed 678,596 tonnes of raw materials used in its products (645,623 tonnes in 2023), broken down into 88% fibres and 12% non-fibres. Within fibres, 53% were natural, 37% synthetic and 10% artificial (man-made). By biological versus technical split, biological raw materials accounted for 57% and technical for 43%. By raw material in 2024: cotton 44%, man-made cellulosic fibres 8%, linen 2%, other biological 3%, polyester 26%, and other technical 17%. Recycled materials reached 33% of all fibres and other raw materials used in products in 2024 (up from 18% in 2023), coming from both conventional and next-gen recycling of post-consumer waste. In addition to product raw materials, an estimated 521,448 tonnes of materials were used in packaging in 2024, split 84% organic packaging and 16% technical packaging. Inditex notes it continues improving corporate systems to report the recycled content of packaging in greater detail. Manufacturing also requires chemicals and water at certain supply-chain facilities.

For resource outflows, Inditex frames its offer as affordable, high-quality, responsibly produced fashion advancing toward a circular economy model. On the recyclability of products, it states there is currently no standard industry methodology to calculate this comparably, so it is working with other players to report it in future. Likewise, it cites a lack of standardised frameworks for measuring product durability and repairability, and is participating as a member of the Technical Secretariat in developing the European Commission's Product Environmental Footprint (PEF). On packaging outflows, Inditex has chosen to eliminate single-use plastics reaching customers in product packaging and promotes collection of packaging for reuse or recycling, including a service letting Zara online customers in parts of Spain receive orders in reused boxes. The #BRINGYOUROWNBAG (#TRAETUBOLSA) initiative, present in 79 markets, has cut bags and envelopes handed out in stores by 48%; proceeds from charging for recycled-paper bags since 2021 total 120.5 million euros, of which 67 million euros was allocated to projects in 31 countries.

Inditex reports waste generated at its headquarters, logistics centres and own factories for 2024 (own stores excluded, but operationally controlled e-commerce centres now included). Total waste was 60,269 tonnes: cardboard and paper 38,413 tonnes (64%), plastic 8,352 tonnes (14%), wood 6,334 tonnes (11%), other non-hazardous 5,800 tonnes (10%), textile waste 1,054 tonnes (2%), metal 261 tonnes (0%) and hazardous waste 55 tonnes (0%). By treatment, 54,961 tonnes were diverted from disposal (hazardous 51 tonnes, 92%; non-hazardous 54,910 tonnes, 91%), of which recycling accounted for 54,669 tonnes (hazardous 18, non-hazardous 54,651), other recovery 26 tonnes and preparation for reuse 266 tonnes. Directed to disposal was 5,308 tonnes, including landfilling 4,990 tonnes and incineration with energy recovery 317 tonnes. In 2024, 9% of waste (5,600 tonnes) was diverted for operations other than recycling. Inditex holds 15 TRUE zero-waste certifications (nine Platinum, six Gold). Waste generated through the Group's own stores was estimated at around 116,965 tonnes in 2024.

Inditex structures its commitment to own workforce around corporate policies: Code of Conduct, Human Rights Policy, Diversity and Inclusion Policy, Global Anti-Harassment Policy, Occupational Health and Safety Policy, Compliance Policy regarding Personal Data Protection and Privacy, Information Security Policy, Ethics Line Procedure, Global Policy on Internal Reporting Channels and Sustainability Policy. The Human Rights Policy is binding on employees and all with a relationship to the Group, prohibits forced and child labour, modern slavery and human trafficking, and sets a minimum employment age of 16. Policies align with the UN Guiding Principles on Business and Human Rights and OECD Guidelines. The Diversity and Inclusion Policy was approved 12 December 2017 and amended 14 December 2020; the Global Anti-Harassment Policy was approved 15 March 2022 and updated 7 November 2023; the Occupational Health and Safety Policy was approved 10 September 2019 and updated 13 December 2022, supported by an ISO 45001 certified management system. Inditex applies a zero-tolerance approach to discrimination. In 2024, 98,749 people accessed training on diversity and inclusion. The Ethics Line serves as the confidential grievance channel.

Inditex engages its workforce through social dialogue mechanisms, internal communication (INET, available in 23 languages), the Ethics Committee and the People department present in each market. The 'Your opinion matters to us' anonymous survey, launched in 2016 and sent to departing store employees, received around 22,000 responses in 2024. The question 'Would you recommend Inditex as a place to work?' obtained an average of 74% positive responses (71% in 2023) and 97% in Spain (93% in 2023). Inditex and UNI Global Union signed a Global Agreement in 2009 for decent work and labour rights, covering 100% of the Group's workforce and renewed in 2024 on its 15th anniversary; UNI represents more than 20 million workers across 150 countries. Responsibility for relationships with employees lies with the Chief People Officer, except the Ethics Line. The European Works Council was set up in 2019. Additional agreements include the 2023 State Collective Agreement in Spain and a 10 July 2024 agreement with Comisiones Obreras on senior staff working conditions.

Inditex identifies potential and actual negative impacts to prevent, mitigate and remedy them, using human rights due diligence processes and grievance mechanisms. The main communication and grievance channel is the Ethics Line, available to all teams and stakeholders, with concerns handled through the same procedure outlined in the Report. Workers may also use third-party reporting channels appointed by relevant authorities, including the institutions, bodies and agencies of the European Union. To ensure awareness of the Ethics Line, Inditex provides access via INET and its website and carries out training, awareness and communication activities forming part of the Compliance Training Plan, adapted to the risk profile of different employee groups. In 2024 the Group also ran awareness initiatives for store and subsidiary office workers, including specific signage announcing the Ethics Line in rest areas and common spaces.

Inditex's actions focus on guaranteeing equal pay, preventing the gender gap, minimising accidents and occupational diseases, protecting against harassment and providing training. Diversity and inclusion rests on four pillars: gender equality, LGBTQI+ inclusion, socio-ethnic inclusion and disability inclusion. The Women in Tech initiative recruited 58% women in junior programmes; non-binary gender options are available in 10 markets (0.02% non-binary, 0.50% unspecified). The SALTA socio-ethnic inclusion programme, present in 21 markets in 2024, has brought more than 1,900 people into teams since 2008, with over 4,000 people acting as mentors, trainers or tutors. The INCLUYE disability programme was created in 2021; the for&from initiative reached 16 stores. In 2024 Inditex delivered 3,292,787 training hours (2,782,830 in 2023), 20.3 hours per person (17.2 in 2023). It filled 70% of vacancies internally, promoting more than 9,300 employees (73% women, 27% men). Health and safety training involved 190,589 employees and 155,784 hours.

Inditex set a target to double the number of people with disabilities employed, framed within its membership of the ILO Global Business and Disability Network. Using base year 2021 (1,443 people employed) the 2024 target value was 2,886, and the value reached in 2024 was 3,142, exceeding the goal. The disability inclusion strategy rests on three priority areas: employability, direct recruitment and professional development; disability awareness and training; and accessibility of workplaces, inclusive shopping experience and transversal projects. Targets were set for short, medium and long term within the Shaping Today x Tomorrow initiative, involving a multidisciplinary accessibility working group. A prior diagnosis was made during 2022 of employability status in each market. Direct employability projects are grouped under the INCLUYE programme, working with Plena Inclusion in Spain and more than 70 national and international organisations. Data is sensitive, as some countries do not permit recording disability status, so the actual number may differ from the figure reported in certain markets.

At year-end 2024 Inditex had 162,083 people (161,281 in 2023), of 170 nationalities across 56 markets. By activity: Store 139,478 (85%), Central services 12,030 (7%), Logistics 9,981 (6%), Factories 594 (1%). By geography: Spain 49,915 (31%), Europe excluding Spain 79,286 (49%), Americas 18,743 (12%), Asia and rest of world 14,139 (9%). By gender: Women 118,698 (73%), Men 42,554 (26%), Non-binary 28 (0.02%), Others/Unspecified 803 (0.50%). By age: under 30 89,044 (55%), 30 to 50 66,560 (41%), over 50 6,479 (4%). Some 83% of the workforce is on permanent contracts (81% in 2023); 57% work part-time and 41% full-time. FTE workforce represented 78% of total jobs. Permanent employees numbered 133,983, temporary 28,100 and non-guaranteed-hour 1,886. In 2024, 138,152 leaves were recorded (144,930 in 2023), a turnover ratio of 88% (93% in 2023), with voluntary turnover 36% and non-voluntary 52%.

The percentage of Inditex's workforce covered by local collective bargaining agreements was 61% globally in 2024 (59% in 2023), while within the European Economic Area the figure was 84% (82% in 2023). In Spain, 100% of the workforce is covered by collective bargaining agreements, as in the previous year. Coverage varies by country, with EEA markets such as Austria, Belgium, Croatia, Slovenia, Spain, Finland, France, Italy, Luxembourg, Norway, the Netherlands, Portugal and Sweden in the 80 to 100% band. Inditex guarantees minimum working-condition guarantees worldwide regardless of collective bargaining coverage, reflected in the Code of Conduct and the Global Agreement with UNI Global Union, signed in 2009 and renewed in October 2024. The Human Rights Policy extends respect for freedom of association and collective bargaining to non-employees. The European Works Council, formally founded in 2019, published with Inditex a joint statement against gender-based violence on 25 November 2024.

Women represent 73% of Inditex's workforce, and in 2024, 77% of the Company's management positions were filled by women (78% in 2023). Several subsidiaries hold GEEIS (Gender Equality European and International Standard) certification; between 2018 and 2024 the global corporate Group and nine subsidiaries (Belgium, France, Italy, the Nordic hub, Germany, Ukraine, Bulgaria, Romania and the United States) were awarded it. Distribution by gender and job classification in 2024: Management 7,457 women (77%) and 2,210 men (23%); Supervisor 10,435 women (69%) and 4,617 men (31%); Specialist 100,806 women (73%) and 35,727 men (26%). Total workforce comprised 118,698 women (73%), 42,554 men (26%), 28 non-binary (0.02%) and 803 other/unspecified (0.50%). Senior Management includes seven women, representing 33.33% of members (31.82% in 2023). The average age of the workforce was 30.9 years (30.6 in 2023), with the youngest groups being the largest.

All of Inditex's workforce receive adequate wages, according to analysis based on applicable collective agreements, legal benchmarks or recognised methodological sources such as the Anker methodology. Further methodological detail is set out in the Report's Methodological Annex. Inditex operates a remuneration policy established according to the value each person contributes through professional experience, dedication and responsibility, with no discrimination on grounds of gender, age, culture, religion, race or other characteristic. Remuneration comprises a fixed component, determined by experience, dedication and responsibility, and a variable component linked to pre-established, quantifiable indicators tied to Company results and, for office employees, sustainability objectives. In stores, the most widely used variable remuneration system is the monthly sales commission scheme. In setting wages, Inditex takes into account international labour standards, national legislation and collective bargaining agreements, as well as the definition of the minimum living wage endorsed by the ILO Governing Body on 13 March 2024.

At the end of 2024, Inditex directly employed 3,142 people with disabilities (2,041 in 2023), representing 2% of the annual average workforce. The breakdown of people with disabilities in the workforce was: Women 1,923 (61%), Men 1,207 (38%), Non-binary 0 (0%) and Other/Unspecified 12 (0.4%), totalling 3,142 (100%). This figure exceeded the target to double the number of people with disabilities employed from the 2021 base of 1,443. The data linked to this metric is particularly sensitive: there are countries where it is not permitted to ask or record information on disability status, and others with regulatory limitations. Collection limitations include confidentiality, heterogeneous legislation and calculation-method discrepancies (number of people with disabilities on 31/01 divided by the average number hired in the last 12 months). As a result, the actual number may differ from the reported figure in markets such as the United Kingdom, Ireland, the Nordic countries, Switzerland, Spain, the United States, Canada, Australia and New Zealand.

From 1 February 2024 to 31 January 2025, Inditex delivered more than 3.3 million training hours to more than 2.5 million participants (more than 2.7 million hours and 2.2 million participants in 2023). Total training hours were 3,292,787 and participants 2,543,451, averaging 20.3 hours per person (17.2 in 2023). The number of unique people trained was 214,952 (214,187 in 2023), broken down as 155,964 women, 55,418 men, 40 non-binary and 3,530 other/unspecified. By job classification, hours per person were 23.9 for Management (231,490 hours), 20.9 for Supervisor (313,953 hours) and 20.0 for Specialist (2,747,344 hours). By gender, hours per person were 19.7 for women, 21.5 for men, 24.7 for non-binary and 47.7 for other/unspecified. By geographic area: Spain 730,780 hours (14.6 per person), Europe excluding Spain 1,675,659 (20.8), Americas 379,609 (20.3) and Asia and rest of the world 506,739 (39.5). Training is mostly delivered in-house through the Tra!n platform.

Inditex has implemented the ISO 45001:2018 management system since 2014; in 2024 it operated in 29 markets and 336 workplaces, covering 86% of the own workforce, with new certifications in Kazakhstan, Australia and France. Recordable accidents totalled 55 in 2024 (16 in 2023), comprising 43 for women and 12 for men. The frequency rate was 0.27 (0.08 in 2023) and the severity rate 0.01 (0.00 in 2023). Work-related health events totalled 548 (499 in 2023), comprising 21 occupational diseases (23 in 2023) and 527 other health events (476 in 2023). In 2024 and 2023 there were no fatalities resulting from recordable accidents or work-related health events among the workforce or other collaborators in any market. The number of days lost due to recordable work-related accidents, health events or deaths was 16,695 days in 2024 (17,605 in 2023). For non-employees working at Group workplaces under its supervision, seven recordable accidents and health events were recorded in 2024.

Inditex promotes work-life balance and co-responsibility across all markets. In Spain, measures are enshrined in the Equality Plans, including splitting leave periods for hospital stays or care of relatives, flexible hours for nursery adaptation, extended leave for personal matters and extended breastfeeding leave. In the United States, 16 weeks' paid leave for birth, fostering or adoption is available to people meeting minimum requirements, alongside care services and emotional, financial and health support. Markets including Greece, the United States, the United Kingdom, Italy, Germany and France apply flexible hours and extended care leave. The Group also promotes the right to digital disconnection under Spain's Data Protection Act. In 2024, 99% of the worldwide workforce was entitled to maternity, paternity or child fostering leave (99% of women and 99% of men), and 6% of those people took such leave (7% of women and 3% of men). Parental leave was taken by 9,322 employees: 8,252 women (89%) and 1,070 men (11%).

Global average remuneration at Inditex in 2024 was 30,850 euros gross annually (28,726 euros in 2023). By gender, women's average was 29,694 euros and men's 33,932 euros (27,831 and 31,196 euros respectively in 2023); Inditex notes these figures are not representative of equal pay because of the higher presence of women in lower-wage markets affected by exchange rates. The gender pay gap, based on median salary in each market including fixed plus variable pay, was 0.7% in favour of women in 2024 (0.5% in 2023, 0.4% in 2022). By geographic area the gap was Spain 1.1%, Europe excluding Spain 0.9%, Americas 0.4% and Asia and rest of world -1.3%. By job classification it was 1% for specialists, -3% for supervisors and -6% for management. Average remuneration was 85,586 euros for Management, 47,467 for Supervisor and 26,434 for Specialist. The ratio between the highest paid individual's total annual remuneration and the median of all employees was 196.

Inditex's Ethics Line is in place for reporting any infringement or irregularity concerning human rights, including potentially severe violations such as child labour or forced labour, in line with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines. In 2024, the Ethics Line (comprising the Global Ethics Line and various Local Ethics Lines) recorded a total of 791 cases, of which 280 were related to own people. Of the total cases reported in 2024, four cases of discrimination were confirmed. No inherently severe human rights-related incidents were confirmed for employees. Regarding the National Contact Points for OECD Multinational Enterprises, no reports were received, neither related to own people nor of any other kind. This year, no fines, penalties or damages were imposed for discrimination or human rights infringements materialising in 2024 in connection with own people.

Inditex's policies for value chain workers aim to foster respect for human rights in the supply chain, empower and support supply chain workers, and create social value. Key policies are the Code of Conduct for Manufacturers and Suppliers, Human Rights Policy, Code of Conduct, Sustainability Policy, Ethics Line Procedure and Sustainability Stakeholder Relations Policy. The Code of Conduct for Manufacturers and Suppliers sets minimum standards of ethical and responsible behaviour, and compliance is a prerequisite for any manufacturer or supplier to form part of the supply chain. The Human Rights Policy establishes respect for all universally recognised human rights, both labour and non-labour, across own operations and the value chain, and is binding on the workforce and value chain parties. The Code expressly prohibits forced or compulsory labour and child labour, applies zero tolerance for modern slavery and human trafficking, and sets a minimum recruitment age of 16 even where local law allows lower. Policies align with the UN Guiding Principles on Business and Human Rights. Grievance mechanisms include the Ethics Line, and regular periodic social audits verify compliance. Partnerships include the Global Framework Agreement with IndustriALL, ACT, the Ethical Trading Initiative and the International Apparel Federation.

Inditex engages value chain workers through several dialogue mechanisms to understand and act on actual and potential impacts. Its ten supplier clusters create local spaces for dialogue and collaboration on the ground. Regular audits at manufacturers and suppliers put teams in direct contact with workers and their representatives through interviews. A central tool is the Global Framework Agreement with IndustriALL Global Union, signed in 2007 and renewed in 2019, which fosters worker participation and respect for freedom of association and collective bargaining, provides a direct listening channel, and includes mechanisms for joint access to workplaces and dispute management. The Ethics Line allows reporting of potential non-compliance. The annual double materiality assessment incorporates the perspectives of expert organisations. Agreements include a Public-Private Partnership with the International Labour Organization. Collaborations are embodied in the Workers at the Centre strategy, monitored using general and specific indicators, with effectiveness also gauged through supplier and manufacturer audits and cluster communication. The Chief Sustainability Officer oversees stakeholder engagement. A specific focus targets vulnerable groups, including women, migrants, people with disabilities, and workers involved in raw material production.

Inditex identifies potential and actual negative impacts to prevent, mitigate and remediate them, implementing due diligence and grievance mechanisms. Main remediation tools are the Workers at the Centre strategy projects, Corrective Action Plans (CAPs) that support suppliers in correcting non-compliances detected through social audits, specific Remediation Plans for protection against child labour and safeguarding of refugees, and remediation measures under the IndustriALL Global Union collaboration. Value chain workers have access to the Ethics Line, managed the same way as for other stakeholders. The Code of Conduct for Manufacturers and Suppliers, which must be accepted to work with Inditex, designates the Ethics Line as a preferred and confidential channel, and requires manufacturers and suppliers to post the Code translated into the local language on their premises and to appoint a management representative responsible for its implementation. Compliance is verified through regular social audits. Workers can also use external grievance channels designated by competent authorities. The Framework Agreement with IndustriALL provides an additional mechanism operating through local affiliates and legitimate workers' representatives via an escalation process, and Inditex provided training for local affiliates in different countries to strengthen awareness of this mechanism.

Inditex's central action is the Workers at the Centre 2023-2025 strategy, based on respect for supply chain workers' human rights, with a goal to reach three million people by 2025. It is structured into five Priority Impact Areas: Social dialogue, Living wages, Respect, Health and Resilience. In 2024 the strategy reached 1,817,233 people, involved 2,429 suppliers and factories and delivered 35 initiatives and solutions. By PIA in 2024 (with cumulative since 2023): Social dialogue 670,281 (741,076), 325 suppliers/factories; Living wages 86,268 (100,454), 67; Respect 174,917 (222,240), 369; Health 1,313,217 (1,694,407), 1,806; Resilience 59,823 (69,804), 58. The Compliance Programme runs unannounced social audits (using own and Social & Labor Convergence Program methodology), Corrective Action Plans and training, with business relationships terminated for critical non-compliances. Remediation Plans cover child labour and refugee and migrant workers. Inditex conducted 776 monitoring visits in 2024 (821 in 2023). Partnerships include ACT, ETI, IndustriALL, International Accord, ILO, RISE and Shift, plus the EVOLVES initiative. In 2024 no inherently severe human rights violations were detected in the supply chain via the Ethics Line, and no material opportunities were identified. Financial resources are included under Operating Expenses.

Inditex has set the target of reaching three million people through its Workers at the Centre strategy between 2023 and 2025. This target is linked to the Human Rights Policy and its commitment to promote and respect human rights in own operations and the value chain. In the current period 2023-2024, 2.2 million people had been reached since 2023, against the 2025 target year figure of 3 million. To achieve this, Inditex designs projects based on the Theory of Change methodology within each of the five Priority Impact Areas, each with specific targets, aiming to guarantee respect for the human and labour rights of supply chain workers and to promote their well-being and that of their communities. A key factor in designing the strategy, targets and actions is close continuous collaboration and dialogue with specialist organisations and leading players in the value chain, which also allows Inditex to track how effective its actions are and define new areas for improvement. The Global Framework Agreement with IndustriALL provides a direct communication channel with supply chain workers through their representatives, giving insight into their needs and Inditex's performance.

Inditex's community policies apply to all affected persons regardless of proximity to its operations or value chain. The policies are the Community Investment Policy, Human Rights Policy, Ecosystems and Biodiversity Policy, Code of Conduct, Sustainability Policy, Ethics Line Procedure and Sustainability Stakeholder Relations Policy. The Community Investment Policy, approved by the Board of Directors in June 2014 and last updated on 3 May 2023, commits to improving community wellbeing, maximising community value generation and building strategic alliances, and sets a framework of priority activity areas (education, emergency relief and environment). It applies across the entire Group, is accountable to the Sustainability department and its chief officer, references the 2030 Agenda, SDGs and Paris Agreement, and involves the Social Advisory Board. The Human Rights Policy advocates special protection of communities, including indigenous communities, respecting their laws, culture and customs. Engagement occurs through NGOs such as Medecins Sans Frontieres, the Red Cross and Water.org, plus the Social Advisory Board and Sponsorships and Patronage Committee. The Ethics Line is available to community members. In 2024 no cases of non-compliance with the UN Guiding Principles, the ILO Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines were identified through the Ethics Line.

Inditex engages communities to manage actual and potential impacts and to design its community initiatives, particularly its community investment strategy. Because direct relationships with an entire community are complex, the model is based on collaboration with community representatives such as NGOs and local and international organisations, including UNHCR, the Red Cross, Medecins Sans Frontieres, Water.org and WWF, who take part from initiative design through implementation and assessment. Beneficiaries of community investment projects are involved in the assessment phase, helping gauge effectiveness. Other engagement tools include the Social Advisory Board, an external and independent advisory body institutionalising dialogue with civil society, and the Sponsorships and Patronage Committee, which governs the Community Investment Policy and approves contributions. Projects linked to the Workers at the Centre and raw materials strategies include the Public-Private Partnership with the International Labour Organization, in place since 2017, to improve respect for Fundamental Principles and Rights at Work in cotton communities, and work with the Organic Cotton Accelerator. Effectiveness is measured through detailed project monitoring using, among others, the Business for Societal Impact (B4SI) methodology, with special attention to vulnerable groups including women, young people at risk of exclusion, LGBTQI+ people, migrants and refugees. Operational responsibility rests with the Chief Sustainability Officer.

By identifying potential and actual negative impacts, Inditex works to prevent, mitigate and remedy their effects for communities, developing due diligence processes and making grievance mechanisms available to all legitimate third parties. The main communication and grievance mechanism is the Ethics Line, available to all stakeholders, with the procedure for handling communications from the community the same as for other stakeholders. To ensure community members know, trust and can access the Ethics Line, Inditex includes information and facilitates access via the corporate website and has designated it a preferred communication channel in all applicable policies. Community members can also use external grievance channels designated by the competent authorities in each case, including the official EU institutions, bodies or agencies. Inditex also analyses any other communications it may receive, for example through the organisations it works with on community matters, in order to monitor them and take any necessary action.

Inditex focuses community investment on long-term strategic projects subject to exhaustive monitoring, investing monetary, in-kind and volunteering resources. In 2024 it supported 485 organisations (476 in 2023) carrying out 953 social and environmental projects, with an investment of over 134 million euros, a 20% increase on 2023, directly benefiting more than 4.6 million people (6% more than the prior year). Beneficiaries comprised people living in developing countries (52%), low income (36%), refugees (5%), in situations of vulnerability (5%) and other profiles (2%). Some 91% of contributions supported SDGs 3, 4, 5, 8, 10, 12 and 15. Three priority areas represented 75% of investment: education 23 million euros (17%), emergency relief 41 million euros (31%) and environment 35 million euros (26%), with other issues 34 million euros (25%). Total contributions including management costs were 135 million euros (113 in 2023), split into cash 61.2 million euros, time 10.6 million euros, in-kind 60.9 million euros and management costs 2.2 million euros. In-kind contributions rose 58% through donation of 7.25 million articles, and employees dedicated 353,618 hours (4% more). Leveraged investment reached 210.2 million euros, a 95% increase. Geographically, Spain accounted for 43%, Asia and rest of the world 23%, the Americas 18% and Europe excluding Spain 17%. In 2024 no negative community impacts were reported through the Ethics Line.

In 2022 Inditex committed to help ten million people through its corporate community investment programme between 2022 and 2025. In 2024 it achieved this target, having helped more than 12.3 million people over the last three years. The target table shows 12.3 million people helped in the current year 2024 against the 2025 target year figure of 10 million. This target is linked to the Sustainability Policy and, more specifically, the Community Investment Policy, which is committed to improving community well-being, maximising the value generated in the community and building strategic partnerships. The work has been aligned with the Paris Agreement and the Sustainable Development Goals of the United Nations 2030 Agenda. In establishing and tracking the target, Inditex involves the Social Advisory Board, an external advisory body institutionalising dialogue with civil society partners, along with strategic partners in community investment initiatives, the non-profit organisations it collaborates with, and the beneficiaries of its actions, relying on continuous dialogue to inform decisions and identify possible improvements.

Inditex governs its relationship with consumers through the Human Rights Policy, Sustainability Policy, Code of Conduct, Information Security Policy, Compliance Policy regarding Personal Data Protection and Privacy, and the Ethics Line Procedure. The Sustainability Policy commits the Group to responsible product design using lower-impact raw materials and fibres, ethical and responsible manufacture, and compliance with stringent health and safety standards. The Code of Conduct sets commitments to responsible marketing and communication, requiring accurate, clear and comprehensive product information and content that is not offensive or discriminatory. The Information Security Policy (approved by the Board on 10 December 2019) aligns with ISO/IEC 27001:2022, PCI-DSS 4.0, K-ISMS and MLPS, while the Personal Data Protection and Privacy Policy (approved 11 June 2019) aligns with GDPR. In 2024 no breaches of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines were identified through the Ethics Line.

Inditex engages consumers through several channels: brand specialised customer service teams handling calls, e-mails, WhatsApp and social media; physical and online store teams as the first line of direct contact; digital channels (websites, apps and social media) reaching more than 200 markets; and the Ethics Line as the main grievance mechanism, open to anonymous reports. Initiatives include Customer Experience (CX), in which store managers analyse feedback and develop teams, and the Big Store digital project. Engagement occurs before, during and after purchase, initiated both by customers and by the Company. Special consideration is given to potentially vulnerable consumers through continuous dialogue with partner organisations. Effectiveness is measured via brand-specific contact monitoring plans tracking metrics such as first call resolution and repeat contacts, with each retail concept's Customer Experience manager ultimately responsible for oversight.

Inditex manages consumer issues through three preferred channels: customer service teams and channels, official grievance mechanisms in each market, and the Ethics Line, through which it identifies and implements remediation and mitigation plans. In 2024 the brands' customer service areas fielded 45,913,444 customer contacts (46,446,384 in 2023), with a service level (share of contacts resolved) of 97 percent (98 percent in 2023). Brands handled 44.5 million cases through Customer Services (45.4 million in 2023): pre-purchase 26 percent, post-purchase 70 percent, customer service 5 percent and complaints 0.02 percent. Official consumer complaint forms and claim procedures processed in Spain totalled 6,924 (5,840 in 2023), mainly relating to returns and exchanges. Customer service quality at five brands (Pull&Bear, Massimo Dutti, Bershka, Oysho and Zara Home) renewed ISO 18295:2 certification, and monthly controls monitor customer care quality.

Inditex takes a dual prevention and mitigation approach to consumer impacts, focused on data protection, accessibility and inclusion, and product and store health and safety. Product safety rests on eight mandatory product standards (Safe to Wear, Clear to Wear, Physical Testing Requirements, Active to Wear, i+Cosmetics, i+Food Contact Materials, i+Home Fragrance and Candles, i+Child Care Furniture) and the Picking inspection programme, which in 2024 showed initial textile compliance of 99.7 percent for Safe to Wear and 99.3 percent for Physical Testing Requirements (99.6 percent and 99.3 percent in 2023); unsafe products are withdrawn and recalled. On data protection, 65 projects involving customer data were analysed under privacy-by-design, monitored by the global Data Protection Officer with annual Board reporting, and adaptation work was done in Canada, Japan and Turkiye. Actions contribute mainly to SDG 12. No inherently severe incidents linked to customers' human rights were revealed through the Ethics Line in 2024.

Inditex states that at this stage it does not have specific quantitative targets linked to its customers. Instead it pursues a global ambition to improve the consumer experience, minimise negative impacts and maximise positive ones through the commitments enshrined in its policies and the initiatives carried out during the year. As an example, it cites its target of introducing new circularity services in its markets, in line with the Sustainability Policy, notably through the development of the Zara Pre-Owned platform (cross-referenced to the E5-3 circular economy targets). The effectiveness of consumer-related actions is tracked through related metrics rather than through discrete, time-bound consumer targets.

Inditex's ethical culture is based on the premise that 'the how matters', with commitments set out in its Codes of Conduct and implemented through a Global Compliance Model whose key elements are the governance and supervisory structure, Codes of Conduct, Ethics Line, disciplinary system, compliance training plan, due diligence, Compliance Policy and Internal Audit function. Within it, the Model of Criminal Risk Prevention (approved by the Board in 2012, revised in depth in 2016) uses a Risk and Control Matrix cataloguing criminal risks including corruption, monitored with support from external auditors; it has been audited by an independent third party with reasonable assurance scope, most recently in 2021, with unqualified reports. The Board approves the ethical commitments; the Audit and Compliance Committee supervises the Compliance function quarterly, receiving reports from the Ethics Committee and Chief Compliance Officer. A Due Diligence Policy governs third-party control, and Inditex Minimum Requirements bind all product suppliers.

Inditex's business model rests on an agile, flexible and proximity-based supply chain. In 2024 it worked with 6,615 factories across all tiers of the supply chain in 50 markets, employing more than three million people (6,710 factories and 49 markets in 2023). By geography these were 1,012 in the European Union, 1,302 in Europe outside the EU, 23 in the Americas, 3,837 in Asia and 441 in Africa. Supplier relations are managed through ten supplier clusters in the main production markets: Spain, Portugal, Morocco, Turkiye, India, Bangladesh, Pakistan, Vietnam, China and Cambodia. The Code of Conduct for Manufacturers and Suppliers is the foundation, setting labour rights, product health and safety and environmental standards, complemented by the proprietary Green to Wear environmental standard and the Inditex Minimum Requirements that all product suppliers must accept, including traceability requirements.

Inditex declares zero tolerance for corruption and commits to complying with anti-corruption laws in all markets. Prevention rests on the Codes of Conduct and policies including the Due Diligence Policy, the Integrity Policies (Donations and Sponsorships, Gifts and Invitations, Dealings with Public Servants), the Conflicts of Interest Policy and the Policy on Public Policy, together with the Global Compliance Model and Model of Criminal Risk Prevention. The Audit and Compliance Committee met in February, March, June, September and December 2024. A 2024 global campaign on the updated Code of Conduct (available in 34 languages) achieved 97 percent acceptance, and the mandatory e-learning covering corruption and bribery prevention has been completed by 91 percent of employees; 2,690 people received specific in-person or hybrid training. In the priority group exposed to compliance risks, 86 percent were trained (79 percent in 2023), all Board members received compliance and/or corruption training, and 813 product suppliers and factories in 30 markets received compliance training.

During 2024 the Ethics Line recorded 791 concerns (515 in 2023), broken down as HR, diversity and workplace respect 619; business integrity 44; environment, health and safety 14; inappropriate use of Company assets 1; financial, accounting or audit fraud 0; queries 67; and others 46. Of 556 closed cases, 313 were classified as beyond the Ethics Line's authority. There were four confirmed cases of corruption (five in 2023), resulting in three disciplinary measures or terminations and one terminated or non-renewed business-partner contract; four confirmed cases of discrimination; and nine confirmed cases of harassment. Inditex states that no relevant aspects affecting the Company were observed in the confirmed corruption reports, that neither in 2024 nor 2023 was it aware of legal proceedings concerning corruption or bribery affecting the Company, and that in 2024 it received no significant fines or non-monetary penalties for non-compliance with anti-corruption or anti-bribery legislation.

In 2024 Inditex developed and approved its Policy on Public Policy (approved by the Board of Directors on 10 December 2024), committing to transparent and responsible engagement in the preparation of public policies, aligned with the OECD Guidelines and the SDGs. The Policy on Donations and Sponsorships expressly prohibits donations to political parties, directly or indirectly, a prohibition also reflected in the Code of Conduct, and no contributions in cash or in kind were made to political parties during the year. No members of the Board of Directors held a comparable position in government administrations in the two years prior to their appointment. Inditex's public policy activities focus on four main topics: Sustainability, Trade, Digital and Finance. The Group is a member of the European Union Transparency Register under registration number 518095443081-20.

Inditex pays suppliers most commonly by bank transfer and offers various financing programmes. It belongs to ACT (Action, Collaboration, Transformation), undertaking five commitments on responsible purchasing practices that include agreeing and respecting fair payment conditions, and it has a third-party payment procedure to meet legal and agreed deadlines. For 2024 the average payment period by supplier type was: trade creditor invoices 36 days (EU) and 32 days (other) against a 60-day standard term, with 94 percent and 95 percent paid within the standard period; finished-product procurement 99 days (EU) and 98 days (other) against 90 days, with 82 percent and 95 percent within term; and raw-material procurement 60 days (EU, 60-day standard, 98 percent) and 122 days (other, 120-day standard, 94 percent). Inditex pays within 60 days under EU regulations and paid 75 percent of the volume within 30 days. No legal proceedings have been brought against the Group for late payment.