Jerónimo Martins SGPS

The Group's governance structure is led by a Board of Directors elected for the 2022-2024 term, comprising 10 members. Pedro Soares dos Santos serves as Chairman of the Board of Directors and Chief Executive Officer, a dual role that provides unified leadership. The Board includes independent directors and members with diverse expertise.

The Board of Directors is responsible for defining the Group's strategic vision based on three key guiding principles: • Leadership: strong banners and brands that enable to achieve and reinforce leadership positions in the markets where it operates • Responsibility: continuous assessment of the impact of the business on the environment and society, an active and significant contribution towards improving the quality of life of our employees, their families and the communities, and towards sustainability as a whole • Independence: careful management of the balance sheet and supply-chain to ensure the continuity of operations and autonomy in strategic decision-making

The Board oversees the Group's mission to operate mainly in the food area, promoting, through its Companies and its Private Brands, the availability of food solutions and products that are safe, healthy and affordable for everyone. Respect for all stakeholders and commitment to the principles of sustainable development are an intrinsic part of its strategy for growth and shared value creation in the short, medium and long term.

The Board has an Audit Committee with 3 members, chaired by Clara Christina Streit since April 2022. The governance structure includes specialized bodies for oversight and control, including the Company Secretary and External Auditor (Ernst & Young Audit & Associados, SROC, S.A.).

Integration of sustainability-related performance in incentive schemes

Roles covered

The integration of sustainability-related performance in incentive schemes applies to:

• Chief Executive Officer (CEO)
• Employees in roles that influence the definition and/or implementation of the Group's climate commitments, targets and actions

CEO remuneration structure

The CEO's remuneration comprises two components:

• Fixed component: monthly remuneration paid in 14 monthly instalments
• Variable component: annual performance-based remuneration

Sustainability KPIs tied to CEO remuneration

The CEO performance review process includes an annual performance assessment with quarterly reviews. These assessments include sustainability targets, with the Company's inclusion and ratings in specific ESG indexes as the main performance indicator.

Weighting and type of incentive

According to the Remuneration Policy, the ESG index performance indicator is:

• Part of a set of key-performance indicators
• Has a 50% weight in the CEO's annual variable remuneration (short-term incentive)

Performance assessment process

The assessments and reviews are:

• Evidence-based
• Involve regular monitoring of the execution of objectives and achievement of goals
• Made available to the Remuneration Committee

Broader employee coverage

The achievement of climate-related and other corporate responsibility objectives is also part of the incentive scheme for employees in roles that influence the definition and/or implementation of the Group's climate commitments, targets and actions.

Consistency with broader workforce

The Remuneration Committee considers it appropriate to guarantee consistency between the quantitative key performance indicators defined for the CEO annual performance evaluation and those that are also considered, according to their responsibilities, in the annual performance appraisal for all Company's managers.

Strategy and Business Model

Strategic Vision

The Group's strategic vision is based on promoting profitable and sustainable growth, through three key guiding principles: • Leadership: strong banners and brands that enable to achieve and reinforce leadership positions in the markets where it operates • Responsibility: continuous assessment of the impact of the business on the environment and society, an active and significant contribution towards improving the quality of life of our employees, their families and the communities, and towards sustainability as a whole • Independence: careful management of the balance sheet and supply-chain to ensure the continuity of operations and autonomy in strategic decision-making

Mission

Jerónimo Martins operates mainly in the food area, promoting, through its Companies and its Private Brands, the availability of food solutions and products that are safe, healthy and affordable for everyone. Respect for all stakeholders and commitment to the principles of sustainable development are an intrinsic part of its strategy for growth and shared value creation in the short, medium and long term, aimed at contributing to the prosperity, the cohesion and the well-being of the communities that its businesses serve.

Business Model and Value Chain

Jerónimo Martins is an economic group based in Portugal with more than 230 years' experience in the food business, meeting the daily needs of millions of consumers through a value proposition that delivers quality food at competitive prices. Food distribution is its primary business activity, which accounts for 98% of its consolidated sales.

The Group has market leadership positions in food retail in Poland and Portugal and an increasingly notable presence in Colombia. The Group operates across three main business areas:

Food Distribution:

• Biedronka (Poland): Chain of food stores aligning proximity locations and quality assortment with competitive prices, accounting for c.70% of sales and c.80% of EBITDA
• Pingo Doce (Portugal): Supermarket chain with restaurant areas in most stores, operating the largest restaurant network in the country
• Recheio (Portugal): Cash & carry stores with specialized food service delivery operation
• Ara (Colombia): Chain of proximity food stores in residential neighbourhoods

Agribusiness:

• Jerónimo Martins Agro-Alimentar (JMA): Focuses on four areas - dairy, livestock farming, aquaculture, and fruit and vegetables, with operations in Portugal and Morocco, and financial stake in Norway

Specialised Retail:

• Hebe (Poland): Health and beauty specialised retail with omnichannel approach
• Jeronymo: Coffee shops and kiosks
• Hussel: Chocolate and confectionery chain

Operational Positioning

The operational positioning reflects an approach focused on value and quality, underpinned by a mass-market strategy designed specifically for the markets and communities in which they operate. The Group offers proximity and convenient food solutions at very competitive prices, requiring operating with maximum efficiency and lean cost structures.

Areas of Focus

When doing business, the Group's Companies have three areas of focus, common to all countries: • Consumer: democratise access to quality food products and solutions, guaranteeing maximum security and savings • Employee: provide a healthy work environment, fair remuneration, and development opportunities • Business partners: establish long-term relationships that enable shared value creation and growth

Interests and views of stakeholders

Key stakeholder groups identified

Jerónimo Martins identifies the following key internal and external stakeholder groups:

Internal stakeholders:

• Employees
• Employees' representatives

External stakeholders:

• Shareholders and investors
• Analysts
• Official bodies, supervising entities and local authorities
• Suppliers and business partners
• Customers and consumers
• Local communities
• Journalists
• Non-governmental organisations and associations

Engagement channels and frequency

The Group defines specific internal and external communication channels according to different audiences' needs and expectations:

Integration of stakeholder views

The views and interests of key internal and external stakeholders are continuously discussed within the relevant divisions and areas. The Corporate Communications and Responsibility Division communicates with transparency the Group's ESG performance, including positive achievements as well as areas of improvement. Through constant dialogue with various internal and external stakeholders, concerns and expectations are incorporated into strategic priorities and major lines of action, promoting better common understanding of business perspectives.

The Committee on Corporate Governance and Corporate Responsibility monitors and supervises matters concerning corporate governance, social responsibility, the environment, ethics, business sustainability, internal codes of ethics and conduct, and systems for assessing and resolving conflicts of interest, particularly in relations between the Group and its stakeholders.

The Investor Relations Office organizes and participates in events to provide investors with an updated and clear vision of Jerónimo Martins' strategies, operational performance, and outlook. Annual reports are prepared in accordance with the main frameworks, methodologies and information requests made by stakeholders.

Key concerns raised during the reporting period

Affected communities:

The B4SI methodology, used to measure social impact, involves an annual survey of supported organisations to understand how support is allocated and the different types of impact on beneficiaries and community organisations. The survey includes an open-ended response field which institutions can use to submit additional needs to be passed on to the Group or its Companies.

In 2024, the nearly 79.6 million euros allocated to 515 organisations positively impacted around 2.3 million people. The majority of beneficiaries (84%) surveyed by institutions that support people in vulnerable situations reported positive impacts in their quality of life. Institutions also report that the support received has enabled them to offer more to their beneficiaries and improve the fulfilment of their mission.

Own workforce:

In 2024, the Group participated in a voluntary assessment process through the Human Rights Coalition (HRC) to understand the level of maturity of its human rights due diligence process, which measured commitments and policies, governance structure, risk assessment, action planning, stakeholder engagement, grievance mechanisms and reporting channels in different dimensions, such as forced labour and occupational health and safety.

Consumers:

The Group values dialogue with customers, with each case treated on an individual basis to understand the customer's perspective and reach a mutually agreed resolution whenever possible. Resolution mechanisms include clarification about reported situations, personalised apologies, discount offers through vouchers, refunds, replacements or reparations of products, depending on the nature of the grievance.

Distinction between affected stakeholders and users of sustainability information

While the table above lists all key stakeholder groups, the reporting distinguishes between:

Affected stakeholders (those impacted by the business):

• Own workforce (employees and employees' representatives)
• Workers in the value chain
• Affected communities (local communities surrounding operations)
• Consumers and end-users (customers)

Users of sustainability information:

• Shareholders and investors
• Analysts
• Official bodies and supervising entities

The Investor Relations Office specifically organizes events to provide investors with updated and clear vision of strategies, operational performance, and outlook, maintaining benchmark levels of dialogue for stakeholders focused on financial and sustainability information.

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

Overview

The Jerónimo Martins Group primarily operates in the food sector, promoting safe, healthy, and affordable food solutions and products through its Companies and Private Brands. Respect for all stakeholders and a commitment to sustainable development principles are integral to its growth and value creation strategy. This approach aims to contribute to the prosperity, cohesion, and well-being of the communities served by its businesses in the short, medium and long term.

Double Materiality Assessment Process

In 2023, Jerónimo Martins conducted its first double materiality assessment in accordance with the preliminary version of the requirements established by the EU's Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS). The process began with the identification of a preliminary list of potential material topics and their impacts, risks and opportunities (IROs). A stakeholder consultation was then carried out to collect input on Jerónimo Martins' impact on different sustainability topics.

This assessment gathered information from more than 16,600 stakeholders from nine different groups (employees, consumers, suppliers and service providers, non-governmental organisations, private charities, analysts and investors, the media, sectoral associations, insurance companies, and opinion makers), in Poland, Portugal and Colombia, to assess the impact materiality along the value chain, considering both severity (scale, scope and irremediability of the impact) and likelihood of occurrence. In addition to the input from these stakeholders, the impact matrix also considered internal and external expertise.

Material financial issues were identified using the Group's risk management system. The assessment considered risks and opportunities along the value chain, based on their magnitude (potential financial impact on sales and costs) and likelihood of occurrence. Once completed, the assessment was also validated by senior managers and members of the Executive Management Team.

2024 Review

In 2024, the assessment was reviewed in accordance with the final version of the ESRS and the final versions of the implementation guidance published in May 2024 by EFRAG. Stakeholders were not consulted again in 2024, but the findings of the 2023 financial year were taken into account. The IROs were again assessed and complemented with desk research and benchmark analysis.

Total IROs Identified

A total of 145 IROs were identified in the 2024 review:

*The same IRO may be identified (fully or partially) for different levels of the value chain, therefore justifying sums above the total.

Of the 145 IROs analysed, 21 were evaluated as material. A total of 35 environmental, social and governance (ESG) sub-topics were identified, 10 of which were considered material to Jerónimo Martins, according to internal thresholds (the ranges applicable to the Enterprise Risk Management processes).

Material Topics and Associated IROs

Ten Most Material Topics

The ten most material topics identified in 2024 as a result of the consolidated double materiality assessment:

1. Product safety and quality standards
2. Product affordability
3. Sustainable and responsible criteria in the supply chain
4. Labour rights and working conditions - own workforce
5. Food waste
6. Product and services innovation
7. Climate change
8. Packaging redesign for sustainable resource use
9. Employee learning and development
10. Engagement and supporting local communities

Like in 2023, the topics "Product safety and quality standards" and "Product affordability" were considered the most relevant both from an impact and financial point of view (risks and opportunities).

Topics Identified by Stakeholders (Impact Materiality)

The topics identified directly by the consulted stakeholders and included in the double materiality matrix are:

• Sustainable and responsible criteria in the supply chain
• Packaging redesign for sustainable resource use
• Employee learning and development
• Engagement and supporting local communities

Topics Identified Through Risk Assessment (Financial Materiality)

The risk assessment highlighted the topics "Labour rights and working conditions - own workforce", "Food waste", "Employee learning and development" and "Product and services innovation" as those with the greatest potential to have a positive or negative financial impact on the Group's business.

Materiality Thresholds

Risks and opportunities are considered material when they exceed a potential variation of 5% in sales (set as the materiality threshold) considering inherent risk. These cases are identified, assessed and managed at corporate level. Where they fall below that threshold (up to 5% of sales) they are identified and assessed at corporate level and managed at Company level.

Climate-Related Risks and Opportunities

Governance

The decarbonisation strategy and management of climate-related risks and opportunities is monitored and supported by the Board of Directors, ensuring that climate-related topics are integrated into the corporate strategy, in particular the sustainability strategy, both in own operations and in the supply chain. Executive responsibility rests with the Group's CEO, who is also Chairman of the Board and of the Committee on Corporate Governance and Corporate Responsibility (CGSRC).

Climate change mitigation and adaptation and the GHG emission reduction targets set out in the Climate Transition Plan are discussed in regular meetings held by the Sustainability Committees of each Company and by the CGSRC.

Climate-related risks, incorporated into the environmental risks of the risk management nomenclature, are integrated into the Group's multidisciplinary management process.

Risk Management Process

The identification, assessment and management of climate-related risks and opportunities is part of an integrated corporate risk management process, in line with ISO 31000, and includes a Risk Exposure Matrix with four levels calculated on the basis of two dimensions: probability and impact, for which the Group uses four metrics (sales, EBITDA, safety and reputation) according to the type of risk or opportunity.

The process covers the value chain of the Group's Companies with a turnover of more than 100 million euros (accounting for 99.95% of total turnover) and involves Private Brand and perishables suppliers.

Climate Risks Assessed

Physical risks (acute and chronic):

• Production: Extreme heat or cold; Temperature variation; Water shortages; Change in precipitation patterns
• Processing: Extreme heat or cold
• Logistics: Strong winds; Rise in average sea level; Resilience of ports
• Establishments: Extreme heat or cold; Rise in average sea level (e.g. coastal flood risk)

Transition risks:

• Market: Energy transition (Processing)
• Technological: Energy transition; Compliance risk and replacement of refrigerant gases (Establishments)
• Reputational: Changes in consumer preferences; Increased concern from stakeholders about climate performance (Consumer/Community)

Climate Risks and Opportunities Considered in Strategy

Circular Economy-Related Risks and Opportunities

The main risks and opportunities identified associated with the circular economy, in particular with packaging and food waste, are related to the types of resources used (renewable and non-renewable), the waste of resources, and the recovery and recycling of waste.

Risks assessed using the LEAP (Locate, Evaluate, Assess and Prepare) approach include:

• Transition risks (political, regulatory, market, technological and reputational)
• Physical risks (e.g. the risk of a raw material shortage)

Because of the potential loss to the value chain, food waste is the most material circular economy risk. The risks associated with regulations, particularly on the recyclability of packaging, are of minor importance.

Biodiversity and Ecosystems

The Group assesses risks related to ecosystem services in accordance with the Ecosystem Services Review methodology proposed by the World Research Institute. Based on this approach, 11 priority action areas were defined (e.g. agricultural crops, pollination, animal production, fish caught and aquaculture), based on the dependencies and impacts on ecosystem services.

By 2026, the goal is to identify and quantify the financial effects of the impacts, risks and opportunities associated with biodiversity and with ecosystems.

Integration with Strategy and Business Model

The Group's approach to managing material IROs is embedded in:

• The corporate responsibility strategy and policies
• The Climate Transition Plan (validated by SBTi in May 2024)
• Investment decisions (estimated annual average of 10% of total consolidated CapEx allocated to climate targets)
• Employee incentive schemes (climate-related and other corporate responsibility objectives included)
• Supply chain engagement programmes
• Sustainable finance framework

Resilience to Material IROs

The Group demonstrates resilience through:

• Structured risk management processes integrated with strategic planning
• Annual risk assessments involving around 70 managers across Companies and countries
• Quarterly reviews to address critical business issues and monitor emerging risks
• Continuous monitoring and reporting to executive management, Audit Committee and Board of Directors
• Allocation of resources through CapEx and OpEx to address material impacts and risks
• Stakeholder engagement and due diligence processes throughout the value chain

Review Frequency

Jerónimo Martins intends to repeat the double materiality assessment every three years. In the interim, adjustments will be made where required to ensure the assessment is kept current.

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

Overview

In 2023, Jerónimo Martins conducted its first double materiality assessment in accordance with the preliminary version of the requirements established by the EU's Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS). In 2024, the assessment was reviewed in accordance with the final version of the ESRS and the final versions of the implementation guidance published in May 2024 by EFRAG (European Financial Reporting Advisory Group).

Step-by-step methodology

The double materiality assessment process followed these steps:

1. Identification of preliminary list: The process began with the identification of a preliminary list of potential material topics and their impacts, risks and opportunities (IROs).

2. Stakeholder consultation (2023): A stakeholder consultation was carried out to collect input on Jerónimo Martins' impact on different sustainability topics. This assessment gathered information from more than 16,600 stakeholders from nine different groups, in Poland, Portugal and Colombia.

3. Impact materiality assessment: The impact matrix considered:

   • Severity (scale, scope and irremediability of the impact)
   • Likelihood of occurrence
   • Internal and external expertise
   • Input from stakeholders

4. Financial materiality assessment: Material financial issues were identified using the Group's risk management system. The assessment considered risks and opportunities along the value chain, based on:

   • Magnitude (potential financial impact on sales and costs)
   • Likelihood of occurrence

5. Validation: The assessment was validated by senior managers and members of the Executive Management Team.

6. Review in 2024: The IROs were assessed and complemented with desk research and benchmark analysis. Stakeholders were not consulted again in 2024, but the findings of the 2023 financial year were taken into account.

Inputs to the assessment

2023 Assessment:

• Stakeholder consultation: More than 16,600 stakeholders from nine different groups (employees, consumers, suppliers and service providers, non-governmental organisations, private charities, analysts and investors, the media, sectoral associations, insurance companies, and opinion makers)
• Internal expertise: Senior managers and Executive Management Team
• External expertise: External experts
• Risk management system: Group's existing risk management framework

2024 Assessment:

• Findings from 2023 financial year
• Desk research
• Benchmark analysis
• Final version of ESRS and EFRAG implementation guidance (May 2024)

Scoring criteria

Impact materiality:

• Severity (comprising scale, scope and irremediability of the impact)
• Likelihood of occurrence

Financial materiality:

• Magnitude (potential financial impact on sales and costs)
• Likelihood of occurrence

Threshold for materiality

Risks and opportunities are considered material when they exceed a potential variation of 5% in sales (set as the materiality threshold) considering their inherent risk. These cases are identified, assessed and managed at corporate level. Where they fall below that threshold (up to 5% of sales) they are identified and assessed at corporate level and managed at Company level.

The thresholds are aligned with the ranges applicable to the Enterprise Risk Management processes.

Total IROs assessed

A total of 145 IROs were identified in the 2024 review, broken down as follows:

*The same IRO may be identified (fully or partially) for different levels of the value chain, therefore justifying sums above the total.

Of the 145 IROs analysed, 21 were evaluated as material. A total of 35 environmental, social and governance (ESG) sub-topics were identified, 10 of which were considered material to Jerónimo Martins.

Value chain mapping

The assessment considered different time horizons (short, medium and long term) and the stage of the value chain in which IROs may occur:

• Upstream (e.g. suppliers, production)
• Direct operations (e.g. stores, distribution centres, head office buildings)
• Downstream (e.g. consumers, end-of-life)

Frequency and last review

• First assessment: 2023
• Last review: 2024
• The assessment is reviewed annually in accordance with the Group's risk management framework

Specific risk management processes

Climate-related risks and opportunities:

• Managed as part of an integrated corporate risk management process, in line with ISO 31000
• Risk Exposure Matrix with four levels calculated on the basis of two dimensions: probability and impact
• Four metrics used: sales, EBITDA, safety and reputation
• Since 2020, all climate-related physical and transition opportunities and risks that are considered material have been assessed annually
• Assessment covered more than 6,000 establishments (stores, distribution centres, head office buildings, central kitchens and industrial units) in six countries (Poland, Portugal, Colombia, Morocco, Czechia and Slovakia) in 2024

Circular economy-related risks and opportunities:

• Assessed using the LEAP (Locate, Evaluate, Assess and Prepare) approach
• Monitoring specific regulations of each country
• Detailed assessment of recyclability of Private Brand packaging using Ellen MacArthur Foundation methodology
• Assessment of food waste following Food Loss and Waste Protocol best practices

Biodiversity and ecosystems:

• Risks assessed in accordance with the Ecosystem Services Review methodology proposed by the World Research Institute
• 11 priority action areas defined based on dependencies and impacts on ecosystem services
• Goal to identify and quantify financial effects of impacts, risks and opportunities by 2026

Integration with risk management

The identification, assessment and management of sustainability-related risks and opportunities is integrated into the Group's overall risk management framework, which is described in Chapter 4 "Corporate Governance", section C "Internal Organisation", subsection III "Internal Control and Risk Management".

Transition plan for climate change mitigation

Scope of the plan

The Climate Transition Plan covers:

• Entities: Jerónimo Martins Group companies with turnover >100 million euros (accounting for 99.95% of total turnover)
• Geographies: Poland, Portugal, Colombia, Morocco, Czechia and Slovakia
• Value chain segments: Own operations (distribution centres, stores, industrial units and farms - referred to as establishments), logistics, sourcing with suppliers (especially food products), and consumers
• Activities: Retail (98.4% of energy consumption), agriculture and fishing (Section A, NACE rev.2) (0.4%), manufacturing (Section C, NACE rev.2) (1.1%), and accommodation (Jeronymo, Section I, NACE rev.2) (0.1%)

The plan sets greenhouse gas (GHG) reduction targets and lays out the decarbonisation strategy, supported by initiatives by Companies in their own operations and, through close collaboration with suppliers, also in their supply chains.

Target year(s) for net zero / carbon neutral

Carbon neutrality targets:

• By 2045, reduce scope 1 and 2 emissions (energy and manufacturing) by 90%, compared to 2021
• By 2050, reduce scope 3 emissions (energy and manufacturing) by 90%, compared to 2021
• By 2050, reduce forest, land and agriculture (FLAG) emissions by 72%, compared to 2021
• By 2050, neutralise residual GHG emissions through projects that meet strict eligibility criteria, in line with international best practices

Scope 1, 2, 3 reduction milestones with baseline years

Baseline year: 2021

Short-term targets (by 2033):

• Reduce scope 1 and 2 emissions (energy and manufacturing) by 55%, compared to 2021
• Reduce scope 3 emissions (energy and manufacturing) by 33%, compared to 2021
• Reduce forest, land and agriculture (FLAG) emissions by 39%, compared to 2021

Intermediate targets (by 2026):

• Reduce the Group's scope 1 and 2 emissions, in absolute terms, by at least 10%, compared to 2021
• Reduce carbon emissions from transporting goods to stores by 5% (in tonnes of CO2e per pallet transported), compared to 2021
• By 2030, ensure that 60% of electricity used is from renewable sources

Progress achieved:

• By the end of 2024, reduced GHG emissions (scopes 1 and 2) by 19% compared to 2021, meeting and exceeding the target
• Carbon emissions associated with goods transport reduced by 6.1% compared to 2021, above the 5% target set

2024 emissions performance:

• Scope 1 and 2 GHG emissions: 783,000 tonnes CO2e in 2024, 15.8% less than in 2023 and 19% less than in 2021
• Total carbon footprint (scopes 1, 2 and 3): 33,546,395 tonnes CO2e in 2024
• Scope 3 emissions: 32,763,786 tonnes CO2e in 2024 (4.9% increase from 2023)

Alignment with 1.5°C / SBTi validation status

In May 2024, the Science Based Targets Initiative (SBTi) validated the proposed GHG reduction targets, making Jerónimo Martins the first food retail company with head-office in Portugal to have its short-term and carbon neutrality targets recognised by the initiative.

The reduction targets ensure alignment with:

• EU 2030 emissions reduction targets
• Science-based pathways for compliance with the Paris Agreement
• GHG reduction trend that limits the rise in average temperature to 1.5°C

The Group Companies are included in the EU Paris-aligned benchmarks as defined in point E1-1 paragraph 16(g) of Annex I of the European Sustainability Reporting Standards (ESRS).

Key levers / decarbonization pillars

Initiatives to reduce GHG emissions in own operations:

2024 progress on key levers:

Renewable energy:

• 2,101 buildings with photovoltaic panels for self-consumption (779 in 2023)
• Energy generated: 295,776 GJ/year (113,901 GJ/year in 2023)
• Savings: 35,567 t CO2e/year (15,772 in 2023)

Refrigerant gases:

• 70% of distribution centres and industrial units using natural or low GWP refrigerant gases
• Around 57% of stores with refrigeration systems running on natural or low GWP refrigerant gases
• Around 86% of stores using stand-alone refrigeration units (freezers) with natural gases

Energy consumption:

• Total energy consumption: 2,206,538 MWh in 2024 (0.8% decrease from 2023)
• Energy intensity: 65.9 MWh per million euros, 9.3% less than in 2023
• 46% of energy from non-renewable sources, 54% from renewable sources

Supply chain initiatives:

• Public commitments to ensure no association with deforestation or conversion of high conservation value ecosystems linked to production of main commodities (palm oil, soy, paper/wood and beef)
• Supporting fruit and vegetable suppliers in adopting sustainable agricultural practices
• Promoting sustainable energy use
• Optimising distribution routes and increased investment in more efficient transport solutions
• Fighting and reducing food waste
• Promoting the ecodesign of packaging
• Fighting plastic pollution

Supplier engagement programme:

• In 2024, engaged with 19 suppliers of Private Brand products and perishables
• 50% of suppliers have climate targets validated by SBTi, 20% in process of defining targets
• 50% of suppliers publish climate transition or decarbonisation plans
• 80% perform energy audits and improve energy efficiency
• 70% purchase and generate renewable energy for self-consumption
• 50% invest in reducing transport emissions

Logistics:

• Biedronka: awarded second Lean & Green star after reducing carbon emissions by further 12% between 2021-2023
• Pingo Doce: achieved four Lean & Green stars for 55% reduction in CO2e emissions (tCO2e/pallet) compared to 2018
• JMA Terra Alegre: awarded first Lean & Green star for 23.4% reduction in logistics CO2e emissions in 2023 vs 2022

CapEx / investment commitments

In 2023, the Board of Directors decided to allocate an estimated annual average of 10% of total consolidated CapEx to the implementation of climate targets.

The implementation of climate commitments is underpinned by ongoing investments, with execution cycles aligned with the business plan, including:

• Installation of photovoltaic systems for self-consumption of renewable electricity in Poland, Portugal and Colombia
• Use of natural refrigerant gases in cooling and freezing units and equipment
• Purchase of certified renewable electricity to power operations in Portugal and Poland (OpEx)

The majority of expenditure is allocated to the acquisition of goods and services from economic activities related to energy efficiency and renewable energy technologies.

As the Taxonomy does not yet include them as eligible activities, investments in reducing refrigerant leaks (particularly high GWP) are not captured as Taxonomy-aligned CapEx, despite accounting for around 15% of scope 1 and 2 emissions in 2024.

Locked-in emissions and stranded asset analysis

The Group's Companies are not exposed to locked-in greenhouse gas emissions associated with their main assets and products and, as such, they are not included as a transition risk.

Use of carbon credits / removals

The Group Companies have not acquired carbon credits to offset their scope 1, 2 or 3 emissions, nor have they implemented removal or storage projects in their operations or value chain.

Commitment to neutralise residual scopes 1 and 2 GHG emissions through projects that meet strict eligibility criteria, in line with international best practices by 2050.

In 2024, within the scope of the Climate Transition Plan, the Group continued to identify solutions to neutralise emissions in line with international criteria and best practices (e.g., agricultural carbon sequestration practices).

Internal carbon pricing

A shadow price is applied as internal carbon price, updated annually in line with carbon tax updates in Portugal and Colombia. In 2024, the internal carbon price was €28.40/tCO2, calculated as weighted average of:

• Portugal: €62.45/tCO2
• Colombia: €5.86/tCO2
• Poland: excluded as tax too low (€0.09/tCO2)

Scope of internal carbon pricing:

• Scope 1 GHG emissions from fuel consumption: 86,895 tCO2e (42.7% of scope 1)
• Scope 3 emissions from fuel and energy activities: 16,178 tCO2e
• Scope 3 upstream transportation and distribution: 260,575 tCO2e (1% of total scope 3)

The internal carbon price is used to:

• Promote reduction of emissions related to fuel consumption in own operations and supply chain
• Support investment decisions (CapEx) for achieving GHG reduction targets
• Support decisions on own fleet and equipment purchases
• Assess store refurbishment budgets
• Assess transition risks of energy prices within climate scenario analysis
• Anticipate impact of carbon tax legislation on the Group

Policies related to climate change mitigation and adaptation

Jerónimo Martins' management of climate change is governed by several policies and codes that integrate climate considerations into the business model and strategy.

Environmental Policy

• Key content: Fighting climate change is identified as one of the priorities. The policy governs management of environmental challenges including climate-related risks and opportunities.
• Scope: Applies to the Group's operations and supply chain
• Public availability: Available on the company website (www.jeronimomartins.com)
• Monitoring: The Climate Transition Plan sets greenhouse gas (GHG) reduction targets and lays out the decarbonisation strategy, supported by initiatives by the Group's Companies in their own operations and, through close collaboration with suppliers, also in their supply chains. In May 2024, the Science Based Targets initiative (SBTi) validated the Group's proposed GHG reduction targets.

Sustainable Sourcing Policy

• Key content: Addresses climate considerations in sourcing decisions, particularly relating to supply chain resilience and carbon emissions reduction
• Scope: Covers Private Brand and perishables suppliers
• Public availability: Available on the company website

Product Quality and Safety Policy

• Public availability: Available on the company website

Code of Conduct

• Public availability: Available on the company website

Code of Conduct for Suppliers

• Public availability: Available on the company website

Governance and oversight

The decarbonisation strategy and management of climate-related risks and opportunities is monitored and supported by the Board of Directors, ensuring climate-related topics are integrated into the corporate strategy. Executive responsibility rests with the Group's CEO, who is also Chairman of the Board and of the Committee on Corporate Governance and Corporate Responsibility (CGSRC).

Climate change mitigation and adaptation and the GHG emission reduction targets set out in the Climate Transition Plan are discussed in regular meetings held by the Sustainability Committees of each Company and by the CGSRC, which assists the Board of Directors in assessing and submitting proposals on the corporate responsibility strategy.

Integration with incentive schemes

The achievement of climate-related and other corporate responsibility objectives is part of the incentive scheme for employees in roles that influence the definition and/or implementation of the Company's climate commitments and targets.

Risk Management Policy

The Board of Directors defines the Group's risk management policy and objectives. Climate-related risks, incorporated into the environmental risks of the Group's risk management nomenclature, are integrated into the Group's multidisciplinary management process.

Actions and resources in relation to climate change policies

Strategic context

As a food retailer with operations in the agri-food sector, Jerónimo Martins depends substantially on favourable climate conditions throughout its value chain. The mitigation and adaptation strategy on climate change aims to reduce physical and transition risks by sustainably reducing GHG emissions in own operations and in the supply chain, involving suppliers in the decarbonisation roadmap.

The plan includes intervention measures in own operations (distribution centres, stores, industrial units and farms), in logistics, in sourcing together with suppliers (especially of food products), and for consumers.

Initiatives to reduce GHG emissions in own operations

Scope: Own operations (distribution centres, stores, industrial units and farms)

Time horizons:

• Short-term: By 2026 (energy efficiency target)
• Medium-term: By 2030 (renewable energy and refrigerant gases in Poland/Portugal)
• Long-term: By 2035 (refrigerant gases in Colombia)

Management of refrigerant gases

The company invests in more efficient refrigeration and air conditioning equipment to reduce energy consumption and GHG emissions from leaks. The company has installed leak control technologies and voluntarily opts for natural refrigerant gases or those with low Global Warming Potential.

Progress in 2024:

In 2024, refrigeration systems of 70% of distribution centres and industrial units, and around 57% of stores were running on natural or low GWP refrigerant gases. Investment in stand-alone refrigeration units (freezers) reached approximately 86% of stores (3,489 at Biedronka, 1,404 at Ara, 305 at Pingo Doce, and 40 at Recheio).

Energy efficiency and renewable energies

The refurbishment and new store opening plan includes:

• Technologies for generating renewable energy
• Energy control and management systems
• Refrigeration technologies and efficient freezers
• Efficient lighting

Renewable energy sources now account for more than 53% of total energy consumption by operations. Considering electricity consumption alone, around 62% came from renewable sources.

Scope: Own operations (stores, distribution centres, industrial units)

Transition from fossil fuels and increased logistics efficiency

Actions include:

• Increasing the proportion of electric and/or plug-in hybrid vehicles in the light vehicle fleet
• Increasing the use of biofuels and hydrogen
• Progressively reducing fossil fuel use by electrifying equipment

Scope: Own operations and logistics

Internal carbon pricing

The company applies a shadow price as an internal carbon price, updated annually in line with carbon tax updates in Portugal and Colombia. This is calculated on the basis of a weighted average of carbon taxes in Portugal (€62.45/tCO₂) and Colombia (€5.86/tCO₂).

Purpose:

• Promote reduction of emissions related to fuel consumption in own operations (scope 1) and supply chain (scope 3)
• Support decisions on: investing in fuel-efficient passenger vehicles; integrating fuel efficiency as a criterion for selecting outsourced transport; replacing fuel with natural gas
• Anticipate impact of carbon tax legislation

Collaboration with suppliers

Between 2021 and 2024, more than 230 Biedronka, Pingo Doce, Recheio and Ara perishables and Private Brand suppliers collaborated with climate assessment, resulting in identification of different climate adaptation and mitigation measures to reduce GHG emissions.

Examples of supplier adaptation measures identified:

Scope: Upstream value chain (suppliers)

Performance commitments (2024-2026)

• Energy consumption: Reduce by 10% (in GJ per €1,000 of sales) by 2026, compared to 2021
• Water withdrawal: Reduce in Distribution activities by 10% (per €1,000 of sales) by 2026, compared to 2021
• Transport emissions: Reduce carbon emissions resulting from transporting goods to stores by 5% (in tonnes of CO₂e per pallet transported) by 2026, compared to 2021
• Waste recovery: Ensure an annual waste recovery rate of at least 85% of the volume of waste generated by 2026
• Environmental certification: Achieve environmental certification for at least 70% of all distribution centres and industrial units by 2026

Resources allocated

Non-financial resources:

• Around 70 managers representing the Group's Companies and countries participate in the annual risk management process
• More than 230 suppliers engaged in climate assessment between 2021-2024
• Assessment of risks and opportunities in 2024 covered more than 6,000 establishments (stores, distribution centres, head office buildings, central kitchens and industrial units) in six countries

Financial resources: Not quantified in the excerpts provided.

Carbon footprint performance (2024)

Scope 1 and 2 emissions: 783,000 tonnes CO₂e in 2024, representing:

• 15.8% reduction vs 2023
• 19% reduction vs 2021 (base year for SBTi-aligned commitments)

Main reduction drivers: contraction in carbon intensity of Polish power grid, investments in renewable energy purchase and production, acquisition of cooling systems with natural or low GWP refrigerant gases.

Targets related to climate change mitigation and adaptation

Overview

In May 2024, the Science Based Targets initiative (SBTi) validated Jerónimo Martins' proposed GHG reduction targets, reflecting the company's commitment to fighting climate change. The targets are aligned with the Paris Agreement and the EU 2030 emissions reduction targets.

Short-term targets (2033)

Long-term targets (Net Zero by 2050)

Intermediate targets (2026)

Energy and renewable electricity targets

Refrigerant targets

Supply chain engagement target

Progress 2024: 20 of Biedronka, Pingo Doce and Recheio's main suppliers were contacted as part of scope 3 emissions reduction plan. By 2026, will also engage main suppliers from Ara, Hebe and JMA.

Carbon pricing

The company uses internal shadow carbon prices to support investment decisions on CapEx for achieving GHG reduction targets. Carbon pricing is linked to carbon tax prices in Portugal and Colombia, corresponding to an average of €28.40/tCO₂e.

Emissions intensity

Progress 2024: GHG emissions intensity (scopes 1, 2 and 3) based on net revenue fell from 1.051 to 1.002 tonnes of CO₂e per €1,000 of sales.

Energy consumption and mix

Total energy consumption (2024 and 2023)

By business unit:

Energy consumption by source (disaggregated mix)

Methodology note: ** As the Group was unable to determine the proportion of renewable fuels due to the lack of public data, the worst-case scenario was considered (0% consumption of fuels from renewable sources). The Group does not have any non-renewable energy generation plants. The only non-renewable energy is generated occasionally by emergency generators.

Scope 2 emissions concern location-based (heating) and market-based (electricity) type emission factors.

Energy intensity

Energy intensity (per million EUR of net revenue from high climate impact sectors):

• 2024: 65.9 MWh/million EUR
• 2023: 72.7 MWh/million EUR
• Change: -9.3%

Net revenue from activities in high climate impact sectors: €33,464 million (2024) vs. €30,608 million (2023), +9.3%

High climate impact sectors considered: Section A (Agriculture, Forestry and Fishing), Section C (Manufacturing), and Section G (Wholesale and Retail Trade) under NACE rev.2. Retail accounts for 98.4% of energy consumption, manufacturing 1.1%, agriculture and fishing 0.4%, and Section I (Jeronymo) 0.1%.

Renewable energy generation detail

** At the end of 2024, there were 1,695 operational Biedronka buildings, 45 waiting to be connected to the electricity grid and 64 new photovoltaic power plants under construction.

Purchased electricity bundled with guarantees of origin

In 2024, electricity purchased with Guarantees of Origin (GO) or renewable energy certificates: Portugal (Pingo Doce and Recheio) and Poland (Biedronka) purchased renewable electricity. Biedronka also had a Virtual Power Purchase Agreement (VPPA) guaranteeing production of 226 thousand GJ of photovoltaic solar energy. Around 62% of electricity consumed came from renewable sources (considering electricity alone).

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions (gross direct)

Scope 1 sub-breakdown (tCO₂eq):

Note: All Scope 1 emissions are reported as gross figures (tCO₂eq).

Scope 2 GHG emissions (gross indirect from purchased energy)

Note: Market-based method accounts for contractual renewable energy instruments and certificates. Location-based uses average grid emission factors.

Scope 3 GHG emissions (gross indirect from value chain)

Methodology note: Categories 8 (Upstream leased assets), 10 (Processing of sold products), 13 (Downstream leased assets), 14 (Franchises), and 15 (Investments) are either not material or not applicable to the Group's business model and are therefore excluded from reported Scope 3 totals.

Total GHG emissions (Scopes 1 + 2 + 3)

Calculation: Scope 1 + Scope 2 (market-based) + Scope 3.

GHG emissions intensity

Calculation basis: Total GHG emissions (market-based) divided by consolidated net sales and services rendered.

Biogenic CO₂ emissions (reported separately)

Note: Biogenic emissions are reported separately from Scopes 1, 2, and 3 in accordance with GHG Protocol standards.

Baseline and targets context

Note: The Group's Science Based Targets initiative (SBTi)-approved near-term and long-term targets are disclosed elsewhere (E1-4). The baseline year for these targets is 2018, though absolute baseline figures are not reproduced in the sustainability highlights or financial excerpts provided.

Scope and methodology notes

• Organisational boundary: Operational control approach. Covers fully consolidated subsidiaries in Portugal, Poland, and Colombia. Startup operations in Morocco, Czechia, and Slovakia have immaterial contribution and are included in their respective business units.
• Gases included: CO₂, CH₄, N₂O, and HFCs (refrigerant leakage). All converted to CO₂ equivalents using AR5 (IPCC Fifth Assessment Report) 100-year GWPs.
• Scope 2 method: Both location-based (grid average factors) and market-based (contractual instruments, residual mix) are reported. Market-based is used for target-setting and total emissions.
• Scope 3 coverage: 9 of 15 GHG Protocol categories are quantified. Categories 8, 10, 13, 14, and 15 are assessed as not material or not applicable.
• Calculation standards: GHG Protocol Corporate Accounting and Reporting Standard; GHG Protocol Scope 2 Guidance; GHG Protocol Corporate Value Chain (Scope 3) Standard.
• Data quality: Primary activity data used for Scopes 1 and 2. Scope 3 relies on a mix of supplier-specific data (where available) and secondary emission factors (spend-based and average-data methods).
• Verification: Scope 1 and Scope 2 emissions are subject to limited assurance by an independent third party. Scope 3 undergoes internal review; external assurance is planned for future reporting cycles.

Year-on-year change summary

Note: Absolute emissions decreased across all scopes in 2024. Intensity improvement reflects both absolute reduction and revenue growth (+9.3% in consolidated sales). The Group attributes reductions to energy efficiency projects, increased renewable energy procurement, photovoltaic installations (~2,000 stores and distribution centres), and supply-chain engagement programmes.

Additional context

• Renewable energy: Approximately 45% of Biedronka stores in Poland have photovoltaic panels installed as of year-end 2024.
• Energy efficiency: The Group achieved a 9.3% reduction in specific energy consumption (MWh per million euros of revenue) in 2024 vs 2023.
• CDP rating: The Group achieved an A score (Leadership) in CDP Climate Change 2024, recognising transparent reporting and ambitious action.
• SBTi approval: Near-term and long-term science-based targets were validated by the Science Based Targets initiative in 2024, aligning with a net-zero pathway by 2050.

For emission-reduction actions, transition plans, and target trajectories, refer to E1-3 (Actions) and E1-4 (Targets) sections of the full Sustainability Statement.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Overview

[ESRS 2 SBM-3; ESRS 2 IRO-1; ESRS E1-9]

Despite the high degree of uncertainty associated with assessing the impact of climate risks, the process is similar to that implemented for managing other risks and is based on our general risk management framework, which includes risks and opportunities in all stages of our value chain:

• upstream (e.g. the impact of changing precipitation patterns on global food supply chains);
• own operations (e.g. the impact on CapEx of replacing cooling systems);
• downstream (e.g. the opportunity to increase investor confidence through optimised management of climate-related financial risks and opportunities or the reduction of GHG emissions in our value chain).

The identification, assessment and management of climate-related risks and opportunities is part of an integrated corporate risk management process, in line with ISO 31000, and includes a Risk Exposure Matrix with four levels calculated on the basis of two dimensions: probability and impact, for which we use four metrics (sales, EBITDA, safety and reputation) according to the type of risk or opportunity.

Materiality threshold

Risks and opportunities are considered material when exceed a potential variation of 5% in sales (set as the materiality threshold) considering its inherent risk. These cases are identified, assessed and managed at corporate level. Where they fall below that threshold (up to 5% of sales) they are identified and assessed at corporate level and managed at Company level.

Inherent risk is the level of risk without considering response strategies to a given climate-related risk (physical or transition).

Identification and monitoring

Identification includes monitoring country-specific regulations (e.g. carbon taxes in Portugal, Poland and Colombia), a detailed assessment of the vulnerability of facilities to extreme weather events (e.g. flood risk mapping of stores and distribution centres in the countries where we have operations) and an analysis of market trends, in particular our consumers' preferences (e.g. preference for local products, choice of low carbon or flexitarian products).

Time horizons

Climate-related financial risks and opportunities were assessed over different time horizons – short, medium and long term – and selected according to their materiality.

Types of climate-related financial risks

There are two types of climate-related financial risks:

• physical (acute and chronic);
• transition (including political, regulatory, market, technological and reputational risks).

Risks assessed

The universe of climate-related risks, as well as the quantification and disclosure of financial risks.

Since 2020, all climate-related physical and transition opportunities and risks that are considered material have been assessed annually.

Assessment coverage

[ESRS 2 SBM-3; ESRS 2 IRO-1; ESRS E1-3; ESRS E1-9]

In 2024, the assessment of risks and opportunities in our operations covered more than 6,000 establishments (stores, distribution centres, head office buildings, central kitchens and industrial units) in the six countries where we do business (Poland, Portugal, Colombia, Morocco, Czechia and Slovakia). It focused on the most frequent physical risks in our operations and on boosting opportunities related to the energy transition and the use of natural or low GWP refrigerant gases.

Risks and opportunities considered in strategy

*Assessment of the different categories of physical and transition risks has been updated for the short-term, 2030, medium-term, 2040, and long-term, 2050, in line with our climate transition plan.

Water stress assessment

Given the growing pressure on water resources, we reassessed the level of water stress associated with the location of our Companies' establishments, in particular JMA farms. Our agri-food production area relies heavily on water resources, namely for animal watering and irrigation. We used the latest version (2023) of the Aqueduct Water Atlas, a World Resources Institute tool that aggregates information on current and projected water scarcity for different time horizons, according to different climate scenarios. Locations classified as being of "high" or "extremely high" risk were deemed material.

JMA drew up a Water Management Plan following this reassessment. This plan fulfils the commitment to define and implement a mitigation and adaptation plan to improve efficiency in water use and manage water scarcity during periods of low precipitation at the Company's farms.

Flood and sea level rise assessment

Assessment for the 2030 and 2040 periods showed that the risk associated with rising sea levels or inland flooding does not have a material impact for the business. The coastal and river flood risk climate models offered by the WWF Water Risk Filter tool were used for this assessment.

Having regard to the long-term projections, which indicate a rise in sea levels of between 0.5 and 1 metre by 2100, the impact of this risk on coastal areas will continue to be monitored periodically in order to identify high-risk areas for our Companies' businesses. Quantifying the flood risk in periods of heavy rainfall is complex due to the uncertainty of the results of climate scenarios. Despite the increase in flood frequency and intensity, the number of stores affected in recent years has been very small.

Mitigation measures

Our establishments have drainage systems and levels of adaptation to the occurrence of floods, especially those caused by heavy rainfall. One such mitigation measure is the construction of distribution centres in Colombia above the average sea level rise line and with a slope to harvest surface runoff, which is then used for secondary activities such as washing floors and watering green spaces.

We monitor the impact of potential sea level rises on our logistics processes by studying the risk associated with the seaports used by the freight carriers we use in the different countries.

We also monitor the state of implementation of national climate action and adaptation plans, especially in Colombia, where there are port infrastructures in higher risk regions, as well as the plans of several countries for strategic ports in regions where we have identified new products or alternative products to those at risk in their production regions.

Policies related to pollution

Jerónimo Martins reports that pollution (ESRS E2) was not identified as a material topic in their materiality assessment. However, the company states that it is "partially reported" and refers readers to section 3.2.5 "Pollution" of the sustainability statement.

The company indicates that its management of environmental challenges, including pollution-related aspects, is governed by the following policies:

Environmental Policy

• Scope: Employees, suppliers, business partners, and local communities
• Key content: Promotes responsible production, distribution, and consumption practices by continuously improving the efficiency and effectiveness of the supply chain. Integrates environmental performance criteria into operations and management decisions, encourages eco-efficiency and eco-innovation, and actively promotes participation in multistakeholder initiatives. Key priorities include tackling climate change, protecting water resources, preserving biodiversity, and accelerating the transition to a circular economy. The Group aims to reduce energy consumption, greenhouse gas emissions, and waste, while enhancing water quality and availability. All initiatives must be regularly monitored, evaluated, and reported to ensure compliance with applicable legislation and continuous improvement.
• Public availability: Available on the company website under "Corporate Responsibility Publications"

Sustainable Sourcing Policy

• Scope: Employees, suppliers, business partners, local communities, and consumers
• Key content: Aims to establish a sustainable approach by incorporating social and environmental concerns into the supply chain, with the goal of gradually and sustainably contributing to positive impacts, and mitigating actual or potential negative impacts of the Group's activities. Focuses on ensuring food quality and safety, offering fair prices, promoting responsible consumption, supporting social wellbeing, and contributing to the sustainability of ecosystems and communities. Emphasizes rigorous supplier selection, fostering long-term ethical relationships, and encouraging good environmental practices. Committed to complying with legislation and protecting biodiversity, the policy aligns with the UN's priority areas to ensure ecosystem services and population well-being.
• Public availability: Available on the company website under "Corporate Responsibility Publications"
• Link to international standards: Aligns with the UN's priority areas

The company's disclosure for E2-1 explicitly states this topic was not identified as material but is partially reported, with references to the Environmental Policy and Sustainable Sourcing Policy as the governing frameworks.

Actions and resources related to pollution

Disclosure Statement

Jerónimo Martins states that pollution was not identified as a material topic. However, the company indicates that E2-2 (Actions and resources related to pollution) is partially reported in:

• Subchapter 3 "Environmental information"
• Section 3.2 "Managing environmental topics"
• Subsection 3.2.5 "Pollution"

Cross-Reference

The company refers readers to:

• The "Corporate Responsibility Publications" page on their website to view the Environmental Policy and the Sustainable Sourcing Policy
• Subchapter 3.2.5 "Pollution" of the Sustainability Statement for partial reporting

Status

The excerpts provided do not contain the actual content of section 3.2.5 "Pollution" where actions and resources would be detailed. Only cross-references and metadata indicating partial disclosure are present in these excerpts.

No specific pollution-related actions, programmes, projects, initiatives, resource allocations, timelines, or KPIs are disclosed in the provided text.

Targets related to pollution

Environmental certification target

Target: Ensure that the number of locations with environmental certification is at least 70% of the total number of distribution centres and industrial/similar units (including fresh dough factory, central kitchens, soup factory, Terra Alegre dairy factory and packing units).

Target year: 2026

Baseline year and value: Not disclosed

Target value: 70% of total distribution centres and industrial units

Type: Absolute (percentage coverage)

Scope: Own operations (distribution centres and industrial units in Poland, Portugal, and Colombia)

Validation: Internal target

Progress to date (2024): In progress. 73% of distribution centres and industrial units had ISO 14001 environmental certification. In Poland, certification according to ISO 14001 has been renewed for 17 distribution centres (DCs) and the Biedronka soup factory. In Portugal, fresh dough factory and Terra Alegre maintained ISO 14001 certification, as well as the DCs (Azambuja, Algoz, Vila do Conde, Alfena, Vila Nova da Rainha and Alcochete) and Pingo Doce's central kitchens (Odivelas and Aveiro). In Colombia, Ara has completed the ISO 14001 certification process for the Gachanchipá and Pereira distribution centres.

Note: While pollution was not identified as a material topic for ESRS E2, the company has partially reported on pollution-related commitments, specifically through environmental management system certification (ISO 14001).

Pollution of air, water and soil

Emissions to air

Nitrogen oxides (NOX) and sulphur oxides (SOX)

The quantities are emitted by the combustion of fossil fuels (use of on-site fuel for equipment operation, emergency generators and heating, as well as light vehicle fleet):

Ozone depleting substances (ODS)

In 2024 it was not verified CFC-11 eq. emissions.

In 2024, there was no emissions of CFC-11 eq.

Emissions to water

Water discharge by destination

*It is estimated that the volume discharged corresponds to less than 0.5% of freshwater.

Water discharge by business unit

Wastewater discharge to environment

Wastewater discharged directly into the natural environment is licensed in accordance with local laws and is properly treated in the places where it is generated before being discharged. Discharged wastewater accounts for 1.8% of the total volume of wastewater generated by the Group, virtually the same as in the previous year (-0.03 p.p. compared to 2023).

Water discharge by water stress class

In terms of water disposal, the volume for 'high' and 'extremely high' water stress is of 1,403,766 m³, accounting for 48% of the total. Water discharged in 'high' and 'extremely high' water stress increased 0.04%, slightly compared to 2023.

Emissions to soil

Not disclosed.

Regulatory compliance

With regard to non-compliance with environmental laws and regulations, there were no significant fines. A significant fine is considered to be a monetary amount equal to or greater than approximately 45,000.00 euros.

Context and management approach

The Group implements measures to optimise water consumption and improve water quality in supply chains. The sustainable agriculture project promoted among fruit and vegetable suppliers, and environmental audits which assess both water consumption and how suppliers and service providers reduce water pollution impacts, are examples of these measures.

Substances of concern and substances of very high concern

Jerónimo Martins addresses substances of concern as part of its Product Safety and Quality Policy. The policy includes a commitment to complying with safety standards for substances of concern and packaging materials. Specifically, the Group:

• Applies rigorous quality and safety standards based on scientific evidence
• Ensures product safety through legal and scientific support
• Complies with safety standards for substances of concern and packaging materials
• Implements procedures and traceability to ensure product safety
• Clearly communicates product information to consumers

Additionally, the Group has committed to reformulating products to eliminate microplastics and avoiding the use of nanotechnology in food products and packaging.

Environmental audits of perishables, Private Brand suppliers and service providers assess requirements related to hazardous substances as part of the environmental performance evaluation. Around 100 requirements are assessed covering topics including hazardous substances management.

However, E2-5 (Pollution) was not identified as material in the dual materiality assessment. According to the ESRS index table, the disclosure requirement E2-5 – Substances of concern and substances of very high concern is "partially reported" under subsection 3.2.5 "Pollution" of the Environmental information chapter.

No quantitative data on total amounts of substances of concern (SoC) or substances of very high concern (SVHC) in tonnes, breakdown by hazard class (CMR, endocrine disruptor, PBT, vPvB), or amounts leaving facilities as emissions, products or services is disclosed in the report.

Anticipated financial effects from pollution-related impacts, risks and opportunities

This topic was not identified as material, nonetheless it is partially reported. See subchapter 3. "Environmental information", section 3.2. "Managing environmental topics", of this chapter.

No specific quantified anticipated financial effects from pollution-related impacts, risks and opportunities are disclosed in the provided excerpts.

Policies related to water and marine resources

The company states that water and marine resources were not identified as a material topic in their materiality assessment. However, the topic is partially reported.

The company's management of water and marine resources challenges is governed by the following policies and codes:

Environmental Policy

• Public availability: Available on the company website
• Additional information: A detailed description of this policy can be found in subchapter 2. "General disclosures", section 2.2. "Governance and strategy"

Sustainable Sourcing Policy

• Public availability: Available on the company website
• Additional information: A detailed description of this policy can be found in subchapter 2. "General disclosures", section 2.2. "Governance and strategy"

Product Quality and Safety Policy

• Public availability: Available on the company website
• Additional information: A detailed description of this policy can be found in subchapter 2. "General disclosures", section 2.2. "Governance and strategy"

Code of Conduct

• Public availability: Available on the company website
• Additional information: A detailed description of this code can be found in subchapter 2. "General disclosures", section 2.2. "Governance and strategy"

Code of Conduct for Suppliers

• Public availability: Available on the company website
• Additional information: A detailed description of this code can be found in subchapter 2. "General disclosures", section 2.2. "Governance and strategy"

Note: The company acknowledges that as experts in the sale of fresh produce, including meat, fish, fruit and vegetables, their daily activities depend on and impact the ecosystems from which many of these products are sourced. However, specific policy details regarding scope, governance, key content, monitoring, and links to international standards for water and marine resources are not disclosed in the provided excerpts and are instead referenced to another section of the report.

Actions and resources related to water

Jerónimo Martins has implemented several actions to reduce water consumption and mitigate water scarcity risks, particularly in areas with high water stress. These measures are integrated into the refurbishment and opening of new stores and other infrastructures (central kitchens, distribution centres, production units).

Own Operations - Infrastructure Measures

Scope: Own operations (stores, central kitchens, distribution centres, production units)

Time horizon: Ongoing (incorporated into refurbishment and new opening plans)

Actions implemented:

• Installation of flow regulators
• Use of taps with timers
• Harvesting rainwater for use in irrigation or washing equipment
• Treating wastewater to prevent deterioration in water quality
• Investment on smart irrigation technologies that use weather and soil moisture data to determine irrigation needs on farms
• Using nighttime or drip irrigation systems to minimise evaporation losses
• Incorporating wet feed, ungraded products and by-products from the food industry into animal feed (high moisture content reduces water needs)

Resources: Not quantified

Employee Awareness Programmes

Scope: Own operations

Time horizon: Ongoing

Named initiatives:

• "Water and Energy Consumption Management Teams" at Pingo Doce and Recheio
• "Everyone for the Environment" at Pingo Doce
• "Dobra energia" (Good energy) at Biedronka
• "Let's Go Green" in office buildings in Portugal, Poland and Colombia

Resources: Not quantified

Cross-reference: These projects are described in more detail in section 3.2.4 "Biodiversity and ecosystems"

Supply Chain Actions

Scope: Upstream value chain (suppliers and service providers)

Time horizon: Ongoing

Actions:

• Sustainable agriculture project promoted among fruit and vegetable suppliers to optimise water consumption
• Environmental audits assessing water consumption and water pollution reduction impacts among suppliers and service providers

Resources: Not quantified

Cross-reference: More information provided in subchapter 5.2.2 "Supplier awareness and training"

Marine Resources - Sustainable Fishing Strategy

Scope: Own operations and upstream supply chain

Time horizon: Ongoing (annual monitoring commitment)

Actions:

• Diversification of fish assortment (over 200 species sold in 2024) to reduce pressure on most consumed species
• Increased sourcing from aquaculture (39% in 2024, up 7 p.p. vs 2023) to reduce pressure on wild stocks
• Annual monitoring of conservation status of wild-caught fish species using IUCN Red List data
• Concrete mitigation actions to reduce negative impacts on marine ecosystems (specific actions referenced but detailed elsewhere)
• No purchases of Critically Endangered or Endangered species

Outcomes achieved (2024):

• Wild-caught fish: 61% of total (down 7 p.p.)
• Aquaculture fish: 39% (up 7 p.p.)
• 35% of wild-caught fish listed as Vulnerable (lowest risk level)
• 51% of wild-caught fish in Near Threatened or Least Concern categories
• 0% Critically Endangered or Endangered species purchased

Resources: Not quantified

Cross-reference: Actions detailed in subsection 3.2.4 "Biodiversity and ecosystems", point "Sustainable Fishing Strategy"

Overall Water Performance

Outcomes (2024 vs 2023):

• Overall specific water consumption: 0.189 m³/thousand euros in sales (-11.1%)
• Distribution specific value: 0.102 m³/thousand euros (-4.7%)
• Agribusiness specific value: 20.386 m³/thousand euros (-29.0%)
• Total water withdrawal: 6,315,041 m³ (-2.9%)

Targets related to water

Water Withdrawal Reduction Target (Distribution)

Target metric: Volume of water withdrawal in Distribution per thousand euros in sales

Target value: 10% reduction

Target year: End of 2026

Baseline year: 2021

Baseline value: Not explicitly stated in absolute terms

Scope: Distribution business unit

Type: Intensity-based (per thousand euros in sales)

Validation: Internal target (not externally validated)

Progress to date (2024): Water withdrawal was reduced by 59% per thousand euros in sales compared to 2021.

Performance Context

In 2024, considering only the Distribution business:

• Water withdrawal increased 4.7% in absolute terms compared to 2023 (due to opening of over 350 new stores)
• Specific consumption fell by 4.7% (from 0.106 to 0.102 m³ per thousand euros of sales)
• Overall specific value across all operations: 0.189 m³/thousand euros in sales in 2024 vs 0.212 in 2023 (-11.1%)

Water consumption

Total consumption

Water withdrawal and reuse

Total withdrawal (m³)

*Total withdrawal volume corresponds to freshwater.

Water withdrawal by business unit (m³)

Recycled water (m³)

**Only at Ara.

Water discharge

Total wastewater (m³)

*It is estimated that the volume discharged corresponds to less than 0.5% of freshwater.

Wastewater by business unit (m³)

Water consumption

Total water consumed (m³)

*Water consumption was calculated according to the Global Reporting Initiative (GRI) methodology, where water consumption is the difference between water withdrawal and water discharge.

Water stress

Water withdrawal (m³)

In 2024, 27% of total water withdrawal (1,721,714 m³) had an "extremely high" or "high" water stress level. In terms of water disposal, the volume for both risk levels is 1,403,766 m³, accounting for 48% of the total.

Water intensity

Intensity metric reported as m³ per thousand euros in sales (see total consumption table above).

Commitments

The Group has committed to:

• Reduce water withdrawal in distribution activities by 10% (per thousand euros of sales), by 2026, compared to 2021. In 2024, the reduction was 59% compared to 2021.
• Define and implement a mitigation and adaptation plan to improve the efficiency of water use and to manage its scarcity during low precipitation periods in JMA units (Water Management Plan developed in 2024).

Methodology notes

• Water stress classification uses the World Resources Institute (WRI) Aqueduct: Baseline Water Stress Class model (2023 version).
• More than 95% of withdrawn water came from municipal or private supply systems.
• Groundwater and surface water accounts for 5%, used for operations such as irrigation and refrigeration systems.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

Materiality Assessment

This topic was not identified as material.

Cross-Reference to Reported Information

Notwithstanding the non-materiality assessment, partial reporting is provided in:

• Subchapter 3. "Environmental information", section 3.2. "Managing environmental topics", subsection 3.2.1 "Climate change", point "Managing climate-related risks and opportunities"

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

Materiality Assessment

This topic was not identified as material, nonetheless it is partially reported. See subchapter 3. "Environmental information", section 3.2. "Managing environmental topics", subsection 3.2.4. "Biodiversity and ecosystems", of this chapter.

Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model (ESRS 2 SBM-3)

This topic was not identified as material, nonetheless it is partially reported. See subchapter 3. "Environmental information", section 3.2. "Managing environmental topics", subsection 3.2.4. "Biodiversity and ecosystems", of this chapter.

Process to Identify and Assess Material Biodiversity and Ecosystem-Related Impacts, Risks and Opportunities (ESRS 2 IRO-1)

This topic was not identified as material, nonetheless it is partially reported. See subchapter 3. "Environmental information", section 3.2. "Managing environmental topics", subsection 3.2.4. "Biodiversity and ecosystems", of this chapter.

Policies related to biodiversity and ecosystems

Jerónimo Martins states that biodiversity and ecosystems was not identified as material in their dual materiality assessment, but the company reports on this topic partially.

The company does not disclose a dedicated biodiversity policy. Instead, biodiversity and ecosystems considerations are governed through the following broader policies:

Environmental Policy

• Part of the suite of policies governing environmental challenges at the Group level
• A detailed description is referenced in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"
• Public availability: Available on the company website

Sustainable Sourcing Policy

• Part of the suite of policies governing environmental challenges at the Group level, relevant to biodiversity given the company's dependence on ecosystems for fresh produce sourcing
• A detailed description is referenced in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"
• Public availability: Available on the company website

Product Quality and Safety Policy

• Part of the suite of policies governing environmental challenges at the Group level
• A detailed description is referenced in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"
• Public availability: Available on the company website

Code of Conduct

• Part of the suite of policies governing environmental challenges at the Group level
• A detailed description is referenced in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"
• Public availability: Available on the company website

Code of Conduct for Suppliers

• Part of the suite of policies governing environmental challenges at the Group level
• A detailed description is referenced in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"
• Public availability: Available on the company website

Context: The company acknowledges that as experts in the sale of fresh produce (including meat, fish, fruit and vegetables), their daily activities depend on and impact ecosystems from which these products are sourced. They recognize that biodiversity loss is a major environmental challenge that can impact global production capacity. The company references initiatives including conserving natural habitats, choosing suppliers with better agricultural and food production practices, and promoting sustainable diets.

Governance: Companies with dedicated Sustainability Committees include Ara, Biedronka, Hebe, Hussel, Jeronymo, JMA, Pingo Doce and Recheio.

Actions and resources related to biodiversity

Fighting deforestation

Action: Forest Positive Coalition of Action membership and commodity commitments

• Scope: Upstream value chain (Private Brands and perishable products)
• Time horizon: End of 2025 target date
• What it does: Commitment to ensure palm oil, soy, paper/wood and beef used in Private Brand and perishable products are deforestation- and conversion-free (DCF), particularly commodities used as direct ingredients. Mapping presence of ingredients linked to deforestation, collecting information on origin and sustainability certification from suppliers.
• Links to policy: Consumer Goods Forum Forest Positive Coalition of Action commitments
• Performance: Awarded leadership level ('A-') in CDP Forests Programme in 2024 (also 2019, 2020, 2022, 2023)

Commodities monitored (2024):

• Palm oil: 77,667 tonnes
• Soy (total): 513,486 tonnes (21,061 direct; 492,425 indirect in animal feed)
• Paper and timber: 212,152 tonnes (170,751 products; 41,401 packaging - virgin fibres only)
• Beef: 40,337 tonnes

Sustainable Fishing Strategy

Action: Wild-caught fish species conservation monitoring

• Scope: Own operations (Private Brand and perishable fish products)
• What it does: Annual monitoring of conservation status of wild-caught fish species using IUCN data via Integrated Biodiversity Assessment Tool (IBAT). Diversifying fish assortment to reduce pressure on most consumed species. Investment in aquaculture systems.
• Expected outcomes: Prevent contribution to overexploitation, depletion or extinction of species. Sold more than 200 species in 2024.
• Performance (2024):
  • Wild-caught fish: 61% (down 7 p.p.)
  • Aquaculture: 39% (up 7 p.p.)
  • IUCN assessment: 35% Vulnerable, 51% Near Threatened/Least Concern, no Critically Endangered or Endangered purchases

Support for biodiversity protection and ecosystem regeneration projects

Resources allocated (2024): Over €327,000 invested across 11 projects (7 in Portugal, 2 in Poland, 2 in Colombia)

Named projects:

Portugal:

1. Reforestation of the Serra do Açor Mountain

• Partner: Associação Floresta Serra do Açor, Arganil Town Council, Coimbra School of Agriculture, common landowners' associations
• Time horizon: 40-year project (launched 2020)
• Scope: Protected landscape area, 2,500 hectares
• Outcomes: Almost one million trees planted since project start
• What it does: Preserve and enhance landscape devastated by 2017 forest fires

2. Green Heart of Cork

• Partner: ANP | WWF
• Time horizon: Started 2011, ongoing
• Scope: Portuguese cork oak forests
• Outcomes (2024): Contributed to conservation of 803.47 hectares of high conservation value forests. Landowners apply good forest management practices in approximately 45,000 hectares of FSC® certified areas, 30,000 hectares certified after support began
• What it does: Promotes conservation of cork oak forests and payment for environmental services, establishes platform linking companies to conservation

Poland:

3. Support for wild-insect pollinators

• Partner: Salamandra (Polish Society for Nature Conservation)
• Time horizon: Partnership began 2021
• What it does: Three main activities: (i) "Biedronka with Salamandra for wild-insect pollinators in natural gardens" grant competition; (ii) education and promotion through Salamandra Nature Magazine and social media; (iii) creating Polish Red List of endangered species with special consideration of pollinators
• Outcomes: Biedronka awarded "Patron of Nature Conservation 2024" by Salamandra

4. Clean Tatra Mountains

• Partner: Clean Poland Association (Stowarzyszenie Czysta Polska)
• Time horizon: Supported since 2019
• What it does: Annual mountain cleanup campaign with eco-town setup in Zakopane for educational activities
• Outcomes (2024): 2,075 volunteers collected 248 kg waste on mountain trails; first 'Clean 5 run' held with 200 trees planted

Colombia:

5. Protection of bees

• Partner: Fundabejaz Foundation
• Time horizon: Started 2021
• What it does: Protection and conservation of bees, raising awareness of their importance. Ara donates sugar as food source for rescued swarms
• Outcomes (2024): (i) rescued 50 hives; (ii) delivered 24 recovered hives to beekeepers/farmers; (iii) 91 awareness campaigns involving 6,420 participants

6. Save the Macaws

• Partner: Loros Foundation
• Time horizon: Started 2024
• What it does: Rehabilitation and release of macaws seized or voluntarily turned over by environmental authorities

Awareness and education activities

Non-financial resources:

• Hosting external awareness events (e.g., "A Graça Gracinha" at Azambuja distribution centre for local children)
• Social media campaigns: Ara's Instagram on International Forest Day and Earth Day
• Employee volunteering: Over 1,000 employees participated in volunteering activities in 2024, donating 3,600+ work hours and 9,000+ personal hours

Environmental volunteering actions:

• 150+ Ara employees planted 556 trees across three partnerships:
  • 100 trees with Immensamente Foundation (Ganchancipa)
  • 206 trees with Fundabejaz Foundation (Pereira)
  • 250 trees with Efecto Mariposa Foundation (Bogotá Reserve)
• 72 Ara employees built 3 emergency homes with TECHO Foundation
• Biedronka employees: 867 participated in Szlachetna Paczka social programme

Partnership and monitoring approach

Non-financial resources:

• Collaboration with local associations and NGOs specialising in biodiversity
• Use of IBAT Alliance tool to assess proximity to protected areas, key biodiversity areas and conservation risk of species
• IUCN Red List assessments for species monitoring
• Preference for projects aligned with Kunming-Montreal Protocol

Targets related to biodiversity and ecosystems

1. Deforestation and Conversion Free (DCF) Commodities

Target: By 2025, ensure that palm oil, soy, paper/wood and beef used in Private Brand and perishable products are deforestation- and conversion-free (DCF), particularly the commodities used as a direct ingredient.

Target year: 2025

Scope: Private Brand and perishable products

Progress (2024): The DCF calculation for palm oil, soy, paper and timber and beef in Private Brand and perishable products is being finalised. The company will report on progress in the second half of 2025, in the 5th Progress Report 'Contributing to a forest positive future'.

2. Palm Oil - Portugal and Poland

Target: Continue to ensure that 100% of palm oil in Portugal and Poland is RSPO certified and progressively extend this commitment to palm oil derivatives.

Target year: Ongoing (by 2025 as part of DCF commitment)

Scope: Portugal and Poland operations, Private Brands and perishables

Progress (2024): Companies in Portugal and Poland maintained RSPO certification for 100% of the palm oil used.

3. Palm Oil - Colombia

Target: By 2026, ensure that palm oil of Colombian origin used in Private Brands and perishable products is traceable to the farm where it was produced and is not associated with deforestation, and that 100% of palm oil of non-Colombian origin used in Private Brands and perishable products is certified by the RSPO.

Target year: 2026

Scope: Colombia (Ara), Private Brands and perishables

Progress (2024):

• Ara has traced the origin of 95% of the palm oil back to the area where it was produced
• More than 75% of the palm oil used in Private Brand and perishables was produced in Colombia
• 66% of Colombian palm oil was RSPO certified
• 59% of palm oil in Ara's Private Brands and perishables that did not come from Colombia was RSPO certified
• Only 0.75% of deforestation detected by public bodies in 2021 was associated with palm oil

4. Soy

Target: By 2025, ensure that 100% of direct and indirect soy is traceable at least to the country of origin and that whenever it comes from an origin where the risk is not negligible, the soy is traced back to the municipality of origin and/or has sustainability certification (e.g., RTRS or Proterra).

Target year: 2025

Scope: Private Brands and perishables (direct and indirect soy)

Progress (2024):

• 95% of total soy in supply chains traced to at least country of origin (up 2 p.p. compared to 2023)
• Around 64% of total soy from known origins comes from countries with risk of deforestation (-6 p.p. compared to 2023)
• 17% of soy from deforestation-risk countries had sustainability certification (e.g. RTRS)

5. Paper and Timber - Short-term

Target: By 2026, ensure that 95% of virgin fibres used in products and 80% of virgin fibres used in packaging are certified (FSC® or PEFC).

Target year: 2026

Scope: Private Brand products and perishables (virgin fibres in products and packaging)

Progress (2024): 90% of virgin fibres used in Private Brand and perishables products and packaging had sustainability certification (FSC® or PEFC).

6. Paper and Timber - Long-term

Target: By 2030, ensure that 100% of virgin fibres used in Private Brand and perishables products and packaging are certified by external and independent bodies, such as FSC® or PEFC.

Target year: 2030

Scope: Private Brand products and perishables (virgin fibres)

Progress (2024): 90% of virgin fibres used in Private Brand and perishables products and packaging had sustainability certification (FSC® or PEFC).

7. Beef

Target: Ensure that 100% of beef in Private Brand and perishable products is traceable to at least the country of origin (implied from DCF commitment by 2025).

Target year: 2025 (as part of DCF commitment)

Scope: Private Brand and perishable products

Progress (2024): 100% of beef mapped to at least country of origin. Only 0.4% of total originated from Brazil.

8. Sustainable Fish Stocks Analysis

Target: By 2026, analyse the sustainability status of fish stocks for at least 80% of fish sales (in kg), from Private Brand and perishable products, and publicly disclose progress.

Target year: 2026

Scope: Private Brand and perishable fish products (by kg)

Progress (2024):

• Analysed more than 80% of sales of Private Brand and perishable fish (in kg) at Ara, Biedronka, Pingo Doce and Recheio
• 51% of wild fish from the ten most representative fishing areas has no conservation risk (50% Least Concern, 1% Near Threatened)
• 33% classified as Vulnerable
• 17% not assessed or insufficient data

9. Tuna Traceability

Target: By 2026, ensure that 100% of wild-caught tuna in Private Brand and perishable products is traceable to the vessel.

Target year: 2026

Scope: Private Brand and perishable tuna products

Progress (2024): 42% of consumption of Private Brand and perishable tuna tracked down to vessel level.

10. Cage-Free Fresh Eggs

Target: By 2025, eliminate the sale of Private Brand fresh eggs from caged hens.

Target year: 2025

Scope: Private Brand fresh eggs across the Group

Progress (2024):

• Group: 98% of fresh Private Brand eggs sold come from non-caged hens
• Biedronka: 100% (achieved end of 2022, extended to supplier brands)
• Pingo Doce: 100% (achieved August 2019)
• Ara: does not have fresh Private Brand eggs in assortment

11. Cage-Free Eggs as Ingredient - Portugal and Poland

Target: By 2026, ensure that at least 90% of eggs used as an ingredient in Private Brand products are from cage-free hens.

Target year: 2026

Scope: Portugal and Poland, Private Brand products containing eggs as ingredient

Progress (2024):

• Biedronka: 100% (since 2022)
• Pingo Doce: 73% (+12 p.p. compared to 2023)
• Recheio: 41% (+3 p.p. compared to 2023)
• Ara: 68% (first time monitored)

12. Nature Conservation Projects

Target: In Colombia, Poland and Portugal, support and/or implement, in the 2024-2026 period, at least two nature conservation and biodiversity protection projects, aligned with the Kunming-Montreal Global Biodiversity Framework, and disclose results annually.

Target year: 2024-2026 (period)

Scope: Colombia, Poland, Portugal

Progress (2024): Supported 11 nature conservation projects (7 in Portugal, 2 in Colombia and 2 in Poland).

Impact metrics related to biodiversity and ecosystems change

Land use and deforestation metrics

Main agricultural commodities with deforestation risk in Private Brand and perishables

*Soy used in animal feed for the production of animal protein contained in products. **Only virgin fibres; recycled fibres are excluded.

Operations in protected areas and biodiversity restoration

The Group owns properties occasionally located or close to the National Ecological Network, and collaborates with government entities to ensure their conservation.

Serra do Açor reforestation project: Launched in 2020, involves the reforestation of an area spanning 2,500 hectares over a 40-year period in the protected landscape area of the Serra do Açor mountain range. Almost one million trees have been planted since the beginning of the project.

Green Heart of Cork project: In 2024, the Jerónimo Martins Group contributed to the conservation of 803.47 hectares of high conservation value forests. The landowners involved apply good forest management practices in approximately 45,000 hectares of FSC® certified areas, 30,000 hectares of which obtained certification after support began.

Total biodiversity protection investment (2024): Over 327,000 euros invested to support 11 projects (7 in Portugal, 2 in Poland and 2 in Colombia) focused on restoring natural habitats, protecting biodiversity and raising environmental awareness.

Species impact metrics - wild-caught fish

Conservation status assessment of wild-caught fish species sold (2024):

Wild-caught fish by conservation status (2024):

• 50% listed as Least Concern
• 1% listed as Near Threatened
• 33% listed as Vulnerable (lowest conservation risk category)
• 17% not assessed or insufficient data

Fish sourcing by FAO area (2024):

• Approximately 60% of assortment sourced from FAO Area 27 - Northeast Atlantic
• FAO Area 34 - East Central Atlantic: 7%
• FAO Area 87 - Southeast Pacific: 7%
• FAO Area 41 - Southwest Atlantic: 5%
• FAO 61 - Northwest Pacific: 4%

More than 200 species of fish sold in 2024:

• Wild-caught fish: 61% of total consumption
• Aquaculture fish: 39% of total consumption

Tuna traceability: In 2024, 42% of consumption of Private Brand tuna and perishables traced down to vessel level (commitment is to guarantee full traceability by 2026).

Sustainable agriculture metrics

Sustainable Agriculture Handbook application (2024):

• 15 new farms in Portugal evaluated
• 13 farms reassessed
• Total 28 farms evaluated during the year
• Average sustainability index for new farms: 3.65 (on a scale of 1 to 5, where 5 is the maximum score)
• Since 2016: more than 200 farms from 100 suppliers integrated
• Suppliers with at least one farm participating represent 67% of the volume of fruits, vegetables and flowers purchased in Portugal

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

This topic was not identified as material, nonetheless it is partially reported. See subchapter 3. "Environmental information", section 3.2. "Managing environmental topics", subsection 3.2.4. "Biodiversity and ecosystems", of this chapter.

Policies related to resource use and circular economy

Jerónimo Martins manages resource use and circular economy through several overarching policies that govern environmental challenges. The company explicitly states that "our management of environmental challenges is governed by the following policies and codes" and directs readers to detailed descriptions in subchapter 2.

Environmental Policy

• Public availability: Available on the company website
• Content: The company states this policy governs management of environmental challenges including efficient waste management, reducing energy and water consumption, fighting food waste, and contributing to a circular economy
• Further details: A detailed description is available in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"

Sustainable Sourcing Policy

• Public availability: Available on the company website
• Content: Governs supplier selection and agricultural/food production practices
• Further details: A detailed description is available in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"

Product Quality and Safety Policy

• Public availability: Available on the company website
• Further details: A detailed description is available in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"

Code of Conduct

• Public availability: Available on the company website
• Further details: A detailed description is available in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"

Code of Conduct for Suppliers

• Public availability: Available on the company website
• Further details: A detailed description is available in subchapter 2 "General disclosures", section 2.2 "Governance and strategy"

Material topics covered: The company has identified two material topics under circular economy: (1) Packaging redesign for sustainable resource use, and (2) Food waste.

Integration with business model: The company acknowledges that integrating environmental variables into the business model can bring economic and social benefits, reduce compliance risks, and improve operational efficiency through initiatives such as efficient waste management, reducing energy and water consumption, fighting food waste, investing in natural habitat conservation, choosing suppliers with better practices, and contributing to a circular economy.

Actions and resources related to circular economy

Ecodesign of Packaging

Description and scope: Implemented over a decade ago (launched in 2011), the ecodesign packaging project seeks to optimise the packaging of Private Brand and perishable products, maintaining product integrity. Scope: own operations (packaging design).

Objectives:

• Reduce the amount of material used
• Promote circular packaging by incorporating recycled materials into its composition and increasing recyclability
• Rework the size, weight and shape of packaging, to enable more product quantities to be transported in each journey

Time horizon: Ongoing since 2011 (long-term action)

Resources allocated: Not quantified in financial terms.

Outcomes achieved:

• Since 2011: 50,351 tonnes of materials avoided through more than 2,300 changes
• Includes around 1,000 FSC® or similar certified packages
• 6,882 tonnes of carbon equivalent avoided as a result of increased transport efficiency
• In 2024: 454 ecodesign packaging projects implemented (262 at Biedronka, 85 at Hebe, 72 at Pingo Doce, 21 at Ara and 14 at Recheio)
• 25.7% of Private Brand packaging changed since 2011
• 1.1% of plastic packaging determined as reusable in 2024 (according to Ellen MacArthur Foundation's method)

2024 Highlights by business unit:

• Biedronka – Kraina Mięs pork vacuum packs now have an absorbent pad made entirely from FSC® certified cellulose, replacing plastic pads. These changes helped avoid 55 tonnes of plastic per year.
• Pingo Doce – Mini Bolachas Salgadas 350g packaging now incorporates 30% recycled PET in the jar, avoiding 4 tonnes of virgin plastic per year.
• Recheio – Five Amanhecer products launched with FSC® certified cardboard packaging.
• Ara – Plastic labels on 13 fresh meat products reduced in size, avoiding 2.7 tonnes of plastic per year.

Closed Loop at Biedronka

Description and scope: The Closed Loop project involves the collection of used paper boxes from Biedronka stores, which are then recycled and transformed back into raw material for the manufacture of new cardboard boxes used to display Private Brand products in the Company's stores. Scope: own operations and downstream (store operations and packaging supply chain).

Time horizon: Launched in 2022; dedicated symbol used to identify recycled boxes since 2023 (ongoing, medium-term).

Resources allocated: Not quantified in financial terms.

Outcomes achieved:

• In 2024: 8,322 tonnes of cardboard collected and transformed into more than 31.6 million new boxes

Circular Economy Projects and Engagement

Description and scope: Participation in circular economy projects to identify opportunities to optimise the use of materials, increase recyclability, incorporate increasingly more recycled materials, and to test reusable solutions. Scope: own operations, upstream and downstream value chain.

Activities:

• Continually account for and monitor the use of different materials that make up packaging
• Promote waste recovery in own operations
• Raise awareness of and engage business partners and customers to encourage waste recovery

Resources allocated: Not quantified.

Opportunities assessed:

• Resource efficiency, such as optimising the use of materials and waste management
• Markets, including supply chain sustainability and the sharing economy (e.g. shared transport packaging)
• Financing, such as investment funds for circular economy projects
• Reputation, continuously improving communication and interaction with stakeholders

Food Waste Fighting Measures

Description: Measures implemented to fight food waste are referenced but explained in detail elsewhere in the report (subsection 3.2.2. "Resource use and circular economy", point "Actions to promote circular economy", subpoint "Fighting food waste").

Scope: Own operations and value chain.

Resources allocated: Not disclosed in this excerpt.

Targets related to circular economy

Target 1: Ecodesign of Private Brand packaging

Target metric: Percentage of Private Brand products' packaging included in the Ecodesign project

Target value: At least 25%

Target year: 2026

Baseline year: 2023 (considering the 2023 assortment)

Baseline value: Not explicitly stated

Scope: Private Brand products

Type: Not specified

Validation: Internal

Progress (2024): Accomplished. 454 eco-design projects completed in 2024. Accumulated value since 2011 is 2,347 packages (25.7% of the 2023 assortment).

Target 2: Reduction of specific plastic consumption

Target metric: Specific consumption of plastic measured in tonnes of plastic packaging per million euros of turnover

Target value: 10% reduction

Target year: 2025

Baseline year: 2018

Baseline value: Not explicitly stated

Scope: Plastic packaging

Type: Intensity-based

Validation: Internal

Progress (2024): In progress. 42% reduction in specific plastic consumption (t/million euros of sales) compared to 2018.

Target 3: Recycled plastic content in packaging

Target metric: Content of recycled plastic incorporated in plastic packaging under company responsibility (Private Brand, service packaging, carrier bags and palletizing film)

Target value: 25%

Target year: 2025

Baseline year: Not specified

Baseline value: Not specified

Scope: Private Brand, service packaging, carrier bags and palletizing film

Type: Not specified

Validation: Internal

Progress (2024): In progress. Recycled plastic content was 11.6% in plastic packaging, 13.4 p.p. below the target for 2025.

Target 4: Waste recovery rate

Target metric: Annual waste recovery rate of volume of waste generated

Target value: At least 85%

Target year: 2026 (annual target for 2024-2026 triennium)

Baseline year: Not specified

Baseline value: Not specified

Scope: Waste generated by operations

Type: Not specified

Validation: Internal

Progress (2024): In progress. Waste recovery rate was 84.8%, 0.2 p.p. below the target.

Target 5: Food waste limitation

Target metric: Annual food waste as percentage of total food sales (in tonnes)

Target value: 2.5% maximum

Target year: 2024-2026 period

Baseline year: Not specified

Baseline value: Not specified

Scope: Food sales

Type: Not specified

Validation: Internal

Progress (2024): In progress. Food waste was 1.8% of total sales volume (in tonnes) of foodstuffs.

Target 6: Food rescue increase

Target metric: Amount of rescued food in own operations and supply chain (through donations, discounted sales, recovery of non-graded food, recovery to animal feed and bioprocessing)

Target value: 10% increase

Target year: 2026

Baseline year: 2023

Baseline value: Not specified

Scope: Own operations and supply chain

Type: Not specified

Validation: Internal

Progress (2024): In progress. 21% increase achieved, 11 p.p. more than the target set for the 2024-2026 triennium.

Target 7: Food waste reduction by 2030 (SDG-aligned)

Target metric: Food waste generated by company activity (kg of food wasted/tonne of food sold)

Target value: 50% reduction

Target year: 2030

Baseline year: 2016

Baseline value: 13.2 kg of food wasted/tonne of food sold

Scope: Company operations

Type: Intensity-based

Validation: Aligned with SDG 12.3

Progress (2024): In progress. Value for 2024 was 19.9 kg of food wasted/tonne of food sold, three times higher than the target assuming the specific value of 2016.

ESRS E5-4: Resource Inflows

Total Material Consumption

Jerónimo Martins reports total material consumption primarily focused on packaging materials used across its operations. The company states that E5-4 was not identified as material according to the updated dual materiality matrix for the 2024 report. However, the company provides extensive disclosure on product packaging materials as this is considered the material issue related to resource inflows.

Main Materials Used

Overall consumption intensity:

• 2024: 15.13 tonnes per million euros in sales
• 2023: 16.99 tonnes per million euros in sales
• Change: -10.9%

Material Breakdown by Type

Recycled Materials Incorporated

Recycled content rate: In 2024, service and Private Brand product packaging incorporated 43.2% of recycled materials (0.5 p.p. less than in 2023). Paper and cardboard packaging contained around 80% recycled materials. In total, around 200 thousand tonnes of recycled materials were used, 3.5% less than in the previous year.

Single-Use Plastics (SUP)

Recycled Plastic in SUP

Recycled plastic content in SUP: Of the total SUP in these categories, 19,867 tonnes were recycled plastic, corresponding to 11.6%.

Virgin Plastic in SUP

Key Findings

• Total material consumption decreased 2.7% compared to 2023, due mainly to a reduction in the amount of plastic and paper packaging for Private Brand products
• The specific value (total material consumption per million euros in sales) decreased 10.9%
• The consumption of single-use plastic (SUP) decreased 5.6% compared to 2023
• SUP accounted for 34% (1.7 p.p. less than in 2023) of the materials used in Private Brand product packaging and service packaging
• The use of virgin plastic decreased 7.9% compared to the previous year
• 57.1% of the plastic packaging of Private Brand products is recyclable (15.1 p.p. more than in 2023)
• Problematic components (e.g. PVC and EPS polymers) were eliminated from 91.8% of packaging in 2024

Materiality Statement

The company explicitly states in the cross-reference table: "This topic was not identified as material according to the updated dual materiality matrix for the 2024 report. For Jerónimo Martins Group, the material issue is related to product packaging."

Resource outflows

Materials and recyclability

In 2024, total material consumption was 506,183 tonnes, decreasing 2.7% compared to 2023. The specific value (material consumption per million euros in sales) decreased 10.9%, from 16.99 to 15.13 tonnes/million euros.

Private Brand product packaging by type (2024):

• Paper and cardboard: 199,538 tonnes
• Plastic: 148,634 tonnes
• Glass: 86,740 tonnes
• Cardboard packaging for liquid products: 15,176 tonnes
• Steel: 20,349 tonnes
• Other materials: 6,366 tonnes

Incorporated recycled materials (2024):

• Total recycled materials in packaging: 212,647 tonnes (43.2% of service and Private Brand product packaging)
• Paper and cardboard: 168,741 tonnes (~80% recycled content)
• Plastic: 12,142 tonnes
• Glass: 31,764 tonnes

Single-Use Plastics (SUP):

• Total SUP consumption: 187,066 tonnes (decreased 5.6% vs 2023)
• SUP accounted for 34% of materials used in Private Brand product packaging and service packaging
• Recycled plastic in SUP: 19,867 tonnes (11.6%)
• Virgin plastic in SUP: 157,713 tonnes (decreased 7.9% vs 2023)

Plastic recyclability:

• 57.1% of Private Brand plastic packaging is recyclable (using Ellen MacArthur Foundation methodology)
• 91.8% of packaging had problematic components eliminated (e.g. PVC, EPS)
• 1.1% of plastic packaging was reusable

Ecodesign and circular packaging initiatives

Since 2011, the ecodesign packaging project has:

• Avoided use of 50,351 tonnes of materials through 2,300+ changes
• Achieved 25.7% of Private Brand packaging changed since 2011
• In 2024: implemented 454 ecodesign projects (262 Biedronka, 85 Hebe, 72 Pingo Doce, 21 Ara, 14 Recheio)
• Avoided emission of 6,882 tonnes CO2e through increased transport efficiency

Reusable packaging solutions

Operations:

• Reusable boxes for perishables avoided use of over 42,000 tonnes of disposable packaging (5% more than 2023)
• Pingo Doce/Recheio: 44 million reuses of boxes
• Biedronka: 21.2 million uses for bakery products
• Ara: 19+ million uses for bottled water, milk, meat, fruit and vegetables

Customer solutions:

• ECO plastic bottle refilling stations: 310 Pingo Doce stores, avoided 101 tonnes single-use plastic
• Reusable paper check-out bags: 1,439 tonnes (40.5% increase)
• Single-use plastic check-out bags: 9,064 tonnes (decreased 5.1%)
• Plastic check-out bags incorporate 50-85% post-consumer recycled plastic (~7,400 tonnes total)
• Paper bags contain minimum 70% recycled material (1,028 tonnes)

Commitments (by end of 2025)

• Ensure 100% of Private Brand plastic packaging is reusable or recyclable
• Incorporate at least 25% recycled content in Private Brand plastic packaging
• Reduce specific plastic consumption by 10% vs 2018
• Reduce virgin plastic in Private Brand packaging by 15% vs 2018

Progress: Specific plastic consumption reduced 42% vs 2018 (exceeding 10% target). Recyclability and recycled content targets remain challenging due to limited availability of food-grade recycled plastic.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Phase-in exemption

The Group will take due diligence to meet the requirements of this indicator within the stipulated phase-in period.

Materiality assessment

Risks and opportunities are considered material where they exceed a 5% potential variation in sales, in which case they are identified, assessed and managed at corporate level. Where they fall below the materiality threshold (variation of up to 5% of sales considering the inherent risk), they are identified and assessed at corporate level and managed at Company level.

Inherent risk is the level of risk without considering response strategies to a given circular economy-related risk (physical or transition).

Key risks

Because of the potential loss to the value chain, food waste is the most material circular economy risk. The risks associated with regulations, particularly on the recyclability of packaging, are of minor importance as, in some cases, they depend on sectoral adaptations.

Market risks, such as the cost differences between recycled and virgin materials, can affect the competitiveness of a product and the reputation of our brands if we do not meet the voluntary objectives we set.

Key opportunities

The opportunities assessed include:

• resource efficiency, such as optimising the use of materials and waste management;
• markets, including supply chain sustainability and the sharing economy (e.g. shared transport packaging);
• financing, such as investment funds for circular economy projects;
• reputation, continuously improving communication and interaction with the various stakeholders, towards meeting their expectations and addressing their concerns.

Waste

Total waste produced

In 2024, operations produced 634,337 tonnes of waste, an increase of 7.0% compared to 2023 (593,064 tonnes), driven by growth in operations and increasing specialized perishable offerings, particularly at Biedronka. Specific waste production (tonnes per million euros in sales) decreased 2.2%, from 19.38 to 18.96.

Waste produced by type (tonnes)

Waste produced by business unit (tonnes)

Waste recovery and destination

Recovery rate: 84.8% in 2024 (decreased 0.6 p.p. from 85.4% in 2023)

Waste recovery rate by business unit (2024):

• Biedronka: 90.0%
• Hebe: 78.4%
• Pingo Doce: 65.2%
• Recheio: 70.3%
• Ara: 75.7%
• JMA: 92.4%

Waste management methods (2024):

• Recovery (recycling, organic recovery, incineration with energy recovery): 84.8%
• Landfill: 14.7%
• Incineration without energy recovery: 0.0%
• Other destinations without recovery: 0.4%

Food waste

2024 performance:

• 19.9 kg food waste per tonne of food sold (+7.6% vs 2023)
• 1.8% annual food waste relative to volume of food sales (+0.1 p.p. vs 2023)
• Within target of ≤2.5% for 2024-2026 period
• Commitment aligned with UN SDG 12.3

Food waste by destination (kg/tonne food sold, 2024):

• Animal feed and bioprocessing: 1.4
• Anaerobic digestion, composting, controlled combustion: 11.7
• Landfill, incineration, wastewater treatment: 6.8

Food waste by business unit (kg/tonne food sold, 2024):

• Biedronka: 21.6 (+10.2% vs 2023)
• Pingo Doce: 20.0 (-9.5% vs 2023)
• Recheio: 5.4 (+35.0% vs 2023)
• Ara: 15.3 (+5.5% vs 2023)

Food waste prevention initiatives:

• Recovery of 83,300 tonnes of food (vs 70,700 tonnes in 2023)
• Avoided ~55,000 tonnes CO2e emissions
• Since 2015: prevented ~137,000 tonnes food waste through incorporation of ungraded vegetables into soups and ready-to-use products
• Since 2019: prevented 38,000 tonnes through markdown initiatives
• 18,600 tonnes donated to charities in 2024
• Too Good To Go partnership (Biedronka): 1.5 million bags delivered, preventing ~2,280 tonnes waste

Customer waste collection in stores (tonnes)

Waste management approach

The Group follows the waste hierarchy: reduce, reuse, recycle. Internal environmental management standards are established to reduce impacts, monitored through audits (9,016 audits conducted in 2024, average score 92%). The Group aims for at least 70% of distribution centres and industrial units to have ISO 14001 environmental certification (73% achieved in 2024).

The Group is committed to providing a healthy work environment, fair and adequate remuneration, answers to the needs and vulnerabilities, and development opportunities within the organisation, in order to promote employee well-being and a feeling of personal and professional accomplishment.

The Group ended 2024 with a total of 139,907 employees and is becoming increasingly multicultural, with 87 different nationalities within the Group.

Internally, we invested 354 million euros in measures to recognise our employees (13% more than the investment made in 2023), who were also recipients of more than 56 million euros in internal responsibility programs and well-being measures.

We maintained our commitment to the training and development of our people, achieving an average of 64 hours of training per employee, with an investment exceeding 17 million euros, 31% of employees having internal mobility opportunities, and more than seven thousand promoted to positions of greater responsibility.

Taking action on material impacts on own workforce

Jerónimo Martins discloses multiple actions and programmes related to own workforce material impacts across several areas:

Security and Safety

Assets, People, and Property Security Programme

• Scope: Own operations (employees, customers, suppliers, shareholders)
• Activities:
  • Definition and dissemination of standards and work instructions
  • Awareness and training initiatives for employees
  • Auditing of stores, warehouses, and sites across all Group companies
  • Risk assessment (threat analysis and vulnerability identification)
  • Emergency drills collaboration
  • Development of innovative technological solutions
• Responsibility: Security Department

Information Security Management System

• Scope: Own operations
• Activities: Implementation and maintenance of system ensuring confidentiality, integrity and availability of critical business information
• Responsibility: Dedicated Information Security Department

Learning and Development

Perishables Training Programmes

• Scope: Own operations (Portugal, Poland, Colombia)
• Participants: 63,541 employees trained in 2024
  • Portugal: 23,492 employees (Pingo Doce and Recheio)
  • Poland: 16,868 employees (Biedronka)
  • Colombia: 23,181 employees (Ara)
• Activities: Perishables School in Portugal covering butchery, bakery, pastry, fresh food, fish categories; Butchery School at Recheio; "Zostań Świeżoznawcą" programme in Poland
• Outcome: 25.4% increase versus 2023

Logistics School

• Scope: Own operations (Portugal and Poland)
• Participants: 432 employees in 2024
• Activities: Training focused on continuous improvement in logistics processes at distribution centres

Customer Service Training

• Scope: Own operations
• Participants: Over 45,000 employees in 2024
• Activities:
  • SVAL model ("Sorrir, Vender, Agradecer, Limpar") at Pingo Doce: 26,260 employees trained
  • Number 1 pilot project at Recheio

Commercial Skills Training

• Scope: Own operations
• Participants: 134 employees
• Training hours: 3,424 hours in 2024
• Programmes:
  • "Biedronkowa Akademia Kupca" (Biedronka Shopping Academy)
  • Commercial School (transversal across Companies)
  • Ara Commercial School (launched 2024)

100% Online Degree in Commercial and Retail Management

• Scope: Own operations
• Participants: 58 employees (2023-2024)
• Activities: Partnership with Universidade Católica Portuguesa
• Resources: Co-financed by the Group

Be a Leader Programme

• Scope: Own operations - Strategic and Managerial levels
• Participants: 1,437 employees since launch; 265 in 2024
• Time horizon: Ongoing since 2018
• Resources: €1.2 million invested in 2024
• Activities: Partnership with Centre for Creative Leadership (CCL); includes classroom training, individual coaching, collaborative learning groups
• Stages: Leading Self, Leading Others, Leading Teams

Mentoring Programme

• Scope: Own operations (Portugal)
• Participants: 81 mentor-mentee pairs across three pilot projects
• Activities: Partnership with LEAD Network; focused on trainees and IT Department

General Management Programme

• Scope: Own operations
• Resources: €542,000 invested in 2024
• Activities: Partnership with Católica Lisbon School of Business & Economics and Kellogg School of Management
• Target: High-potential leaders from Portugal, Poland, Slovakia, Colombia

Store Management Programmes

• Scope: Own operations
• Participants: 1,377 operations leaders trained since inception
• Programmes:
  • "Programa de Especialização de Gestão de Loja" (Recheio)
  • "Programa Geral de Gestão de Loja" (Pingo Doce)

Michelin Star Chef Programme

• Scope: Own operations (Pingo Doce)
• Participants: 51 employees in 2024
• Target: Chefs and sous chefs in Meal Solutions' central kitchens
• Activities: Communication, emotional management, conflict management, team motivation

Leadership Academies in Poland

• Scope: Own operations (Biedronka, Hebe)
• Participants:
  • 869 employees in Biedronka operational programmes ("Akademia Zarządzania dla SOM", "Biedronkowa Akademia Zarządzania 2.0")
  • 35 employees in "Akademia Zarządzania Biuro" and General Management Programme
  • New "Biedronkowa Akademia Zarządzania – Zaawansowana" launched for experienced store managers

Leadership Academy (Colombia)

• Scope: Own operations (Ara)
• Participants: 5,253 in 2024
• Status: New programme launched in 2024

Talent Development

Trainee Programme

• Scope: Own operations (Group-wide)
• Participants: 85 participants in 2024 (37 new entrants)
• Time horizon: Two-year programme
• Activities: Revised in 2024 for Group alignment; includes projects with tutors, immersive retail experience, mentorship, senior management meetings

Summer Internship Programme

• Scope: Own operations (Portugal, Poland, Colombia)
• Participants: 73 university students (Portugal/Poland); 31 interns (Colombia)
• Time horizon: Two months during summer holidays

Professional Internship Programme

• Scope: Own operations (Portugal)
• Participants: 20 interns in 2024
• Time horizon: 6 months to 1 year

Ambassador Programme

• Scope: Own operations (Portugal)
• Participants: 19 participants in 2024
• Activities: Representing Jerónimo Martins Group at universities

Campus Recheio 2024

• Scope: Own operations (Recheio)
• Participants: 24 participants
• Activities: Curricular, professional and seasonal internships, ambassador programmes, academic work, business visits

Futuro JMA (JMA Future)

• Scope: Own operations (agrifood business)
• Participants: 19 people
• Activities: Customised internships for agrifood business

Inclusion and Diversity

Incluir (Include) Programme

• Scope: Own operations (Portugal)
• Launched: 2015
• Participants: 37,518 employees and 17,203 family members in 2024 (15.1% increase vs 2023)
• Target: People with disabilities/impairments, migrants, refugees, people at social risk
• Resources: Network of 124 partner institutions
• Activities:
  • Two-week training at Incluir Centres in Lisbon and Porto
  • Week 1: Interpersonal skills
  • Week 2: Simulation stores for operational tasks
  • Specialized recruitment team for rehabilitation and social integration
  • Individual development plans with case managers
• Infrastructure: Dedicated Centres with accessibility features (lifting platforms, Braille, tactile maps, adjustable lighting)

Intergenerational Training

• Scope: Own operations (Poland - Biedronka and Hebe)
• Participants: 56 people trained in 2024
• Activities: Training on intergenerational communication, cooperation, feedback, culture of appreciation

JM Talks

• Scope: Own operations (Group)
• Participants: 547 people
• Activities: Knowledge sharing sessions between experienced and junior leaders

Reverse Mentoring

• Scope: Own operations (Biedronka)
• Participants: 12 seasoned employees supported by young people
• Activities: Development of technological and intergenerational management skills

Christmas Internship Programme

• Scope: Own operations (Pingo Doce)
• Participants: 352 children of employees aged 16-25
• Time horizon: During Christmas holidays

Summer Academy

• Scope: Own operations (Pingo Doce)
• Participants: 131 young people
• Activities: Business knowledge and communication/interpersonal skills development

Employee Wellbeing

Health Screenings Programme

• Scope: Own operations (Portugal)
• Resources: Over €1.3 million invested in 2024
• Participants: 37,518 employees (15.1% increase vs 2023) and 17,203 family members
• Activities: Blood tests (vitamin, diabetes, hormone, cancer screening/tumour markers), specialist analysis, ultrasound scans for offices and distribution centres employees, discounted examination packages for family members

Physical Wellbeing Programme

• Scope: Own operations (Poland - Biedronka and Hebe)
• Participants: 13,066 employees in 2024
• Resources: €205,000 invested
• Activities: Sports card access to 5,000+ facilities, individual/group sports participation financing, running and cycling challenges

Mental Health Programme

• Scope: Own operations (Portugal)
• Resources: €209,000 invested in 2024
• Participants: 1,142 people (767 employees and 375 children)
• Activities: Free psychology and psychiatry appointments for employees and minor children; "Cuidar do Cuidador" (Caring for the Carer) programme for Pingo Doce operational HR managers including training, supervision and individual coaching

Mindgram Platform

• Scope: Own operations (Poland - Biedronka and Hebe)
• Participants: 5,534 active users in 2024
• Launched: 2023 (Hebe), extended to Biedronka in 2024
• Activities: Free online platform for employees and families offering:
  • Educational content (articles, webinars, podcasts on mental health, career development, personal finance)
  • Unlimited online psychological support sessions
  • Chat with professionals in psychology, law, finance

Razem zadbajmy o zdrowie (Let's Take Care of Health Together)

• Scope: Own operations (Poland)
• Activities: Access to psychiatry appointments

Spokojna Głowa (Calm your Mind)

• Scope: Own operations (Biedronka)
• Participants: 4,711 views in 2024
• Activities: Digital content on motivation, healthy lifestyle, meditation, stress management; webinars on mental health

Mental Health Helplines

• Scope: Own operations (Ara and Biedronka)

Social Support

Social Emergency Support

• Scope: Own operations (Group-wide)
• Resources: €48.4 million invested in 2024 in internal social responsibility measures
• Resources (Portugal and Poland): €7.9 million in Social Emergency Fund (Portugal) and employee allowances/loans (Poland) - 7.5% increase vs 2023
• Activities: Support for employees in vulnerable situations due to social/family emergencies

Performance and Development Management

Performance Appraisal Process

• Scope: Own operations - all eligible employees
• Coverage: 100% participation across all hierarchical levels (Strategic, Managerial, Operational)
• Activities: Annual cycle including objective setting, monitoring, evaluation, feedback, career discussions, personal development plans
• Principles: Meritocracy, equal opportunities, non-discrimination

Potential Assessment

• Scope: Own operations
• Participants: 8,278 employees in 2024
• Activities: Strategic tool for talent monitoring, development planning, succession pipeline management

Skills Assessment Tool

• Scope: Own operations (Portugal, Poland, Colombia - pilot)
• Participants: 4,552 employees assessed in 2024
• Activities: Assessment of skills required for internal/external recruitment

Anti-Corruption and Ethics Training

Anti-Corruption Policy Training

• Scope: Own operations (Group-wide)
• Training hours: 24,937 hours in 2024 (47.1% increase vs 2023)
• Reach: 42,477 employees via communication campaigns
• Activities:
  • E-learning and advanced training for critical functions
  • Specific training for HR and Quality/Food Safety teams on Due Diligence Procedure
  • Colombia: 6,151 employees trained in self-control and risk management for money laundering/terrorist financing; PTEE (Transparency and Business Ethics Programme) training
• Onboarding: Code of Conduct and Anti-Corruption Policy acknowledgment for all new employees

Food Safety Training

Food Safety Training (Poland)

• Scope: Own operations (Biedronka)
• Participants: 25,135 employees (14.6% increase vs 2024)
• Training volume: 9% growth
• Topics: HACCP standards, waste separation, washing/cleaning, hygiene practices

Food Safety Training (Portugal)

• Scope: Own operations
• Training volume: 60.7% increase vs 2023
• Topics: HACCP risk control, food defence practices, meat handlers card renewal (required every 3 years)

Food Safety Training (Colombia)

• Scope: Own operations (Ara)
• Topics: "Tiendas Siempre Limpias" (Stores Always Cleaned), hygiene plan, water control, waste handling, quality audits, cold chain, critical control points

Employee Engagement

Employee Satisfaction Surveys

• Scope: Own operations (Group-wide)
• Time horizon: Ongoing throughout year; comprehensive survey every 2 years per Engagement Policy
• Topics: Health and safety at work, employee support services, Hello JM features satisfaction
• Link to policy: Engagement Policy

Work Organization

Schedule Planning Tool Enhancement

• Scope: Own operations
• Status: Evolution into new solution
• Activities: Data-fed tool using sales and in-store customer traffic for predictability of staffing needs
• Expected outcome: Better work-life balance through improved scheduling

Targets related to own workforce

1. Human and Labour Rights

Target: Promote respect for human and labour rights by:

• Ensuring a training module on the Code of Conduct available to 100% of employees
• Ensuring a global training programme on human and labour rights available to 100% of managers
• Implementing an internal global policy and process of prevention and compliance with labour rights

Target year: Not specified Baseline year: Not specified Scope: Global (all employees and managers across the Group) Progress (2024):

• E-learning training module on Code of Conduct launched for Poland, Portugal and Colombia (mandatory for all employees); Slovakia version under development
• E-learning training module on human and labour rights developed; pilot conducted; launch for all managers in Portugal planned for 2025
• In Portugal, critical topics identified and approved; preliminary diagnosis of compliance conducted by external entity

2. Gender Equality

Target: Strengthen the promotion of gender equality across the Group by:

• Deploying a global diagnosis of HR practices to identify any gender inequalities
• Ensuring a gender pay ratio variation of +/- 3% compared to the parity ratio (100%), globally and by country
• Ensuring a global training programme on unconscious bias available to 100% of managers

Target year: Not specified Baseline year: Not specified Baseline value: Gender pay ratio of 98.5% (implied from 2024 result) Scope: Global and by country Type: Intensity-based (ratio) Progress (2024):

• Global diagnosis carried out focused on gender representativeness and HR practices
• Global gender pay ratio: 98.5% (stable, within defined variation range)
• Country-specific ratios: Biedronka: 98.1% | Pingo Doce: 99.9% | Ara: 98.7%
• E-learning training module on discrimination and harassment (including unconscious bias) developed; pilot conducted; launch to all managers in Portugal planned for 2025

3. Leadership Development and Knowledge Transfer

Target: Reinforce leadership capabilities in future generations and stimulate knowledge transfer by:

• Organizing at least four yearly global sessions with senior experts, available to all young talent population
• Promoting a global Jerónimo Martins experience for the young talent population, with the definition of a new global trainee policy
• Ensuring that 90% of managers take part in at least one leadership development initiative by the end of 2026
• Embedding the Group's Values and associated behaviours in people management processes with at least two global processes reviewed and 100% of eligible employees impacted
• Implementing a mechanism to measure leadership impact in the Group

Target year: 2026 (for 90% managers participation) Baseline year: Not specified Scope: Global Progress (2024):

• Two JM Talks sessions held globally with 547 young leaders participating
• New global policy for young talent defined; expected to be published in 2025
• 52.5% of the Group's managers participated in at least one leadership development initiative
• Performance management process revised to include Group's Values and behaviours evaluation
• New Group-wide employee engagement survey planned for 2025, including leadership-related questions

4. Recognition and Compensation Transparency

Target: Strengthen recognition mechanisms and promote greater transparency about compensation by:

• Ensuring at least one recognition mechanism that values behaviours in all Companies, covering 100% of employees by 2026
• Making available the total compensation package statement (fixed and variable remuneration and benefits) to 100% of employees by 2026

Target year: 2026 Baseline year: Not specified Scope: Global (all Companies, 100% of employees) Progress (2024):

• All Group's Companies working to ensure compliance; 2024 performance cycle includes Values and behaviours evaluation
• Group assessing feasibility of timetable for total compensation package statement based on implementation priorities of existing technological solutions

5. Social Inclusion and Employment of Disadvantaged Groups

Target: Increase the number of employees in our workforce at a disadvantaged position in accessing the labour market (people with disabilities and/or impairments, refugees and migrants or people at social risk) and contribute positively to increasing social inclusion awareness within and outside the Group, promoting at least four yearly forums to share good practices

Target year: Not specified (ongoing increase) Baseline year: 2024 (first year of monitoring) Baseline value: 4.7% of the Group's population Scope: Global Progress (2024):

• 4.7% of employees at a disadvantage in accessing the labour market (first year baseline)
• 54 actions to share good practices conducted (exceeding target of four yearly forums)

6. Internal Development and Mobility

Target: Reinforce internal development and mobility opportunities by:

• Creating personal development plans for at least 95% of eligible managers
• Evolving the personal development plan definition process, aligning it with individual and business needs
• Ensuring that 100% of eligible internal vacancies are published and increasing the average number of applications per vacancy
• Rolling out a global referral programme

Target year: Not specified Baseline year: 2024 (for internal vacancies) Baseline value: 74.6% eligible vacancies published internally; 2.6 internal applications per vacancy Scope: Global Progress (2024):

• 95.3% of eligible managers have defined personal development plans
• PDP process evolved to include reflection and monitoring moments during Get Feedback sessions
• 74.6% eligible vacancies published internally; average 2.6 internal applications per vacancy (first year baseline)
• Global internal referral policy for IT department in place, extended to other roles in Portugal

7. Occupational Health and Safety

Target: Foster safe working conditions by:

• Investing in certifying at least three new workplaces/Companies following ISO 45001
• Decreasing the current frequency index to 12.00 and severity index to 0.29

Target year: Not specified (2024-2026 commitment cycle) Baseline year: 2023 (implied) Baseline value: Frequency index: 13.06; Severity index: 0.32 (implied from 2024 reduction) Scope: Global Type: Absolute Progress (2024):

• Occupational health and safety management system in two central kitchens of Pingo Doce's Meal Solutions certified by ISO 45001:2023; certification of logistics in Portugal and Recheio in preparation
• Frequency index: 11.87 (decrease of 1.19 compared to 2023; target achieved)
• Severity index: 0.29 (decrease of 0.03 compared to 2023; target achieved)

8. Flexible and Healthy Work Environment

Target: Promote a flexible and healthy work environment across the Group by:

• Piloting at least one measure in the scope of new ways of working and/or hiring
• Making training in wellbeing available to 100% of managers
• Ensuring that 100% of employees have access to a structured wellbeing programme
• Supporting employees in vulnerable situations, ensuring at least the same level of investment in the Social Emergency Fund (Portugal) and Możesz Liczyć programme (Poland)

Target year: Not specified Baseline year: 2023 (for social support investment) Baseline value: €7.3 million (implied from 2024 increase of 7.5%) Scope: Global Progress (2024):

• Biedronka implemented Tikrow solution; Pingo Doce evolving schedule planning tool
• Wellbeing contents to be incorporated into global development training tool
• 100% of employees in Portugal and Poland have access to wellbeing programme; various initiatives in Colombia
• Investment of more than €48.4 million in internal social responsibility measures; €7.9 million in social allowances and Social Emergency Fund (7.5% above 2023)

Characteristics of the undertaking's employees

Total headcount and FTE

Total workforce (31 December 2024): 132,126 employees
Total workforce (31 December 2023): 128,289 employees

The Group reports headcount figures but does not explicitly break out FTE (full-time equivalent) separately in the excerpts provided.

Headcount by gender

Gender breakdown is not disclosed in granular tabular form in the excerpts. The excerpts note that the Group has 87 different nationalities and is included in the FTSE Diversity & Inclusion Index, but do not provide a split of male/female/other/not disclosed headcount.

Headcount by country or region

The excerpts indicate the Group operates in Poland, Portugal, and Colombia, with over 90% of business in Europe. Specific headcount by country is not disclosed in tabular form.

Headcount by employment contract type (permanent/temporary/non-guaranteed hours)

Not disclosed in the excerpts.

Headcount by employment type (full-time/part-time)

Not disclosed in the excerpts.

Employee turnover rate / number of employees who left

Not disclosed in the excerpts.

New hires (number / rate)

Not disclosed in the excerpts.

Additional employment-related information

The excerpts include limited contextual information:

• The Group invested over €350 million in recognition measures in 2024 (up 13% year-on-year).
• Investment in training and development programmes is mentioned but not quantified in headcount-related terms.
• The Group references employees across its operations (Biedronka, Pingo Doce, Recheio, Ara, Hebe) but does not provide disaggregated headcount tables.

Remuneration context (Jerónimo Martins, SGPS, S.A. - parent company only)

The excerpts include a table for total remuneration at the parent company level (Jerónimo Martins, SGPS, S.A.), which is not the same as Group-wide employee headcount:

Note: The 2024 figure reflects a reduction due to the transfer of several employees to shared services centers; the comparable average salary for the 2023 population would be €146,538.

This table refers only to employees of the parent entity (Jerónimo Martins, SGPS, S.A.) and does not represent the consolidated Group headcount of 132,126 employees.

Conclusion: The excerpts do not contain the detailed ESRS S1-6 tables (headcount by gender × region × contract type × employment type, turnover, new hires). The only quantitative data available are total Group headcount (132,126 in 2024 vs 128,289 in 2023) and parent-company-level average remuneration figures.

Characteristics of non-employees in the undertaking's own workforce

Workers who are not employees

At the end of 2024, there were 21,661 workers who are not employees recorded in our internal systems, accounting for 13.4% of the Group's total workforce. In most cases, these workers are hired through temporary employment agencies to perform roles such as store and logistics operators.

Workers who are not employees by geography

Methodology

• The number of workers who are not employees in the global office functions and operations in Portugal corresponds to the headcount recorded in the human resources management system on 31/Dec/2024.
• In Poland, the number of workers who are not employees in Biedronka stores corresponds to the headcount recorded in a local management system on 31/Dec/2024. In the distribution centres and Hebe stores, the accounting of workers who are not employees corresponds to the number of full-time equivalent (FTEs) on 31/Dec/2024, estimated from the hours worked report provided by the service provider.
• In Colombia, the number of workers who are not employees in Ara's operations corresponds to the headcount recorded in internal manual systems on 31/Dec/2024.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

A top concern in safeguarding employees' rights is freedom of association and collective bargaining. Under the terms of applicable law, all employees are free to form and join organisations without the need for prior authorisation and may be represented by them when negotiating agreements with their employer.

Collective bargaining, for now only applicable to Portugal, covers 98.2% of employees in the country, where we have 13 active collective agreements.

In Poland and Colombia, there are no collective labour regulation instruments applicable to the Group's Companies. Working conditions and the way in which the employment contract is executed are regulated by the respective legal systems and by the internal, local and global policies in force within our Group.

Overall Group coverage: 24.9% of the Group's total workforce (Portugal only)

Collective bargaining coverage by geography

*In Poland and Colombia there are no collective regulation instruments applicable to the Group's companies.

Social dialogue and workplace representation

In the context of social dialogue, we participate in several bargaining forums with employee representation structures. In Portugal, we actively participate through sectoral employers' organisations, such as APED (Portuguese Association of Distribution Companies), and those that cut across various industries, such as CIP (Confederation of Portuguese Business).

We also contribute to sectoral social dialogue at European level promoted by the European Commission, where the Group is represented through its membership of EuroCommerce.

Workplace representation (EEA only):

• Portugal: 85.9% of employees in Companies with employee representation
• Poland: 95.4% of employees in Companies with employee representation

The Group ensures timely compliance, in accordance with the laws of each country, with all rules related to the right to information and/or consultation in force.

Social dialogue coverage by geography

Social dialogue mechanisms and channels

The Labour Relations Division, unions, social dialogue forums, and union representatives engage with employees' representatives through letter, e-mail, and social dialogue forums.

In the area of diversity and inclusion, we were recognised as one of the 100 best-performing companies in the world in the FTSE Diversity & Inclusion Index, highlighting our achievements in promoting gender equality, with the salary ratio between women and men remaining above the market, at 98.5%.

We were included in the FTSE Diversity & Inclusion Index, which recognises the Top 100 companies in the world that better qualify as inclusive workplaces. The Jerónimo Martins Group is the only Portuguese company to be included in this index.

As an employer, we are becoming increasingly multicultural. We have 87 different nationalities within the Group.

Adequate wages

Benchmark used

Jerónimo Martins benchmarks adequate wages against national minimum wages in each country of operation. The company states:

"We therefore continued to ensure that all Jerónimo Martins Group employees received adequate salaries, in accordance with the applicable benchmarks."

The applicable benchmark is defined in footnote 65 as:

"Comparing the lowest monthly income of the lowest remuneration category, equivalent to full-time working hours, excluding trainees and apprentices, with the applicable national minimum wage pursuant to the laws in each country and/or by collective bargaining, where applicable."

No living wage methodology is disclosed. The company uses national minimum wage as the benchmark, not a living wage standard that covers basic living needs for workers and their families.

Coverage and performance

100% of employees receive wages at or above the national minimum wage in their respective countries.

By country:

• Portugal: Take-home income between 17% and 60% above the national minimum wage
• Poland: Take-home income between 9% and 17% above the national minimum wage
• Colombia: Take-home income 12% above the national minimum wage

Take-home income includes base salary plus guaranteed additional payments (meal allowance, transport allowance, presence allowance depending on country).

Comparing average salaries to national minimum wages, there is a differentiation of at least 23%, reaching double the reference in Ara (Colombia).

Geographic scope

Covers main operations in:

• Portugal
• Poland
• Colombia

Slovakia and Czechia are noted as "not yet sufficiently representative to calculate this indicator" (0.2% of total workforce).

Methodology details

The company follows three pay strategy principles:

1. Creating positive impact ensuring "balanced and dignified standard of living for employees and their families"
2. Competitive pay packages adjusted to functional levels with fairness and equity
3. Recognizing effort, commitment and performance

Entry-level salaries are set to be competitive compared to national minimum wages, with increases in line with experience and performance.

Take-home income calculation (per footnote 65):

• Portugal: entry base salary + meal allowance
• Poland: entry base salary + presence allowance
• Colombia: entry base salary + meal allowance + transport allowance

The company also reports significant investment in recognition measures (354 million euros in bonuses, awards) in 2024.

Context on minimum wage increases

The company tracks minimum wage evolution:

• Poland: minimum wage increased over 19% in 2024 compared to 2023, and over 65% since 2020. Biedronka increased entry-level pay by 19% to remain competitive.
• Portugal: minimum wage increased by 7.9% to €820 in January 2024. All companies ensured up to 8% increase in minimum entry-level salaries.
• Colombia: minimum wage increased 9.5% to 1,423,500 Colombian pesos in 2025.

Targets and commitments

No forward-looking targets regarding living wage benchmarks are disclosed.

Limitations

The company does not assess wages against a living wage benchmark (such as Fair Wage Network, Global Living Wage Coalition, Anker Methodology, or similar). The reference to "adequate salaries, in accordance with the applicable benchmarks" refers exclusively to compliance with national minimum wage laws and collective bargaining agreements, not to a living wage standard that independently assesses the cost of living for workers and their families.

Social protection

Coverage overview

In the main countries where we do business (Portugal, Poland, Colombia, Slovakia and Czechia), all employees are covered by social protection through mandatory public schemes against loss of income, in which casualties such as:

• Sickness
• Unemployment
• Employment injury
• Acquired disability
• Parental leave
• Retirement

are included.

Supplementary company programmes

As a Group, we have a permanent commitment to making a difference in the lives of our employees and their families, and to supporting them in situations of vulnerability and/or social emergency, as well as in priority support areas such as health and education, through internal social responsibility (ISR) programmes that complement existing community responses.

Investment in ISR by pillar of action (million euros)

*In order to expand its reach and social impact, some of the ISR programmes were transferred to the Jerónimo Martins Foundation during the year. The figures reported refer only to the investment provided by the Jerónimo Martins Group until the respective transition.

**This includes a value of 6,044,378€ granted in loans to Biedronka employees, which is returned to the Company.

Defined benefit and contribution pension plans

Retirement benefits recognized in balance sheet (million euros)

Consolidated Group:

JMH (Parent Company):

Amounts recognised in income statement (thousand euros)

Consolidated Group:

JMH (Parent Company):

Retirement Pension Plan for Executive Directors

Approved at the 2005 Annual General Meeting, this is a Defined Contribution Pension Plan where:

• The contribution rate is 25% of pensionable salary (fixed in advance)
• The value of benefits varies depending on earnings obtained
• Plan participants include Executive Directors of the Company
• Retirement date coincides with normal retirement age as established in the General Social Security Scheme
• Pensionable salary = gross monthly salary paid by the Company and subsidiaries × 14 ÷ 12
• Variable remuneration is added annually to the fixed monthly amount

For Directors in office at the 2005 General Meeting who did not opt for this plan, a complementary pension regime applies (established in 1996) granting a Complementary Pension at retirement age when they: (i) are over 60 years old; (ii) have performed executive functions; and (iii) have performed the role of Director for more than 10 years.

Remuneration paid to Directors including pension contributions (euros)

*Annual variable remuneration fixed and paid in 2024, following the performance assessment for the year 2023

Persons with disabilities

Employees with disabilities and/or an impairment

Programmes and initiatives

Incluir (Include) Programme (Portugal, launched 2015) aims to create training and hiring opportunities for people with disabilities and/or impairments, migrants, refugees and people at social risk. The programme follows a methodology customised to each person and adapted to available roles, encompassing training in psychosocial skills and practical on-the-job training, as well as adaptation of the workstation.

Based on a network of 124 partner institutions that support identification of potential candidates. The process includes:

• Application and recruitment by internal technical team specialised in rehabilitation and social integration
• Analysis of skills profile and motivations
• Individual plan creation with assigned case manager
• Two-week initial training at Incluir Centres (Lisbon and Porto): one week on interpersonal skills, one week in simulation stores
• Ten-week training in real work context with tutors (80 tutors in 2024)

Since launch in 2015, the Incluir Programme has reached 2,059 people. In 2024, the programme saw 350 people involved, 92 of whom were hired.

Biedronka (Poland, 2024) strengthened its strategy with creation of a self-checkout support function to support consumers in using automatic checkouts.

Recognition

• Recheio and Holding Company: Inclusive Employer Brand (IEFP) since 2021; Holding Company elevated to "Excellence" level in 2023
• Pingo Doce: Inclusive Employer Brand since 2023; distinguished as Master Diversity, Equity and Inclusion by Distribuição Hoje magazine in 2024

We maintained our commitment to the training and development of our people, achieving an average of 64 hours of training per employee, with an investment exceeding 17 million euros, 31% of employees having internal mobility opportunities, and more than seven thousand promoted to positions of greater responsibility.

Health and safety metrics

(a) Health and safety management system coverage

100% of the Group's workforce was covered by a HSW (Health and Safety at Work) management system in 2024.

(b) Fatalities

Employees:

• 1 fatality (Portugal, resulting from head trauma due to work accident)

Workers who are not employees:

• 2 fatalities (1 in Portugal, 1 in Colombia)

(c) Recordable work-related injuries and rates

*High-consequence work-related injuries are those that result in employee absence of more than 180 days.

**Rate of high-consequence work-related injuries = (Number of high-consequence work-related injuries except fatalities/Total Hours Worked) × 10⁶.

***Rate of recordable work-related injuries = (Number of recordable work-related injuries/Total Hours Worked) × 10⁶. Recordable injuries include those resulting in fatalities, days away from work, limited work or transfer to another job, medical treatment beyond first aid or loss of consciousness.

Work-related ill health:

Note: In Poland and Colombia, the number of recordable work-related ill health among workers who are not employees is not yet fully monitored. The Group continues to improve information systems to ensure complete reporting.

(d) Days lost

No rate for days lost was disclosed.

Work-life balance metrics

Entitlement and coverage

All Group employees are entitled to family leave and to make use of it.

Work-life balance initiatives coverage

• Hours bank system (Pingo Doce): 22,433 employees in 2024
• Scheduling solution (Pingo Doce): 26,887 employees in 2024
• Automated planning pilot (Pingo Doce): 542 employees in 2024
• Flexible Working Policy (offices): 6,617 employees across all Companies
• Daycare centres (Portugal): 225 children of employees in 2024
• Tikrow platform (Biedronka): Met 43,273 immediate needs in 2024

Parental leave metrics (2024)

*The return-to-work rate is the percentage of employees who returned from parental leave based on employees who took parental leave during the period.

**The rate of employees who are still on parental leave corresponds to the percentage of employees who have not yet returned from leave, based on employees who have taken parental leave in the period.

***The retention rate corresponds to the percentage of employees who returned from parental leave in 2023 and who remain working in the Group 12 months later.

Compensation metrics

Pay gap

Jerónimo Martins reports the gender pay ratio by country and for the most representative Company in each country:

The gender pay ratio represents the salary difference between women and men within the universe of Jerónimo Martins employees, based on comparable realities. It is expressed considering women's average salary as a percentage of men's average salary, where 100% is the pay ratio that represents full pay equity.

The methodology was changed in 2024, considering the new structure of functional levels fully implemented in the different countries in which the company operates. In Slovakia and Czechia, countries in which the company recently started operating, there is not a sufficiently robust sample to be included in the calculation and presentation of results. The ratios of the most representative Company in each country are reported. As more than 97.3% of employees belong to the Operational functional level, the results of the gender pay ratio are mostly illustrative of this segment.

Remuneration ratio

Concerning the ratio between the remuneration of the highest paid individual and the median remuneration of employees, the company states:

Phased in: Due to the complexity in standardizing salary information caused by the geographic dispersion of the Group that was amplified in 2024, the immediate incomparability of functions in different countries and the dissimilarity of remuneration concepts in the several Group Companies, it is fundamental to find a base to calculate this indicator that prevents it from being misleading. The Group is taking all due diligences to fulfil the requirements of this ratio, guaranteeing the quality of the information disclosed.

Methodology

The gender pay ratio calculation is aligned with the ESRS methodology, with partial ratios being reported by Company and country, considering the heterogeneity between them. The calculation considers comparable realities within the employee universe and excludes countries with insufficient sample sizes (Slovakia and Czechia).

Incidents, complaints and severe human rights impacts

Labour-related complaints

In 2024 we received 3,580 labour-related complaints, of which 100% were analysed, 85.4% were closed and 51.9% required remedy actions.

*Number of complaints made by employees through the Ethics Committee, Ethics Offices and the Employee Assistance Service.

**Number of complaints analysed by resolution mechanisms out of the total number of complaints received.

***Number of complaints whose conclusion within the scope of the analysis resulted in the need to implement remediation actions out of the total number of complaints received.

****Number of complaints considered closed by 31/Dec/2024 after the appropriate analysis, out of the total complaints received.

Complaints involving discrimination and harassment

Among the received labour complaints, in 2024 a total of 136 complaints involving discrimination, including harassment, were reported and responded to through our resolution mechanisms. No incidents of forced labour, human trafficking or child labour were identified.

*In terms of the potential total amount of fines, pecuniary penalties and compensation for damages as a result of the aforementioned cases, the architecture necessary for this reporting is under development. The Group will take the necessary steps to report these potential indicators. Information on contingent liabilities considered to be material associated with ongoing proceedings is described in note 23. "Contingencies, contingent assets and contingent liabilities" in Chapter 3. "Financial Statements".

**Number of complaints involving discrimination and harassment investigated by the resolution mechanisms, out of the total complaints involving discrimination and harassment received.

***Number of complaints involving discrimination and harassment closed that led to the implementation of remedy actions, out of the total complaints involving discrimination and harassment received.

****Number of complaints involving discrimination and harassment considered closed by 31-12-2024 after the appropriate investigation, out of the total complaints involving discrimination and harassment received.

Severe human rights impacts

No incidents of forced labour, human trafficking or child labour were identified in 2024.

Fines and sanctions

With regard to non-compliance with environmental laws and regulations, there were no significant fines (a significant fine is considered to be a monetary amount equal to or greater than approximately €45,000).

Policies related to value chain workers

Jerónimo Martins upholds and respects human and labour rights throughout the value chain and, together with suppliers, seeks to mitigate potential risks and encourage the sharing of good social practices. The company is guided by a set of policies and requirements related to managing the risks and material impacts on the well-being of workers in the value chain.

Note: Workers in the value chain was not identified as a material topic by the company, but policies are still disclosed.

Sustainable Sourcing Policy

• Scope: Value chain workers and suppliers
• Public availability: Published on the Group's website
• Key content: Related to managing risks and material impacts on people's well-being in the value chain; disseminated among suppliers and/or included in contracts
• Alignment with international standards: The company states it is tightening up its human rights due diligence process in line with OECD recommendations and EU law related to the Corporate Sustainability Due Diligence Directive

Code of Conduct for Suppliers

• Scope: Suppliers and value chain workers
• Public availability: Published on the Group's website and/or included in contracts
• Key content: Sets requirements related to managing risks and material impacts on people's well-being in the value chain
• Alignment with international standards: Linked to the company's broader commitment to OECD Guidelines and UNGPs, as referenced in the due diligence framework

Anti-Corruption Policy

• Scope: Third-party entities that work with Group Companies, including suppliers
• Governance: Monitored by the Ethics Committee
• Public availability: Disseminated among suppliers
• Key content: Anti-corruption requirements applicable to suppliers and value chain partners
• Monitoring: The Ethics Committee monitors disclosure and compliance; the company periodically checks effectiveness through audits

Taking action on material impacts on value chain workers

Note: S2 (Workers in the value chain) was not identified as a material topic by Jerónimo Martins. However, the company reports partial information on actions taken.

Social Audit Programme

Action name: Social audits of perishables and Private Brand suppliers

What it does:

• Assesses suppliers to prevent and mitigate potential risks of human and labour rights violations
• Establishes direct contact with workers in the value chain
• Evaluates over 125 requirements across 12 dimensions including: preventing child and forced labour, preventing discrimination, safeguarding right of association, contractual terms, working hours, salaries and benefits, health and safety at work, emergency preparedness
• Includes criteria of "zero tolerance" (up to 26 specific criteria depending on scheme)
• Conducts interviews with workers in the value chain (over 420 people interviewed during 19 audits in 2024)

Scope: Upstream value chain (direct suppliers of perishables and Private Brand products)

Selection criteria:

• Purchase volume (annual volumes over €1 million)
• Risk matrix associating products and risk countries (using ILAB List of Goods Produced by Child Labor or Forced Labor)

Audit schemes: Three types adapted to high-risk social sectors:

1. Primary production
2. Operations at sea
3. Manufacturing industry

Resources allocated:

• Financial: Audits financially supported by the Group since programme inception
• Non-financial: External independent entity conducts audits; internal teams coordinate
• Four training courses held in 2024 covering human and workers' rights, policy and regulatory environment analysis, Group policies and codes

2024 Performance:

• 19 in-person audits carried out at direct suppliers (local suppliers in Portugal and Colombia)
• 8 suppliers classified as "Inadequate" in previous cycles were re-audited; 4 re-evaluated as "Excellent", 4 maintained "Inadequate" score
• Overall scores: 12 Excellent, 5 Very Good, 1 Good, 0 Satisfactory, 1 Inadequate

Process:

• Document analysis, on-site inspections, worker interviews (individual and group)
• Interviews prioritize vulnerable groups (young/older adults, migrants, temporary workers, pregnant workers, those returning from sick leave)
• Personalised corrective action plans for suppliers with critical non-conformities
• Mandatory response within 12 months depending on severity
• Regular contact during 12-month period to review progress
• In loco or remote assessment performed following year for "Inadequate" suppliers

Link to policy: Sustainable Sourcing Policy; Consumer Goods Forum's Sustainable Supply Chain Initiative; Human Rights Coalition Priority Principles (CGF)

Communication channels: Ethics Committee and Whistleblowing Policy available to value chain workers

Sustainability Certification Programme

Action name: Encouraging suppliers to implement sustainability certification systems

What it does:

• Promotes certifications following benchmarks with environmental and/or social requirements verified by external entities
• Ensures implementation of good environmental practices in value chain
• Confirms absence of child or forced labour, fair payment to producers
• Uses specific symbols on products at point of sale to communicate attributes to consumers

Scope: Upstream value chain (suppliers)

Link to policy: Referenced in policies on Consumers and end-users

Commitments and Targets (2024-2026)

Environmental audits commitment:

• Target: Carry out environmental audits to at least 20% of selected Private Brand and perishables suppliers (based on risk assessment, purchase volume >€1 million) in 2024-2026 period
• Progress (2024): In progress. 37 suppliers audited (including re-audits); 11 with ISO 14001 certification. At least 232 suppliers expected to be audited in 2024-2026 (20% more than 2021-2023)

Egg farming inspections (Poland):

• Target: Carry out inspections to 100% of egg farming units for Biedronka Private Brand fresh eggs by end of 2024
• Progress (2024): Accomplished. 100% inspected. Since 2018, more than 200 audits carried out

Animal welfare audits:

• Target: By 2026, ensure animal welfare topics included in audits of perishable suppliers producing products with at least 80% animal protein (Portugal and Poland), and publicly disclose results
• Progress (2024): Accomplished. Audits conducted in primary meat production, slaughterhouses, and fresh aquaculture fish production in both countries. Results reported in Governance section

Fish welfare audits (Poland):

• Target: Starting 2024, carry out 100% of fresh fish from aquaculture audits according to 'Fish Welfare' standard
• Progress (2024): In progress. 42% of Biedronka direct suppliers audited. Also initiated in Portugal for first time

The Group allocates significant resources to support local communities. In 2024, more than 81 million euros were allocated in direct support to over 2,100 entities. If we consider the 40 million euros attributed to the newly created Jerónimo Martins Foundation, the total amount reaches over 121 million euros in support for surrounding communities.

With the purpose of caring for the Group's employees and their families, as well as the communities in which it operates, the Jerónimo Martins Foundation was created on March 19, 2024. This project represents another significant step in the commitment to ensuring support for employees and communities in moments of their greatest need, mitigating their vulnerabilities. Its activities will primarily focus on three areas: social emergency, health, and education, fields where the projects already implemented by the Group have long demonstrated positive impacts.

In Colombia, Ara launched the "1 Million Reasons" programme, within the scope of which the company invested one million euros to support, together with NGOs and charities on the ground, the most vulnerable communities, especially children and mothers. We estimate to have reached 60,000 people by the end of 2024 through the several projects, namely with the creation of the first food bank in the Pacific region.

The "One Million Reasons" social investment programme was awarded by Portafolio newspaper in the 'Corporate Social Responsibility' category. Recognition by the Colombian Association of Food Banks was received for Ara's commitment to food security and the fight against hunger. The Colombian Family Welfare Institute (ICBF) recognised Ara's commitment to Colombian children.

Ara allocated one million euros to the "One Million Reasons" social investment programme, with two primary objectives: to promote health through food, focusing in particular on fighting child malnutrition, and to support local communities by creating social empowerment projects, in which education plays a key role in bringing change.

Targets related to affected communities

Target 1: Monitoring social impacts

• Target: Monitor and disclose at least 70% (in value) of the social impacts resulting from the annual support offered by all Jerónimo Martins Companies, according to the Business for Societal Impact (B4SI) model and aligned with criteria for financial materiality
• Target year: Not specified (ongoing)
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: All Jerónimo Martins Companies
• Type: Percentage-based
• Progress (2024): Accomplished. In 2024, it was possible to monitor 99% of the Group's direct support (eligible according to the internal methodology based on the B4SI criteria)

Target 2: People impacted from vulnerable environments

• Target: Directly impact one million people per year (children, youngsters and elderly from vulnerable environments)
• Target year: 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: All geographies (Poland, Portugal, and Colombia)
• Type: Absolute number
• Progress (2024): Accomplished. Based on the B4SI methodology, the Group Companies have supported more than 1.2 million people from vulnerable backgrounds, including projects focused on health and healthy eating

Target 3: Children nutrition support in Colombia

• Target: Promote health through food to at least 3,000 vulnerable children per year, through in-kind donations in regions with highest indicators of malnutrition and food insecurity
• Target year: Ongoing (per year)
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Colombia
• Type: Absolute number
• Progress (2024): Accomplished. 4,294 children were supported through the "Desayunos Saludables" (Healthy Breakfast) project in partnership with ABACO

Target 4: Store donation program in Colombia

• Target: Ensure that 50% of stores donate food and non-food products to nongovernmental organizations
• Target year: 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Colombia (Ara stores)
• Type: Percentage-based
• Progress (2024): In progress. 273 Ara stores with donation procedures to local institutions, representing 19% of the Company's stores

Target 5: Community mothers' houses in Colombia

• Target: Support more than 1,200 community mothers' houses through food and equipment assistance, while following-up on nutritional indicators of children under their care
• Target year: 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Colombia
• Type: Absolute number
• Progress (2024): Accomplished. 2,963 community mothers' houses were supported with gift cards. Technical assistance programme developed in partnership with ICBF and UNICEF

Target 6: Environmental volunteering in Colombia

• Target: Ensure at least 200 volunteers participate in environmental protection initiatives and livelihood improvement projects for vulnerable people
• Target year: 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Colombia
• Type: Absolute number
• Progress (2024): In progress. 150 volunteers participated in different initiatives focused on environmental protection and improvement of livelihoods of vulnerable people

Target 7: Humanitarian support in Colombia

• Target: Support more than 60,000 people in vulnerable conditions through humanitarian and livelihood programs (food), prioritizing children and regions with highest poverty rate and food insecurity indicators
• Target year: 2026
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Colombia
• Type: Absolute number
• External validation: Partnership-based (at least two partnerships with NGOs and/or other industry leaders)
• Progress (2024): Accomplished. More than 63,000 people supported through the "One Million Reasons" program (investment of one million euros until 2026)

The Group's consumer-focused policies are embedded in its mission to democratise access to quality food products and solutions, guaranteeing maximum security and savings for those who choose our proximity stores, in which perishable products and Private Brand play a central and strategic role in promoting health through food.

As part of our commitment to offering consumers high-quality and safe food that also contributes to better public health, 100% of all Private Brand breakfast cereals in Portugal have wholegrain cereals as the first ingredient, a target achieved earlier than the deadline we set ourselves. In Poland, our progress reached 92% of all eligible products.

Our commercial strategy has ensured that more than 90% of the Group's food product purchases were made from local suppliers, a trend we have maintained for more than a decade. The proportion of Private Label and perishable products with sustainability certification increased and now represents more than 14% of these categories, compared to 7.8% when we started disclosing this indicator in 2021.

Taking action on material impacts on consumers

Jerónimo Martins has implemented multiple actions across its operations to address material impacts on consumers and end-users, focusing on product quality and safety, product innovation, and affordability.

Product Quality and Safety

Risk assessments and certifications

• What: Systematic risk assessments for Private Brand products and perishables, considering regulatory compliance, physical characteristics, supply chain track records, and facility certification
• Scope: Own operations (stores, distribution centres) and upstream (suppliers)
• Certifications renewed/extended in 2024:
  • ISO 22000:2018 at 17 Biedronka distribution centres and head office
  • FSSC 22000 v.6.0 for soup factory in Poland
  • ISO 9001 for Private Brand development in Portugal
  • HACCP for 2 Pingo Doce central kitchens, 11 Recheio stores, and 7 distribution centres in Portugal
• Target: Maintain 17 certified distribution centres in Poland and certify new centres within 2 years of operation (2024-2026)
• Outcomes: 18,219 internal audits (8% increase vs 2023), 252,851 surface analyses, 89,832 food product analyses

Food product recalls/withdrawals

• What: Three-level recall system based on severity
• Outcomes 2024: 221 total incidents (23.8% decrease vs 2023); only 4 Level I critical recalls (1.8% of total, 33.3% decrease vs 2023)
• Target: Zero Level I recalls attributable to Jerónimo Martins; 100% effective collection when recalls occur

Food safety and hygiene training

• What: Continuous training programmes on HACCP standards, hygiene practices, food safety systems, waste separation, food defence
• Scope: Own operations across all geographies
• Resources: 249,346 training volume hours (2.6% increase vs 2023); 9,727 training courses (17.4% increase)
• Reach: 57,130 employees trained (14.8% increase vs 2023)
  • Portugal: 11,120 employees, 60,328 training hours (60.7% increase)
  • Poland: 25,135 employees, 27,731 training hours (14.6% increase in employees)
  • Colombia: 20,875 employees, 161,287 training hours

Partnerships and support

• What: Memberships in The Consumer Goods Forum, Global Food Safety Initiative, Global G.A.P. (sole Portuguese retailer in International Fruit and Vegetables Committee)
• Scope: Industry collaboration across value chain
• Portugal-specific: Partnerships with Portuguese Directorate-General for Health, participation in APED technical committees on food quality

Product Innovation

Product launches with specific dietary needs

• 2024 launches:
  • 103 gluten-free references (Poland: 15, Portugal: 77, Colombia: 11)
  • 8 lactose-free references
  • 26 vegan/vegetarian references
  • 14 organic references
• Total portfolio: 1,461 gluten-free, 88 lactose-free, 188 vegan/vegetarian, 143 organic products

Nutritional reformulations

• What: Recipe improvements prioritising children's products and high-consumption items
• 2024 scope: 58 food products reformulated
• Quantified impact:
  • 576 tonnes sugar avoided
  • 169 tonnes fats avoided (45 tonnes fat, 125 tonnes saturated fat)
  • 60 tonnes salt avoided
  • 13 tonnes fibre added (6 products)
• By Company:
  • Biedronka: 24 products (15 salt, 7 sugar, 5 fat, 1 saturated fat reductions)
  • Pingo Doce: 13 products
  • Recheio: 3 products
  • Ara: 18 products

Certified ingredients, products and packaging

• What: Promotion of sustainability certifications (FSC®, PEFC, OEKO-TEX Made in Green, organic, WelfairTM animal welfare)
• 2024 performance: 14.2% of Private Brand and perishables sales from certified products (0.8 p.p. increase vs 2023)
  • Biedronka: 16.8%
  • Pingo Doce: 25.7%
  • Ara: 4.2%
• Portfolio: 1,831 certified references (23% increase vs 2023); 556 new certified products launched in 2024
• Target: 15% of sales from certified products by 2026
• Time horizon: 2024-2026

Healthy ageing products (2024-2026)

• What: Private Brand products meeting nutritional/dietary needs for +50 age groups
• Scope: Portugal and Poland
• Time horizon: 2024-2026

Product guarantee extension (Biedronka)

• What: Extension from 2 to 3 years for electric and non-electric non-food products
• Scope: Poland downstream (consumers)
• Time horizon: 2024-2026

Product Affordability

Market research and price management

• What: Market and customer research studies on social/economic conditions, competitor analysis, sales data to maintain price leadership
• Scope: All geographies

Supplier engagement and category management

• What: Procedures ensuring product differentiation through price, quality and safety; continuous portfolio improvement
• Scope: Upstream value chain

Marketing and accessibility initiatives

Biedronka (Poland):

• "Nobody cares about their customers' wallets as much as Biedronka" campaign: 400+ product price reductions
• 4,000+ regular prices maintained despite VAT changes
• 1,300+ stores with butcher/delicatessen service counters
• Moja Biedronka app: 13 million users
• 60 promotional campaigns annually

Pingo Doce (Portugal):

• My Pingo Doce app with exclusive savings tools: "Poupa Shaker", "Clube do Bebé", "Clube do Vinho", loyalty programmes
• 237 Comida Fresca restaurants (40 new openings)

Community Support and Social Impact

Social impact monitoring

• What: Monitoring using Business for Societal Impact (B4SI) model
• Target: Track at least 70% (by value) of annual social support impacts across all Companies (2024-2026)
• Scope: All geographies

Vulnerable populations programmes

• What: Social projects for children, youth and elderly from vulnerable environments
• Target: Directly impact 1 million people per year until 2026
• Scope: All geographies
• Time horizon: Through 2026

Remediation and Grievance Mechanisms

Ethics Committee and reporting channels

• What: Digital whistleblowing platform, Ethics Offices (4 in Portugal, 2 in Poland, 1 in Slovakia)
• Scope: All stakeholders, all geographies
• Principles: Independence, impartiality, integrity, confidentiality, no conflicts of interest
• Additional bodies: Anti-Mobbing/Anti-Discrimination/Sexual Harassment Committee (Poland), Committee for Labour Co-existence (Colombia), Employee Assistance Service (SAC)

Targets related to consumers

Jerónimo Martins has disclosed multiple targets related to managing material impacts on consumers and end-users under ESRS S4-5. These are presented in Chapter 6 'Sustainability commitments', section 6.1 'Commitments 2024-2026'.

Summary Table of Consumer-Related Targets

Additional Context

All targets are internal targets developed by Jerónimo Martins. No science-based or externally validated targets (e.g., SBTi) are mentioned for consumer-related metrics. Targets apply across different geographies (Poland, Portugal, Colombia) and business banners (Biedronka, Pingo Doce, Hebe, etc.). Most targets are intensity-based or percentage-based rather than absolute values. Progress is systematically tracked and reported annually.

Values and Corporate Culture

The way we fulfil our Mission is shaped by our Values and Behaviours. They are the same for our Companies in all countries where we operate:

We raise the bar We are restless and we do not settle. What we do is beyond expectations, we never accept the status quo and we encourage others to do the same. We believe there is always a way to do better and to overcome the most demanding obstacles. This is why we never give up. We are always ready to try and to take calculated risks, without compromising what needs to be done.

We count on each other Together we are stronger. We collaborate and share. We believe each person's development must be encouraged so that we are all able to achieve the most ambitious goals. We work hard to make sure everyone is heard and that we learn from different people and perspectives. We value our achievements and celebrate success.

We believe in doing the right thing What we do is as important as how we do it. We are accountable for our decisions, and we don't lie. We act ethically and with integrity and our long-term decisions take into account our people, our clients, our communities and our shareholders. We treat with dignity and respect those who are part of our business.

Corporate Responsibility Integration

As an intrinsic part of our sense of corporate citizenship, we incorporate, in a clear and committed way, environmental and social concerns in the pursuit of our business. This involves adopting policies and practices that focus on fighting climate change, deforestation and pollution, preserving the environment, biodiversity and natural resources, reducing the use of polluting materials, increasing recycling and the recovery of the waste generated by our activities, as well as promoting respect for and defending human rights and the principles of diversity and inclusion.

The Group establishes long-term relationships that enable shared value creation and the growth and development of the Group's strategic partners, and that ensure the sustainability of the supply chain and innovation that enhances the attractiveness and relevance of our value propositions.

Our commercial strategy has ensured that more than 90% of the Group's food product purchases were made from local suppliers, a trend we have maintained for more than a decade. The proportion of Private Label and perishable products with sustainability certification increased and now represents more than 14% of these categories.

Prevention and detection of corruption and bribery

Jerónimo Martins has established comprehensive policies and mechanisms to prevent and detect corruption and bribery across its operations and value chain.

Anti-Corruption Policy

Approval and scope:

• Approved by the Board of Directors in 2019
• Applicable to all Jerónimo Martins Group Companies and all associates, including management positions and positions based on a term of office, regardless of the nature of their contractual relationship, job position or working country

Key content and principles:

• Establishes acting principles and obligations laid out in the Code of Conduct with regard to honesty and integrity
• Sets rules for preventing unlawful conducts that constitute acts of corruption
• Safeguards against potential conflicts of interest
• Requires associates to immediately report the existence of conflicts of interest and refrain from carrying out any act or making any decision in relation to it
• Establishes that any associate who becomes aware or has justified suspicions of breaches to the Policy should report such situations
• In case of doubt about the existence of a conflict of interest, the Ethics Committee should be consulted
• Zero tolerance for any behaviour involving corruption, influence peddling, receiving or offering undue advantages, or paying or receiving any benefits contrary to the laws in force in each country and Jerónimo Martins's Code of Conduct

Public availability:

• Available on the Company's institutional website

Links to international standards:

• Aligned with the United Nations Global Compact Principle 10: "businesses should work against corruption in all its forms, including extortion and bribery"
• Aligned with United Nations Sustainable Development Goal 16 (Peace, Justice and Strong Institutions)
• Aligned with United Nations Guiding Principles on Business and Human Rights
• Aligned with OECD Guidelines for Multinational Enterprises on Responsible Business Conduct

Monitoring implementation:

• Face-to-face and telematic training sessions are carried out
• Communication instruments containing various information are disseminated, highlighting concrete situations that may constitute internal or external risks for the Company
• In 2024, 24,937 hours of training were provided on this topic (47.1% more than in 2023), reaching 21,953 employees
• Communication campaigns reached 42,477 employees in 2024
• Training provided in two formats: e-learning and advanced training for critical functions
• Training content is periodically reviewed to ensure it is up to date
• Specific target audiences receive specialized training (Human Resources, Quality and Food Safety teams)
• Policy disseminated among suppliers through the Supplier Code of Conduct and Sustainable Sourcing Policy
• Ethics Committee monitors disclosure of and compliance with the Anti-Corruption Policy

Whistleblowing Policy

Key content and principles:

• Establishes the set of rules adopted to receive, record, and handle reports on wrongdoing by employees and other stakeholders concerning any companies that are part of the Jerónimo Martins Group
• Ensures mechanisms for detecting and preventing wrongdoing
• Promotes a culture of transparency, integrity and accountability
• Ensures adoption of ethical, principled and professional behaviour by the Company's employees and managers
• Ensures compliance with EU law, national law and the Jerónimo Martins Group Code of Conduct
• Enables effective risk management
• Ensures confidentiality of the identity of whistleblowers and all information that directly or indirectly enables identification of the whistleblower
• Prohibits retaliation against whistleblowers
• Establishes data protection measures and rights of whistleblowers

Public availability:

• Available on the Company's institutional website

Oversight and implementation:

• Ethics Committee safeguards the confidentiality of contacts sent to its email address
• Ethics Committee provides a digital platform (available at www.jeronimomartins.com and comissaodeetica.jeronimomartins.com) for confidential reporting, anonymously if desired
• Four Ethics Offices in Portugal, two in Poland, and one in Slovakia serve as independent reporting channels
• Ethics Committee and Ethics Offices follow principles of independence, impartiality, integrity, confidentiality and absence of conflicts of interest

Plan for the Prevention of Corruption Risks and Related Infractions (PPRC)

Key content and principles:

• Follows the General Framework for the Prevention of Corruption approved by Decree-Law No. 109-E/2021 of 9 December 2021 (Portugal)
• Identifies and classifies the Company's main and potential corruption risks
• Considers the likelihood and impact of the risks identified
• Lists prevention and mitigation measures for these types of risks
• Annual report on PPRC implementation published in 2024

Public availability:

• Published on the corporate website (initially published in 2022)

Integrity Due Diligence Procedure

Key content and principles:

• Approved in 2023
• Autonomous internal document aimed at assessing risks related to corruption in the supply chain
• Implements an integrity due diligence procedure to identify corruption risks posed by third parties in the value chain

Code of Conduct

Scope:

• Applicable to all employees
• Provided to employees at the moment of admission in any of the Group's Companies

Key content and principles:

• Establishes ethical standards and principles
• Includes provisions on honesty and integrity that are further detailed in the Anti-Corruption Policy
• Commits the Group to adopt trade policies ensuring protection of consumers' rights

Monitoring implementation:

• In 2024, 27,455 employees received training on the Group's Code of Conduct (an increase of 22,204 employees compared to 2023)
• Ethics Committee monitors disclosure of and compliance with the Code of Conduct
• Employees can resort to their hierarchy for guidance about the Code of Conduct or to report any irregularity
• Employee Assistance Service available as an internal channel in each of the countries where the Group operates

Supplier Code of Conduct

Key content and principles:

• Sets forth the ethical standards and principles that suppliers must follow in their business dealings with the Group
• Suppliers must not offer personal gifts or benefits to Jerónimo Martins' employees, except for symbolic gifts up to a pre-defined value

Monitoring implementation:

• Disseminated among suppliers
• Included in contracts
• In global sourcing processes, supplier selection criteria include accepting the Sustainable Sourcing Policy, Code of Conduct for Suppliers and Anti-Corruption Policy

Additional control and oversight mechanisms

Internal Audit:

• Internal Audit Department assesses the quality and effectiveness of internal control and risk management systems
• Results made available monthly to the Internal Control Committee (which reports to the Audit Committee) and to the Group's Managing Committee
• Quarterly reports presented to the Audit Committee
• Audits include verification of operational risks that may be associated with fraud and corruption

Audit Committee:

• Responsible for monitoring the preparation and disclosure of both financial and non-financial information
• Receives quarterly reports on internal audit findings

Risk assessment:

• Annual risk management process involves approximately 70 managers from Companies and countries where the Group operates
• Quarterly reviews ensure alignment with critical areas and active monitoring of emerging risks
• Topics considered throughout risk assessments include aspects that could be associated with risks of corruption, reputation, affected communities and human rights
• Risk assessment in the supply chain assessed through social audits whose criteria include corruption issues

Incidents of corruption or bribery

Disclosure statement

Jerónimo Martins has addressed ESRS G1-4 requirements regarding incidents of corruption or bribery in its 2024 sustainability statement.

In the ESRS reporting framework table (section 7.1), the company states:

"This disclosure requirement was not identified as material, nonetheless it is partially reported. For information on these matters, see the reports on indicators GRI 2-27 e GRI 206-1."

The company further notes:

"We are improving our reporting processes in order to respond to socio-economic compliance indicators."

Anti-corruption framework

The company maintains comprehensive anti-corruption policies and procedures:

• Anti-Corruption Policy approved in 2019, applicable to all Group companies and associates
• Whistleblowing Policy with dedicated digital platform for confidential reporting
• Ethics Committee with independent oversight and dedicated website (comissaodeetica.jeronimomartins.com)
• Ethics Offices: 4 in Portugal, 2 in Poland, 1 in Slovakia
• Plan for the Prevention of Corruption Risks publicly available on corporate website
• Integrity Due Diligence Procedure approved in 2023 for supply chain corruption risk assessment

Training and communication

In 2024:

• 21,953 employees trained on the Anti-Corruption Policy (representing a significant increase of 6,366 employees compared to 2023)
• 24,937 training hours provided on anti-corruption topics (47.1% increase vs 2023)
• 42,477 employees reached through communication campaigns
• Training included e-learning modules and advanced training for critical functions

Resolution mechanisms

Complaints received through various channels in 2024:

• 3,580 labour-related complaints total
• 100% analysed
• 85.4% closed
• 51.9% required remedy actions

Of these, 136 complaints involved discrimination including harassment, with:

• 100% analysed
• 53.7% required remedy actions
• 92.6% closed

No incidents of forced labour, human trafficking or child labour were identified.

Legal and compliance matters

Regarding non-compliance with environmental laws and regulations, the company reports:

"there were no significant fines*" (*defined as monetary amounts ≥ €45,000)

For anti-competitive behaviour matters, the company refers to Chapter 3 Financial Statements, note 23 on contingencies for legal proceedings exceeding €5 million pending resolution.

Data architecture development

The company explicitly states it is developing architecture to report:

• Potential total amount of fines
• Pecuniary penalties
• Compensation for damages

related to discrimination and other compliance cases, committing to report these indicators in future periods.

Note

While the company has not provided specific metrics on confirmed corruption or bribery incidents, convictions, or related fines for 2024 under G1-4, it has disclosed comprehensive anti-corruption governance, training metrics, and complaint resolution data. The company acknowledges this disclosure requirement and states it is improving reporting processes for socio-economic compliance indicators.

Political influence and lobbying activities

Political engagement approach

This disclosure requirement was not identified as material.

Ethical standards and guidelines

Jerónimo Martins Group companies do not support political parties or their representatives, nor do they contribute financially to groups that may support party interests. See Code of Conduct available on our website.

Political contributions

The Group does not make political contributions: €0

Trade association memberships

No specific trade association membership data disclosed.

Lobbying expenditure

No lobbying expenditure data disclosed.

Payment practices

Payment terms and practices by country

Jerónimo Martins operates payment practices across its food distribution operations in Portugal, Poland and Colombia, which account for more than 99% of the Group's sales. Payment terms are established in General Supply Agreements and vary depending on type and size of supplier and/or category of products supplied.

2024 Payment terms distribution:

Supplier responsibilities breakdown (2024)

As of December 31, 2024, existing liabilities under confirming protocols totalled €882 million, representing 17.8% of total inventories suppliers, with no amounts beyond payment terms agreed with suppliers.

Supplier finance arrangements (Confirming/Reverse Factoring)

Supplier finance arrangements enable suppliers to anticipate receipt of their invoices by approximately 7 days at competitive cost. By end of 2024, these programmes were in place in:

• Portugal: Over 200 suppliers
• Poland: Over 200 suppliers
• Colombia: Over 200 suppliers

These arrangements do not expose the Group to additional credit risk, nor provide significant additional benefits in payment terms. Amounts under these protocols continue to be classified as trade credits from suppliers.

Special programmes for smaller suppliers

Poland (Biedronka):

• Maximum 21-day payment terms for producers with annual turnover < 100 million złoty (approximately €24 million)
• 2024: Approximately 260 suppliers benefitted (60 more than 2023)
• Programme in place since 2020

Portugal:

Programme 1 - CAP members:

• Average 10-day payment (vs. 30 days legal requirement)
• No financial costs to producer
• Target: Small and medium-sized producers that are Confederation of Portuguese Farmers (CAP) members
• Since 2012: Around 375 suppliers benefitted

Programme 2 - IAPMEI certified SMEs:

• Maximum 30-day payment terms
• Target: Portuguese SMEs certified by IAPMEI (Public Agency for Competitiveness and Innovation)
• 2024: All Pingo Doce and Recheio's suppliers identified as certified Portuguese SMEs benefitted

Colombia (Ara):

• "Plazos Justos" (Fair Deadlines) programme
• Payment in less than 45 days for micro, small and medium-sized enterprises
• 2024: Approximately 1,170 suppliers participated

Legal proceedings

During 2024, Jerónimo Martins companies have not been involved in legal proceedings related to late payments to trade suppliers.

Payment processing tools

In Portugal, Poland and Colombia, specific tools ensure efficient invoice processing:

• Electronic communication (EDI) for receiving suppliers' invoices and related documents
• Web portal where suppliers access information including list of invoices to be paid, with notifications for required clarifications or actions

Bank guarantees related to suppliers (2024)