Inditex

The role of the administrative, management and supervisory bodies

Reference: pages 104-106.

Inditex's Corporate Governance System is described in detail in the Annual Corporate Governance Report, incorporated by reference. The Board of Directors sits above executive bodies (the CEO, the Management Committee, the Chief Corporate Officer and the Chief Sustainability Officer) and advisory bodies (the Sustainability Committee, the Sustainability and Inclusion Advisory Committee, the Cybersecurity Advisory Committee and the Ethics Committee). The Sustainability Committee "monitors our strategy and practices in sustainability, diversity and inclusion" and reports on target achievement, while the Audit and Compliance Committee oversees "financial and non-financial risks" and the integrity and independent verification of the sustainability information. The CEO reports quarterly to the Board; the Chief Sustainability Officer reports at least quarterly to the Sustainability Committee. Cross-membership between the Sustainability Committee and the Audit and Compliance Committee, and the annual double materiality assessment reported to the Sustainability Committee, tie sustainability oversight into the Board's agenda.

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

Reference: pages 105-107.

The Chief Sustainability Officer "reports to the Sustainability Committee, at least quarterly, regarding the main events of interest in the field of sustainability," including progress against strategic targets, and also reports to the Board, the Audit and Compliance Committee and the Management Committee as required. The Sustainability Committee "oversees the sustainability information that is included in the Directors' Report" and is responsible for evaluating whether it is consistent with Company policy, liaising with the Audit and Compliance Committee, which supervises the preparation process and integrity of the information and its independent verification. The double materiality assessment is carried out annually and its findings are "reported to the Sustainability Committee," which ensures they are reflected in reporting; the Sustainability and Inclusion Advisory Committee conveys stakeholder expectations on sustainability matters to governing bodies.

Integration of sustainability-related performance in incentive schemes

Reference: pages 106-107.

Detail on the Remuneration Committee's role in approving and reviewing director remuneration, and on the integration of sustainability targets in the CEO's and Senior Management's variable pay, "can be found in the Annual Report on Remuneration of Directors," incorporated by reference. The Sustainability and Inclusion Advisory Committee holds joint meetings with the Sustainability Committee to discuss, among other matters, "the double materiality assessment and the Consolidated Statement of Non-Financial Information and Sustainability Information." Senior Management's remuneration structure is aligned with the CEO's, so that "reaching sustainability targets is also a component of the Senior Management's variable remuneration, as well as a component of other key personnel variable remuneration." The Annual Report on Remuneration of Directors carries the quantified weighting of sustainability criteria in CEO variable pay.

Statement on due diligence

Reference: page 107.

Inditex's due diligence process "allows us to identify and prioritise the potential sustainability-related negative impacts — including human rights and environmental aspects — throughout the value chain," based on the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Due diligence is "the second pillar of Inditex's human rights strategy," alongside the Human Rights Policy and grievance mechanisms. In 2025 the Company carried out a human rights saliency exercise involving "more than 400 employees from different areas of the Company," consulting more than 25 external organisations, whose findings "have been included in the materiality assessment" and underscore health protection, fair and equal treatment and a healthy environment. A table maps the core elements of due diligence (embedding, identifying and assessing impacts, stakeholder engagement, taking action, tracking effectiveness) to the relevant chapters (GOV-1, IRO-1/IRO-2, S1-2 to S4-3, E1-3 to E5-2, G1-2/G1-3).

Risk management and internal controls over sustainability reporting

Reference: pages 107-108.

Inditex operates an Internal Control System on Sustainability Reporting (ICSR) "to ensure the quality, accuracy, integrity, traceability and transparency of the information included in this Report," built on synergies with the Internal Control over Financial Reporting System and following the COSO framework and guidance from Spain's Institute of Internal Auditors. The Board of Directors "is ultimately responsible for the existence and maintenance of an adequate ICSR," delegating oversight to the Audit and Compliance Committee. Risks are understood as "the absence or insufficiency of stable and defined processes" that could lead to errors or unreliable information. During 2025, Inditex progressed in "defining and documenting a model for managing and reporting the most relevant sustainability indicators," established specific manuals for quantitative indicators, and documented the double materiality assessment's criteria, methodology and responsibilities. The Statement is verified by Ernst & Young.

Strategy, business model and value chain

Reference: pages 109-113.

Industria de Diseño Textil, S.A. is the Inditex Group's parent, distributing fashion and household products through eight retail concepts (Zara, Pull&Bear, Massimo Dutti, Bershka, Stradivarius, Oysho, Zara Home and Lefties) across 214 markets, generating revenue of 39,864 million euros in 2025 (38,632 million in 2024). At year end the Group employed 163,047 people in 57 markets and 174 nationalities. The business model rests on four drivers — fashion proposal, shopping experience, sustainability and talent — and the value chain spans design, raw materials extraction/production, manufacturing (6,684 factories across 49 markets, organised into 10 supplier clusters), logistics and distribution, and downstream stores, online sale, use and end of life, with proximity manufacturing concentrated in Spain, Portugal, Morocco and Türkiye. The Group allocated 175 million euros to community investment in 2025 and does not operate significantly in fossil fuel, chemicals, weapons or tobacco sectors.

Interests and views of stakeholders

Reference: pages 114-115.

Inditex identifies six main stakeholder groups — teams (S1), customers (S4), suppliers (S2, G1), society, environment (E1-E5) and shareholders — with the relationship organised into identification of topics and stakeholders, classification and prioritisation, and definition of a strategy per group with objectives, commitments and dialogue tools. Governance runs through the Sustainability and Inclusion Advisory Committee (formerly the Social Advisory Board, created in 2002) and the Sustainability Committee. Cross-cutting tools include the corporate website, this Report and the annual materiality assessment itself, alongside policies such as the Code of Conduct, the Code of Conduct for Manufacturers and Suppliers, the Human Rights Policy and the Sustainability Stakeholder Relations Policy. Sector-wide partnerships and alliances — with governments, trade unions, academic institutions and civil society — are documented in the corporate website's Partnerships report.

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

Reference: pages 118-121.

The materiality assessment identifies impacts, risks and opportunities (IROs) across all environmental and social standards except S3, which the report states plainly is not material: "the identified potential impacts and risks linked to ESRS 'S3 - Affected communities' are not material for Inditex," following a 2025 human rights saliency exercise that found material social impacts centred on the own workforce, customers and supply-chain workers. Each IRO carries a code (e.g. E1.I1, S1.R1), an impact/risk/opportunity type, a time horizon and value-chain phase; environmental topics show mainly negative actual impacts plus a climate/pollution/water/biodiversity/resource-use risk, while E5 and S1 also carry an opportunity. Cybersecurity is treated as a company-specific IRO under G1 rather than as a separate topic. No risks or opportunities were identified that could trigger a material change in balance sheet valuations next year, and Inditex has invoked the phase-in provision for anticipated financial effects outside E1.

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

Reference: pages 113-117.

For "the fourteenth consecutive year" Inditex applies a double materiality methodology aligned with ESRS, EFRAG's IG1 guidance and GRI 3, run through identification of IROs (due diligence findings, the Risk Map, stakeholder dialogue, ESRS 1 AR16 and the LEAP approach for environmental topics), assessment of impact materiality (severity-based thresholds, with human rights probability assumed 100%) and financial materiality (aligned with the Group's Integrated Risk Management System, using a 2% cash-flow-at-risk and 3% probability threshold), and validation by Management, the Sustainability Committee, the Sustainability and Inclusion Advisory Committee and the Board. A Materiality Advisory Network of universities, ZDHC, Conservation International, the Pacific Institute, ECODES, the Climate Group, the UN Global Compact, the IOE, the ETI and UNI Global Union, plus specialists Risilience and Shift, informed the process, moving stakeholder engagement toward interviews in the detailed 2024 assessment.

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

Reference: pages 116, 233-236.

IRO-2 is presented jointly with IRO-1 under the materiality section, and the Annexes carry a granular "Table of contents required by Directive 2013/34/EU [IRO-2_02]" mapping every disclosure requirement to its chapter and initial page, plus a second "Table of contents of information derived from other EU legislation [IRO-2_01]" cross-referencing SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoints. The concordance table records Inditex's explicit rationale wherever a datapoint is not disclosed — for example "Not disclosed, subject to phase-in" for the E1/E2/E3/E4/E5 anticipated-financial-effects requirements, and "Not material" for S1-7 and the S3 human-rights datapoints — rather than leaving these silent. This content index is the source used to classify each disclosure requirement's status in this dataset.

Transition plan for climate change mitigation

Reference: pages 125-129.

Inditex's Climate Transition Plan is "consistent with our science-based targets (SBTs), pursuing a GHG emissions reduction pathway aligned with the Paris Agreement ambition of limiting global warming to 1.5ºC," built on the 'announced policies' emissions scenario and three decarbonisation levers — Reduction (own operations self-consumption and PPAs, the Supply Chain Environmental Transformation Plan, alternative maritime fuels), Neutralisation (Sustainability Innovation Hub, Fibres Plan, Pre-Owned) and Mitigation beyond the value chain (regenerative practices, nature-based and technological solutions). The Group targets net-zero by 2040, a 53% emissions cut by 2030 and 20% by 2027, versus 2018. The CEO defines the strategy for Board approval following a favourable Sustainability Committee report; the plan was also presented to the Sustainability and Inclusion Advisory Committee and announced to shareholders at the AGM. Inditex "has not been excluded from the EU Paris-aligned benchmarks."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 "Risks and opportunities due to climate change" section, where this content is disclosed in the FY2025 report (pages 134-136). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Climate risks are classified as physical or transition within the materiality-assessment IRO table (E1.R1, page 118). Methodology: analysis was performed on "over 13,700 own and third-party facilities in our value chain," covering short (0-3y), medium (3-10y) and long term (10y+), using the University of Cambridge Centre for Risk Studies methodology. Five scenarios were used: current policies (3ºC by 2100), NDCs (2.3ºC), below 2ºC (1.8ºC), delayed transition (1.7ºC) and net zero (1.3ºC by 2050) — physical-risk pathways drawn from the IPCC Sixth Assessment Report, transition-risk data from the NGFS. Physical phenomena assessed include heatwave, water stress, river and coastal flooding and wildfire; transition dimensions cover Regulatory, Legal liability, Technological, Market and Reputation. The report states the analysis carries "a high degree of uncertainty" that "rises the longer the time horizon," and that Inditex has invoked the phase-in provision for anticipated financial effects as a result.

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate-risk section, where this content is disclosed in the FY2025 report (pages 121, 134-136). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The report does not describe a standalone ESRS-defined resilience analysis; instead it states that scenario analysis is used "to examine the resilience of our strategy," covering short-, medium- and long-term horizons across five emissions pathways. On the basis of this analysis, "none of the Company's activities or assets were found to be incompatible with the climate transition, or require significant efforts to guarantee that compatibility." Climate-related risks were factored into the estimates used for certain assets, liabilities, income and expenses per Note 2 to the Consolidated Annual Accounts. Mitigations named for physical risk include technical contingency systems, insurance, and logistics centres designed to absorb capacity from other centres in a contingency; mitigations for chronic risk include the Climate Transition Plan and Fibres Plan. Given the stated uncertainty of the scenario findings, Inditex has invoked the phase-in provision for anticipated financial effects.

Policies related to climate change mitigation and adaptation

Reference: page 125.

Inditex's climate ambition, set out in the Sustainability Policy and Energy Policy, rests on "developing responsible energy management," reducing GHG emissions and collaborating to transform the sector, improving climate adaptation and mitigation capacity, a cross-cutting approach that recognises the need to protect and restore nature, and "the commitment to a fair transition." Climate governance aims to ensure IROs linked to climate are addressed, supported by mechanisms including the variable remuneration system. The Climate Transition Plan operationalises these commitments with decarbonisation levers and net-zero-by-2040 milestones (see E1-1). Detail on the policies and their updates sits in the MDR-P. Policies section and the Detailed information. Policies annex (page 201).

Actions and resources in relation to climate change policies

Reference: pages 129-131.

In own operations, self-consumption (11,506 MWh generated in 2025, up from 9,962 MWh in 2024) and virtual PPAs spanning 12 years with 98 MW of installed capacity contributed to a 2025 reduction of "more than 436,000 tonnes of GHG in our scopes 1 and 2 with respect to 2018." Efficiency measures span LEED/BREEAM-certified buildings (two LEED Platinum, 14 LEED Gold headquarters/logistics certifications; seven LEED Platinum stores among 5,460), 28 ISO 50001 certifications, and 87% of own stores connected to the Inergy energy-monitoring platform. In the value chain, category 1 (purchased goods and services) emissions fell 1.1 million tonnes of CO2e versus 2018, driven by the Supply Chain Environmental Transformation Plan 2024-2027 (requiring a 4.2% annual scope 1/2 reduction from manufacturers) and alternative maritime fuels, which covered "more than 98%" of maritime transport in 2025 against a 90% target, via agreements with Maersk, Hapag-Lloyd, MSC and CMA CGM.

Targets related to climate change mitigation and adaptation

Reference: pages 128-129.

Inditex targets net-zero GHG emissions across scope 1, 2 and 3 by 2040 (95% scope 1/2 cut, 90% scope 3 cut versus 2018, remaining 10% neutralised per SBTi guidelines), an interim 53% total emissions cut by 2030 (95% scope 1/2, 51% scope 3) and 20% by 2027, all SBTi-approved and Paris-aligned. In 2025 the Group "reduced scope 1, 2 and 3 emissions by 11% of our SBT target, as compared to 2018," against a total emissions figure of 10,528,872 tCO2e (2018 base year) versus 9,384,325 tCO2e in the current year. Supporting sub-targets include using at least 90% alternative maritime fuels by 2025 (98% achieved), tripling renewable generation capacity in central offices/headquarters/distribution by 2027, reaching 40% self-consumption/PPA-sourced electricity by 2027 and 60% by 2030, eliminating coal from the supply chain by 2030, and 50% renewable electricity in manufacturing by 2030 (100% by 2040).

Energy consumption and mix

Reference: page 132.

Total energy consumption in 2025 was 1,685,273 MWh (1,670,262 MWh in 2024), of which 1,581,084 MWh — 94% — came from renewable sources, up from 92% in 2024. Fossil energy consumption totalled 104,189 MWh (6% of the mix), split across crude oil/petroleum products (26,260 MWh), natural gas (72,222 MWh) and purchased fossil electricity/heat/steam/cooling (5,707 MWh); there was no coal or nuclear consumption. Relative energy consumption fell to 174 kWh/m² (177 in 2024) and 42 Wh/€ (43 in 2024), a 29% reduction per square metre versus 2018. Renewable electricity certificates covered "more than 90%" of RE100-aligned requirements, of which 35% were bundled and 65% unbundled. NACE classification places Inditex in retail sale of household equipment, so this total relative consumption is treated as equivalent to a high-climate-impact-sector disclosure.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 133-134.

2025 gross scope 1 emissions were 58,238 tCO2e (60,909 in 2018 base year); gross market-based scope 2 was 1,000 tCO2e (419,448 in 2018); gross scope 3 was 12,611,193 tCO2e across 12 GHG Protocol categories, led by upstream transportation and distribution (2,604,471 tCO2e) and use of sold products (2,913,689 tCO2e). Total market-based GHG emissions were 12,670,431 tCO2e, down 6% year on year. Emissions intensity fell to 1.5 g CO2e per euro (market-based scope 1+2), from 19 g CO2e/€ in 2018. Biogenic emissions from biofuel use totalled 18 tCO2e in scope 1 and 510,443 tCO2e in scope 3 in 2025. Scope 1, 2 and 3 GHG emissions "have been verified independently" by Ernst & Young in accordance with ISAE 3410, alongside the rest of the Report's assurance.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 234 (ESRS content index).

The concordance table states plainly that "the Company does not use carbon credits to finance GHG mitigation and therefore no disclosures are included in this regard." No dedicated E1-7 narrative section exists in the E1 chapter beyond this index entry; the Climate Transition Plan's net-zero pathway instead relies on internal reduction levers (Reduction, Neutralisation, Mitigation beyond the value chain, see E1-1) with only the residual 10% of the 2040 target neutralised through GHG removals per SBTi guidelines, rather than through purchased carbon credits.

Internal carbon pricing

Reference: page 234 (ESRS content index).

The concordance table states that "the Company does not apply an internal carbon pricing system and therefore no disclosures are included in this regard." As with E1-7, no separate narrative section addresses internal carbon pricing elsewhere in the E1 chapter; this brief index statement is the entirety of Inditex's disclosure on the point for FY2025.

Policies related to pollution

Reference: pages 137-138.

Inditex's pollution policies commit to "minimisation of the potential environmental impact that might be generated in our value chain," protection of soil health and water quality, efficient water use and wastewater treatment, and reduction of emissions to air, soil and freshwater. Own-operations prevention runs through an ISO 14001-certified Environmental Management System; supply-chain prevention runs through environmental audits against the Green to Wear standard and Corrective Action Plans. Product chemical safety is governed by mandatory standards including Green to Wear, Clear to Wear, The List by Inditex, and the i+ Standards for cosmetics, food-contact materials and home fragrances, with a target of 95% certified chemical products by 2026.

Actions and resources related to pollution

Reference: pages 138-140.

Avoidance measures include the Picking compliance-verification programme (66,426 inspections, 839,699 analyses and tests in 2025, an initial compliance rate of 98.7%) and the Supply Chain Environmental Transformation Plan's wastewater and chemicals requirements. Reduction measures include R&D+i partnerships with BASF, CHT, Pulcra and Jeanologia, and Sustainability Innovation Hub initiatives such as The Mill by Inditex, Circular Dyeing by Inditex, and the Microfibers DNA by Inditex/Air Fiber Washer. Metrics show 99% of Green to Wear-scope factories authorised for water resources and wastewater discharge, 94% compliant with discharge limits, and 69% meeting ZDHC Wastewater Guidelines v2.2 substance limits. Inditex is a member of the AFIRM Group management committee and continues working with ZDHC's Chemical to Zero Progressive framework.

Targets related to pollution

Reference: page 234 (ESRS content index).

Inditex states plainly that "specific targets related to pollution are not available," directing readers instead to the E2-1 policies and E2-2 actions sections for how effectiveness is monitored and ambition assessed [E2.MDR-T_14-19]. In practice this tracking runs through the Picking programme's compliance rates (98.7% initial compliance in 2025) and the Green to Wear standard's wastewater-authorisation and ZDHC-compliance metrics reported under E2-4, which substitute for a numeric pollution target.

Pollution of air, water and soil

Reference: page 140.

Pollutant emissions are located mainly in supply-chain manufacturing rather than Inditex's own operations, but "it is not possible to quantify these emissions" given the lack of robust, contrasted estimation methodologies in the textile industry. Supply-chain metrics reported instead: 99% of factories under the Green to Wear standard held water-resource authorisation, 99% held wastewater-discharge authorisation, and 94% of factories' direct or indirect discharge complied with legal or agreed effluent-treatment-plant limits. Of factories carrying out wastewater discharges, 92% met the ZDHC Foundational level, and 69% complied with ZDHC Wastewater Guidelines v2.2 substance limits in direct and indirect discharges. Environmental audits trigger Corrective Action Plans where non-compliance is found.

Substances of concern and substances of very high concern

Reference: page 141.

Microplastics and substances of concern are located primarily in the value chain, during manufacturing and product use. Inditex reports that "no related metrics have been included" for microplastics because of "the lack of a robust sectoral methodology to calculate these emissions" and difficulty obtaining value-chain data, though the Company has joined The Microfiber Consortium to contribute experimental data toward future reduction metrics. Substance-of-concern volumes similarly cannot be quantified because chemical manufacturers typically disclose concentrations only above 0.1%, obscuring whether a substance is absent or merely below the reporting threshold, and international classification of substances is inconsistent outside the EU. Mitigation relies on The List by Inditex, the ZDHC Manufacturing Restricted Substances List, the Green to Wear chemical-management module, chemical-inventory digitalisation and the ZDHC Performance InCheck Report.

Policies related to water and marine resources

Reference: page 142.

The Water Policy sets out use-and-supply commitments (prioritising recycled water and alternative sources, reducing withdrawal and discharge, cutting consumption in high-water-stress areas), treatment commitments (improving wastewater treatment, minimising the water footprint, exploring reuse technologies), pollution-prevention commitments on hazardous chemicals and other pollutants, and lower-water-impact product design considerations from raw-material sourcing through end of life. Inditex supports ocean and seas protection through The Fashion Pact, the Alliance for Water Stewardship and the Arctic Corporate Shipping Pledge (Ocean Conservancy). Impacts identified in the materiality assessment concentrate in the value chain rather than own operations, where the policy's water-management action lines are targeted.

Actions and resources related to water and marine resources

Reference: pages 143-144.

The Care for Water (CFW) standard, part of Green to Wear, benchmarks water-intensive manufacturing facilities and sets minimum water-management requirements for wet-processing factories over 2024-2027; the Best Available Techniques (BAT) tool details measures from process optimisation to lower-water-use machinery. In 2025 Inditex partnered with ZDHC to make the CFW standard available industry-wide. Partnerships include the World Wildlife Fund, the CEO Water Mandate, the Alliance for Water Stewardship and Water.org, which improves drinking-water and sanitation access in Bangladesh, Cambodia and India; more than 20 industry leaders including BASF, CHT, Pulcra and Jeanologia support water-related R&D. Water actions are cross-referenced with pollution mitigation described under E2.

Targets related to water and marine resources

Reference: page 143.

Inditex targeted a 25% reduction in relative water consumption in the supply chain by 2025 versus 2020, and "in 2025 we achieved the target we had set, reaching a 26% reduction" — from 101 to 75 litres per kilogram of garment. Türkiye, Mainland China and India were identified through the materiality assessment and water-risk databases as the main markets with wet-processing facilities exposed to material water risk, and the target is aimed particularly at those locations. The achievement is credited to the Supply Chain Environmental Transformation Plan's wet-process water-management requirements, and the report notes the reduction also helps cut GHG emissions associated with water use in manufacturing.

Water consumption

Reference: page 143.

Because "almost all the water withdrawn is discharged at the end of its use" in supply-chain production, water withdrawal — reported under the industry-standard term "consumption" — is the most representative E3 metric for Inditex; material consumption is concentrated in the supply chain's wet processes (dyeing, washing, finishing, printing) and in raw-material production. The Company achieved a 26% reduction in relative water consumption in the supply chain versus 2020 against a 25% target (see E3-3), reaching 75 litres per kilogram of garment. Own-operations water consumption is addressed separately under Act 11/2018 disclosures (1,998,478 m³ in 2025, 207 litres/m² relative), and is treated as not material to the E3 standard.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Reference: page 234 (ESRS content index).

The concordance table states that "the Company does not have a Biodiversity Transition Plan and therefore no disclosures in this regard are included." No dedicated E4-1 narrative exists elsewhere in the E4 chapter beyond this index statement. Biodiversity and ecosystem considerations are instead addressed through the Ecosystems and Biodiversity Policy (E4-2), the AR3T-framework actions (E4-3) and the five-million-hectare protection/restoration/regeneration target (E4-4), rather than through a formal transition plan.

Policies related to biodiversity and ecosystems

Reference: page 145.

The Ecosystems and Biodiversity Policy sets Company principles on impacts and dependencies on ecosystems and biodiversity, addressing physical and transition risks, and commits to refusing "materials and products linked to deforestation, sourcing from primary and endangered forests and ecosystem conversion and degradation," and to sourcing lower-overall-impact products, supplies and raw materials. It targets value-chain mapping and traceability to detect and monitor impacts, and — reinforced by the Water Policy — recognises the hydrosphere's role as an ecosystem-services provider. The Policy frames impacts on ecosystems as also carrying "a social dimension," linking the right to a clean, healthy and sustainable environment to economic development, social justice and well-being, and balancing ecosystem protection with local community needs.

Actions and resources related to biodiversity and ecosystems

Reference: pages 146-148.

Actions follow the SBTN/TNFD AR3T framework — Avoid, Reduce, Restore, Regenerate, Transform. Avoid: forest raw materials (wood, pulp) must be certified to avoid High Conservation Value areas. Restore: partnerships with WWF (forest-landscape restoration in Mexico, forestry management in China), SOS Mata Atlântica, and Conservation International's Mountains to Mangroves initiative delivered 1,107,098 hectares in restoration or restored in 2025 (up 484,220 hectares on 2024), funded with 12 million euros via #BRINGYOUROWNBAG proceeds. Regenerate: the Regenerative Fund for Nature with Conservation International and Kering supported regenerative farming in Argentina, South Africa, India and Pakistan, delivering 398,217 hectares in regeneration or regenerated (up 262,561 hectares), funded with 7 million euros. Transform: memberships include WWF, Ocean Conservancy, Business for Nature, OP2B, LEAF Coalition, the Deforestation-Free Call to Action for Leather and Pack4Good.

Targets related to biodiversity and ecosystems

Reference: page 146.

Inditex targets 5 million hectares "under protection, restoration or regeneration projects or other forms of management for biodiversity improvement" by 2030, against 1.5 million hectares reached by 2025. The target sits within SBTN's 'Restore & Regenerate' action-framework category and is aligned with the EU Biodiversity Strategy for 2030 and the Kunming-Montreal Global Biodiversity Framework. It is delivered with expert partners including WWF and Conservation International (see E4-3), and is reinforced by related climate, water and Fibres Plan commitments given the interdependence of biodiversity with GHG reduction and natural-resource management.

Impact metrics related to biodiversity and ecosystems change

Reference: page 146.

The materiality assessment identified certain of Inditex's own facilities located near biodiversity-sensitive areas; however, the Company states it "have not found any material negative impacts from these facilities in those areas." A footnote to the materiality IRO table clarifies that "no facilities were identified that were located near biodiversity-sensitive areas and had an operating profile with a significant impact on biodiversity," and that biodiversity offsets were not used in any of the reported restoration or regeneration initiatives. The primary impact metrics reported are the hectares in restoration/restored (1,107,098) and regeneration/regenerated (398,217) under E4-3/E4-4, rather than own-operations biodiversity-pressure indicators.

Policies related to resource use and circular economy

Reference: page 149.

The Sustainability Policy and Ecosystems and Biodiversity Policy commit Inditex to circularity "from product design to considerations relating to product end of life," to prioritising lower-environmental-impact raw materials over conventional ones, and to responsible design and careful raw-material selection sourced through lower-impact production systems. The Fibres Plan operationalises the raw-materials commitment, aiming for 100% of textile fibres used to have a lower environmental impact by 2030. An animal-welfare commitment, aligned with the internationally recognised "Five Freedoms," requires that products of animal origin come from animals "treated ethically and responsibly."

Actions and resources related to resource use and circular economy

Reference: pages 151-152.

The Sustainability Innovation Hub approved three new fibres for the Fibres Plan and ran nine life-cycle analyses in 2025, alongside a Cotton Strategy delivering the first garments made with regenerative-practice cotton (1%) plus 21% recycled and 58% organic cotton. On use, end of life and waste, Zara Pre-Owned (repair, resale and donation) operates in 17 markets; the clothing collection programme recovered 20,495 tonnes of garments and footwear through 5,415 store containers, donated to 92 community organisations, of which 53% were reused and 47% sent to recycling or, as a last resort, energy recovery. The Supply Chain Environmental Transformation Plan's Green to Wear standard sets waste-sorting, labelling, storage and authorised-waste-manager requirements for supply-chain facilities.

Targets related to resource use and circular economy

Reference: pages 149-150.

The Fibres Plan targets 100% lower-environmental-impact textile fibres by 2030; in the latest 2025 campaign, 88% of fibres used were lower-impact (up from prior years), of which 47% were recycled and 30% organic or regenerative, with polyester at 98% and linen at 96% lower-impact against a 100%-by-2025 sub-target for each. A second target — providing circularity services such as Zara Pre-Owned in key markets — was achieved in 2025, with the service "in the consolidation phase in 17 markets." These targets contribute primarily to the reuse and recycle tiers of the waste hierarchy (Prevent, Reduce, Reuse, Recycle, Recover, Dispose).

Resource inflows

Reference: pages 152-153.

Raw materials used in products totalled 705,554 tonnes in 2025 (678,596 tonnes in 2024): 88% fibres and 12% non-fibres, with fibres split 53% natural, 38% synthetic and 9% artificial. By raw material, cotton represented 43% of total tonnes (44% in 2024), man-made cellulosic fibres 8%, linen 2% and polyester 27%. Recycled sources supplied 42% of materials used in products in 2025, up from 33% in 2024. Packaging materials totalled an estimated 509,361 tonnes (86% biological, 14% technical), down from 521,448 tonnes in 2024. Methodology detail on lower-impact fibre criteria sits in the Detailed information. Methodology annex.

Resource outflows

Reference: page 153.

Inditex participated in the Technical Secretariat developing the European Commission's Product Environmental Footprint (PEF) methodology, approved for apparel and footwear (PEFCR) in 2025, and continues supporting its refinement; no harmonised industry methodology yet exists to calculate product recyclability on a like-for-like basis. On product packaging, Inditex has "chosen to eliminate single-use plastics that reach customers," and the #BRINGYOUROWNBAG (#TRAETUBOLSA) initiative, live in 84 markets since 2021, is estimated to have cut the number of bags and envelopes provided by 50%; proceeds from charging for recycled paper bags have reached 159 million euros since launch, of which 75 million euros has been allocated to environmental projects across 46 markets. Waste generation and destination metrics are reported separately (see E5-5-Waste).

Waste

Reference: pages 153-154.

Waste generated at headquarters, logistics centres and own factories totalled 58,154 tonnes in 2025 (60,269 tonnes in 2024): 64% cardboard and paper, 13% plastic, 11% wood, 10% other non-hazardous, 1% textile, 1% metal and 0.2% (131 tonnes) hazardous waste. Of the total, 52,895 tonnes (91%) were diverted from disposal — 52,788 tonnes recycled — while 5,260 tonnes (9%) were directed to disposal, including 4,829 tonnes landfilled. Inditex holds 15 TRUE zero-waste certifications (nine Platinum, six Gold) across headquarters, logistics centres and own factories, identifying "environmentally responsible spaces that have achieved 90% or greater overall diversion from landfill or incineration." Store waste is not yet captured at the required systems detail; it is separately estimated at approximately 136,000 tonnes for 2025.

Policies related to own workforce

Reference: pages 158-159.

The Sustainability Policy and Human Rights Policy protect the rights of Inditex's people; the Human Rights Policy and Code of Conduct "expressly prohibit forced and child labour," and the Company states it does "not tolerate any form of modern slavery or human trafficking in our organisation or in our value chain." The Diversity and Inclusion Policy, under the purpose "We Design Opportunities for All," underpins programmes for gender equality, socio-ethnic inclusion, LGBTQI+ inclusion and disability inclusion, and prohibits discrimination on grounds including race, disability, religion, sexual orientation and gender identity. Policy is driven by the Board, implemented by a Global Diversity & Inclusion Officer and Diversity Champions in each market, and reinforced via the Ethics Line, the UNI Global Union agreement and training measures.

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 172-174.

Social dialogue runs through the Code of Conduct's guarantee of "the right of all workers to join, associate with and/or create the trade union of their choice," the Global Agreement with UNI Global Union (signed 2009, renewed 2024, covering "100% of the Group's workforce"), and the European Works Council, formally founded in 2019, which in 2025 signed a joint declaration on employment of senior staff. INET is the main internal communication channel; the Chief People Officer holds delegated responsibility for people relationships. In Spain, a 2024 agreement with Comisiones Obreras addresses senior-staff continuity and working-hours reduction from age 55, and the 2023 Equality Plan unifies gender-equality provisions across all retail concepts and central services.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 172.

Beyond the Ethics Line, employees "may also submit any queries or concerns through their manager or the Human Resources department," as set out in the Code of Conduct. Prevention and mitigation efforts focus on equal pay, minimising accident and occupational-disease risk, protection against harassment, and adequate training; where an impact has occurred, Inditex applies "a dual perspective of remedying the negative effect and preventing its recurrence," illustrated by health, safety and well-being initiatives addressing work-related accidents and occupational diseases. Compliance awareness, sensitisation and training relevant to remediation are detailed under G1-3, and Ethics Line follow-up and control procedures are detailed under the grievance-mechanism section shared with G1-1/G1-4/S1-17.

Taking action on material impacts on own workforce, and approaches to mitigating material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

Reference: pages 160-172.

Actions span diversity and inclusion (GEEIS certification at the corporate Group and nine subsidiaries; 76% of management positions held by women; the SALTA programme for at-risk groups, present in 22 markets; the INCLUYE programme for disability inclusion, 3,339 people with disabilities employed); pay equity (a 0.0% gender pay gap in 2025 total salary, from 0.7% in 2024); talent development (3.4 million training hours across 2.5 million participants; 80% of vacancies filled internally); and health, safety and well-being (Wellbeing Committees in 26 markets, ISO 45001 implemented across 33 markets covering 94% of the own workforce). Talent attraction and retention is identified as the key workforce-related opportunity, pursued through programmes such as Junior Talent and the Inditex Leadership Academy.

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

Reference: page 234 (ESRS content index).

Inditex states that "specific targets related to own workforce are not available," pointing instead to the S1-1 policies and S1-4 actions sections for how effectiveness of policies and actions, and the level of ambition, is monitored [S1.MDR-T_14-19]. In practice this tracking runs through the quantified metrics reported across S1-6 to S1-16 — gender pay gap, disability employment, training hours, ISO 45001 coverage and accident rates — which substitute for a stated numeric own-workforce target.

Characteristics of the undertaking's employees

Reference: pages 160-162.

At year end 2025 Inditex employed 163,047 people (162,083 in 2024) across 57 markets and 174 nationalities: 85% in stores, 7% in central services, 6% in logistics and 1% in factories. By gender, 73% were women and 26% men; by age, 54% were under 30. Europe (ex-Spain) accounted for 49% of the workforce, Spain 31%. 82% held permanent contracts (83% in 2024); 58% worked part-time and 41% full-time, reflecting the retail sector's seasonal staffing needs. The Full-Time Equivalent workforce represented 78% of total jobs. Turnover totalled 135,184 leaves (86% turnover ratio), split 32% voluntary and 54% non-voluntary, the latter influenced by seasonal temporary-contract endings.

Collective bargaining coverage and social dialogue

Reference: pages 167-168.

Globally, 61% of Inditex's workforce is covered by local collective bargaining agreements (61% in 2024); within the European Economic Area the figure is 83% (84% in 2024), and in Spain, "100% of the workforce is covered by collective bargaining agreements." Coverage varies by market, from 0-19% in some Asian and American markets up to 80-100% across Austria, Belgium, Croatia, Spain, Finland, France, Italy, Luxembourg, the Netherlands, Portugal and Sweden. All employees, regardless of collective-agreement coverage, benefit from minimum guarantees under the Code of Conduct and the UNI Global Union Global Agreement, which cites ILO Conventions 87 and 98 on freedom of association and collective bargaining.

Diversity metrics

Reference: pages 163-166.

Women hold 73% of Inditex's workforce and 76% of management positions (77% in 2024); by job classification, women hold 76% of Management, 69% of Supervisor and 74% of Specialist roles. Senior Management includes six women, 26.09% of the total (seven women, 33.33% in 2024). Diversity and inclusion runs on four global pillars — gender equality, LGBTQI+ inclusion, socio-ethnic inclusion and disability inclusion — supported by programmes including Women in Tech (22% of STEM positions held by women in 2025), I AM PROUD (local awareness initiatives in 48 markets), and SALTA (more than 2,100 people hired from at-risk groups since 2008, active in 22 markets). GEEIS gender-equality certification covers the global corporate Group and nine subsidiaries.

Adequate wages

Reference: page 166.

"All of our workforce receive adequate wages," Inditex states, verified through a cascading methodology: checking collective-bargaining-agreement coverage first, then official minimum wages, then market comparisons using the Anker methodology, and finally verification against Directive (EU) 2022/2041 on adequate minimum wages where no other mechanism applies. Global average remuneration was 31,750 euros gross annually in 2025 (30,850 euros in 2024); by gender, women's average remuneration was 31,074 euros and men's 35,818 euros, a gap the report attributes to a higher proportion of women in lower-average-remuneration markets rather than unequal pay, with the gender pay gap indicator (S1-16) providing the more representative equal-pay measure.

Persons with disabilities

Reference: pages 165-166.

At year end 2025, Inditex directly employed 3,339 people with disabilities (3,142 in 2024), 2% of the annual average workforce, of whom 62% were women, 38% men and a small share non-binary or other/unspecified gender. The Company notes it "exceeded our target of doubling the number of people with disabilities we employed with respect to 2021" already in 2024. The INCLUYE programme and annual Impact Week drive integration, alongside for&from, a collaborative retail model generating employment for people with disabilities — 17 stores across Spain, Italy, Mexico and Portugal, including a second Zara Home for&from store opened in Portugal in 2025. Inditex partners on disability inclusion with two university chairs (Miguel Hernández University of Elche/APSA and the University of Barcelona) and is on the ILO Global Business and Disability Network Steering Committee.

Training and skills development metrics

Reference: pages 169-170.

Inditex delivered more than 3.4 million training hours to more than 2.5 million participants in FY2025 (around 3.3 million hours in 2024), reaching 199,037 unique people trained (214,952 in 2024) at an average 21.3 hours per person. Internal promotion filled 80% of the Group's vacancies, translating to more than 9,100 promotions, 73% of which went to women. Flagship programmes include Junior Talent (more than 4,100 candidates, 140 hires from 40 universities and 11 nationalities), the Sustainable Fashion School (over 1,850 people trained across three editions, accredited by the University of Leeds, plus a new denim capsule certified by Polimoda), the Changemakers community (over 5,000 members) and the Inditex Leadership Academy, developed with IE Business School, which trained more than 200 management-team members in 2025.

Health and safety metrics

Reference: pages 170-172.

ISO 45001:2018 is implemented across 33 markets and 612 workplaces, covering 94% of the own workforce (29 markets, 336 workplaces, 86% in 2024); Inditex is recognised as a Healthy Organization in 27 markets. In 2025 there were 41 recordable accidents (55 in 2024), a frequency rate of 0.20 (0.21 in 2024) and severity rate of 0.01. Work-related health events totalled 469 (548 in 2024), including 11 occupational diseases. "In 2025 and 2024, there were no fatalities resulting from recordable accidents or work-related health events." Days lost to recordable accidents, health events or deaths were 15,110 in 2025 (16,695 in 2024). Safety training reached 279,859 employees for 221,254 hours, and 14,762 people participated in Back School and Preventive/Recovery Plans (up from 7,983 in 2024).

Work-life balance metrics

Reference: pages 168-169.

In 2025, 94% of Inditex's workforce was entitled to maternity, paternity or child-fostering leave (99% in 2024), and 5% of the workforce took such leave (6% women, 2% men). Of the 7,404 employees taking maternity/paternity leave, 88% were women. Spain's Equality Plan enshrines splittable leave for hospital stays or dependant care, flexible hours for nursery adaptation, and extended personal, study, adoption or dependant-care leave. Internationally, markets including Germany, Austria, the United States, France, Italy and the United Kingdom extend local rights around flexible hours, dependant-care leave and financial childcare assistance; France, Australia and Slovenia have specific digital-disconnection rights, reinforced at Inditex under Spain's Data Protection Act and the Group's Equality Plan.

Compensation metrics (pay gap and total compensation)

Reference: pages 166-167.

Inditex reports a 0.0% gender pay gap for 2025 on total salary (fixed plus variable), against 0.7% in 2024 and 0.5% in 2023, calculated on median market salaries. By job classification the gap was 0% for specialists, -2% for supervisors and -5% for management (favouring women in the latter two categories), representing 85%, 9% and 6% of the workforce respectively. By geography the gap ranged from -3.2% in Asia and the rest of the world to 0.5% in Europe (ex-Spain). The ratio between the highest-paid individual's total annual remuneration and the median employee remuneration was 267 in 2025 (278 in 2024). Average remuneration by job classification ranged from 27,918 euros (Specialist) to 92,578 euros (Management).

Incidents, complaints and severe human rights impacts

Reference: pages 189-191.

The Ethics Line recorded 1,164 concerns in 2025 (791 in 2024), of which 447 related to Inditex's own people and 124 to the value chain; by topic, 678 concerned labour rights/health/safety and 231 human rights/people/culture. Confirmed cases and remedial measures included 22 cases related to labour rights, health and occupational safety (17 leading to disciplinary measures or termination), 4 discrimination cases and 19 harassment cases (13 leading to disciplinary action). "During 2025 and 2024, no inherently severe human rights-related incidents have been confirmed for our employees or other stakeholders," and no breaches of the UN Guiding Principles, the ILO Declaration or the OECD Guidelines were detected; no reports were received via OECD National Contact Points, and no significant fines, penalties or damages resulted from discrimination or human-rights cases.

Policies related to value chain workers

Reference: page 175.

Inditex's value-chain-worker policies aim to foster "respect for human rights," provide workers with "the tools for their empowerment, participation and well-being," and create social value in workers' communities. Manufacturers and all supplier companies must comply with the Code of Conduct for Manufacturers and Suppliers, which sets minimum ethical and behavioural standards including the prohibition of child and forced labour, alongside the Code of Conduct and Human Rights Policy where applicable. Commitments are delivered mainly through the Workers at the Centre strategy and supply-chain-management initiatives focused on identification, support and remediation, reinforced by the Global Framework Agreement with IndustriALL Global Union and partnerships with the Ethical Trading Initiative and ACT.

Processes for engaging with value chain workers about impacts

Reference: pages 176-177.

Engagement runs through the Global Framework Agreement with IndustriALL Global Union (first signed 2007, renewed 2019), which supports freedom of association and collective bargaining and provides "a crucial direct listening channel" for managing workplace incidents and encouraging worker representation, backed by training for local affiliates; and through ten supplier clusters spanning Spain, Portugal, Morocco, Türkiye, India, Bangladesh, Pakistan, China, Vietnam and Cambodia, which generate local dialogue spaces. Direct interviews with workers and their representatives also occur during regular manufacturer and supplier audits. The Workers at the Centre strategy applies a particular focus to women, migrant workers and raw-material-production workers as especially vulnerable groups. The Chief Sustainability Officer holds delegated operational responsibility for value-chain stakeholder engagement.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 177.

Dedicated remediation mechanisms include a mandatory child-labour remediation plan — triggered when an under-minimum-age worker is found, requiring corrective actions, schooling and a living allowance until minimum working age, or employment of an adult family member, with continuous monitoring alongside external expert organisations — and refugee/migrant remediation plans assessing working and living conditions with support from expert NGOs where needed. Social dialogue under the IndustriALL Global Framework Agreement provides a further conflict-resolution lever. Value-chain workers also have access to the Ethics Line, and Corrective Action Plans (CAPs) developed after social audits give manufacturers structured roadmaps to correct and prevent non-compliance with the Code of Conduct for Manufacturers and Suppliers.

Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions

Reference: pages 177-179.

The Workers at the Centre 2023-2025 strategy, covering five Priority Impact Areas — Social dialogue, Living wages, Respect, Health and Resilience — involved 3,992 suppliers and factories in 2025 through 30 initiatives, cumulatively reaching 3.1 million people since 2023. Health was the largest area (2,159,028 people reached, 1,397 factories involved in 2025); Social dialogue reached 1,031,467 people through 311 factories. Actions are backed by 10,164 supply-chain audits in 2025 (10,923 in 2024), including 1,815 pre-assessments and 6,039 social audits (99% externally conducted), plus 410 social and 590 environmental Corrective Action Plans. Effectiveness is monitored via common indicators (people reached) and initiative-specific metrics, including supply-chain worker surveys.

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

Reference: page 176.

Inditex set a target in 2023 to reach three million people over 2023-2025 through the Workers at the Centre strategy — its primary tool for value-chain human and labour rights and worker well-being. "In 2025, we achieved this goal, reaching 3.1 million people over the course of this three-year period." Close, continuous collaboration and dialogue with specialist organisations and industry players underpins the target's design and tracking; scope, methodology and year-on-year changes are detailed in the Detailed information. Methodology annex, and the MDR-T annex (page 221) confirms "there have been no changes to the target or its calculation methodology, so the results are comparable year-on-year."

Policies related to consumers and end-users

Reference: page 180.

Consumer policies commit Inditex to "respecting our customers' human rights, rejecting any kind of discrimination," complying with "the most demanding quality, health and safety standards," and "guaranteeing information security, particularly in connection with our customers' data and privacy." A further commitment covers responsible marketing and communication, providing "accurate, clear and comprehensive information about products" and avoiding offensive or discriminatory content or content promoting an unhealthy image. These principles are implemented through the mechanisms described across the S4-2 to S4-4 sections and detailed further in the MDR-P Policies section and the Detailed information. Policies annex.

Processes for engaging with consumers and end-users about impacts

Reference: pages 180-181.

Engagement runs through specialised customer service teams per retail concept (handling calls, emails, WhatsApp and social media on products, purchasing, shipments and incidents), physical store teams as the first line of direct contact, and digital channels reaching customers "in more than 200 markets." Interaction occurs before, during and after purchase, initiated by either party, with monthly monitoring of customer-interaction quality via contact-monitoring plans tracking variables such as incidents resolved without recontact. Particular consideration is given to vulnerable consumers, including those dependent on accurate product information and higher-risk groups such as children, with continuous dialogue with partner organisations feeding their perspective into Company operations.

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: pages 181-182.

Inditex maintains three preferred channels for consumer issues: customer service teams, official grievance mechanisms and the Ethics Line. In 2025, 21 million cases were handled through Customer Services across all commercial markets, 80% post-purchase (order status, shipments, changes and returns) and 15% pre-purchase; complaints and claims represented 0.03% of cases. Official consumer complaint and response mechanisms in Spain processed 6,781 cases in 2025 (6,924 in 2024), mainly related to product returns/exchanges and store/online sales. Confidentiality and data protection are maintained throughout, with anonymous communication available except where a query requires order-related follow-up.

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 182-184.

Product health and safety is managed through eight product standards (Safe to Wear, Clear to Wear, Physical Testing Requirements, Active to Wear and specialised cosmetics/food-contact/home-fragrance standards); Picking inspections showed 99.7% initial compliance for Safe to Wear and 99.4% for Physical Testing Requirements in 2025. Digital accessibility follows WCAG 2.2 AA-level standards across brand websites, apps and recruitment platforms. Data protection saw 70 customer-data projects reviewed for privacy-by-design compliance, 87% of required office staff completing mandatory privacy training (97% in 2024), and 83% of store staff across 31 markets trained; two personal-data security incidents in 2025 required notification to data protection authorities (four in 2024).

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

Reference: page 234 (ESRS content index).

Inditex states that "specific targets related to consumers and end-users are not available," directing readers to the S4-1 policies and S4-4 actions sections for how effectiveness and ambition are monitored in their absence [S4.MDR-T_14-19]. In practice this tracking runs through the Picking programme's product-compliance rates and the customer-service and data-protection metrics reported under S4-3/S4-4, which substitute for a stated numeric consumer target.

Business conduct policies and corporate culture

Reference: pages 187-192.

Inditex's ethical culture rests on the premise that "the how matters," codified in the Code of Conduct and Code of Conduct for Manufacturers and Suppliers, with an internal-regulation architecture spanning the Compliance Policy, Due Diligence Policy, Integrity Policies (Gifts and Invitations, Dealings with Public Servants, Donations and Sponsorships), the Anti-Money Laundering and Terrorist Financing Policy, the Conflicts of Interest Policy and the Criminal Risk Prevention Policy. The Board defines and approves these ethical commitments; the Audit and Compliance Committee holds risk-management and business-conduct competencies, receiving quarterly Compliance function reports. The Compliance function comprises the Ethics Committee (chaired independently, appointed by the Board) and the Compliance department, within the General Counsel's Office, whose independence is safeguarded by the Chief Compliance Officer liaising directly with the Audit and Compliance Committee.

Management of relationships with suppliers

Reference: pages 193-196.

Inditex's Inditex Minimum Requirements govern supply-chain relationships, anchored in ten supplier clusters and the Code of Conduct for Manufacturers and Suppliers, the Green to Wear standard and Traceability Requirements. In 2025, 6,684 factories across 49 markets and more than three million workers made up the supply chain (6,615 factories, 50 markets in 2024). Traceability is verified through designation checks, certificate reviews and 10,709 unannounced traceability audits (10,387 in 2024). Social audits classified 61% of active factories 'A' rating and 32% 'B' in 2025 (up from 57% 'A' in 2024); 57% of active factories were audited during the year. Environmental audits under Green to Wear covered 54% of active in-scope factories, with 71% of audited factories rated 'A' or 'B'. Critical non-compliance can end the commercial relationship.

Prevention and detection of corruption and bribery

Reference: pages 191-192.

Inditex operates "zero tolerance for corruption of any kind" through its Global Compliance Model, including a Model of Criminal Risk Prevention in Spain and local anti-corruption models elsewhere, targeting corruption in business, corruption in international transactions, bribery of public officials and influence peddling. In 2025 and 2024 the Group "did not receive... any significant fines or non-monetary penalties for non-compliance with the applicable laws or regulations in the filed of corruption or bribery." Compliance training reached 88% of the priority group of employees exposed to compliance risk in 2025 (86% in 2024, on an updated target-group definition), and 100% of Board members received compliance and/or anti-corruption training, unchanged from 2024. Confirmed corruption cases in 2025 totalled 9 (4 in 2024), with 5 leading to disciplinary measures or termination.

Targets related to business conduct

Back-filled from the business conduct (G1) chapter and its Metrics (MDR-M) annex, where business-conduct effectiveness is addressed as part of the MDR-A/MDR-M disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone targets DR only in the 2025/2026 ESRS.

Inditex's FY2025 statement contains no numeric business-conduct target: the MDR-T (Targets) annex (pages 209-221) lists dedicated target sections for E1, E3, E4, E5 and S2, but no equivalent G1 target section, and the G1-3 concordance-table entry states that "the initiatives carried out during the year are part of the company's normal operations and are presented integrated throughout chapter G1" under MDR-A rather than MDR-T. Consistent with MDR-T's other limb, effectiveness is instead tracked through metrics: "Percentage of the priority group of our employees that has received compliance training" (G1-3_07, page 222), which reached 88% in 2025 (86% in 2024), 100% Board training coverage, Ethics Line concern volumes by topic, and confirmed-case/CAP outcome data reported under G1-3 and G1-4.

Confirmed incidents of corruption or bribery

Reference: pages 189-191.

"With regard to the confirmed reports of corruption, no relevant aspects affecting the Company have been observed in any of them," and during 2025 and 2024 the Group was not aware of legal proceedings concerning corruption or bribery affecting it. Breakdown of Ethics Line-driven outcomes: 9 confirmed cases of corruption or bribery in 2025 (4 in 2024), of which 5 (3 in 2024) resulted in disciplinary measures or termination of employment, and 4 (1 in 2024) resulted in corrective measures or termination/non-renewal of business-partner contracts. Preventing corruption and bribery accounted for 59 of the 1,164 total Ethics Line concerns raised in 2025 (44 of 791 in 2024). In all confirmed breaches, remedial measures ranged from warnings to termination of employment relationships, training or procedural review.

Political influence and lobbying activities

Reference: page 193.

The Policy on Public Policy governs Inditex's engagement in public-policy-making on sustainability, trade, transport, digital, reporting and finance topics; the Group is registered on the EU Transparency Register (number 518095443081-20). The Policy on Donations and Sponsorships "expressly prohibits making donations to political parties, either directly or indirectly," reflected in the Code of Conduct, which also bars offering, granting, soliciting or accepting gifts or invitations from authorities or public officials. Consequently, "no contributions were made (in cash and/or in kind) to political parties during 2025 and 2024." No Board members held a comparable government-administration position in the two years prior to appointment, and the Conflicts of Interest Policy governs any hiring from public authorities that could raise a conflict.

Payment practices

Reference: page 196.

Mandatory Group-wide payment procedures set payment periods and means for all suppliers, including SMEs, based on "long-term relationships and responsible financial management," with bank transfer as the most common method and various supplier financing programmes offered. For trade-creditor invoices, the average payment period in 2025 was 34-42 days against a 60-day standard, with 92-94% of payments within the standard period; the Group pays within EU-regulation limits, with "72% of the volume of payments made to these creditors... paid within 30 days in 2025" (75% in 2024). Inditex adheres to ACT's five commitments on responsible purchasing practices, including respecting fair payment conditions. "No legal proceedings have been brought against the Group for delays in payment to its suppliers, manufacturers and/or third parties" in 2025 or 2024.