Kingspan

Reference: page 140

The Board of Directors holds overall responsibility for the Group's internal control system, with day-to-day implementation delegated to executive management. The Audit & Compliance Committee, a Board sub-committee, monitors the effectiveness of risk management and internal controls, including management of material IROs. A CSRD working group of Group management and senior managers coordinates CSRD implementation, with progress on the DMA and IRO scoring reported to the CFO quarterly and to the Audit & Compliance Committee at every meeting. The CEO oversees sustainability matters and their integration into strategy, risk management and business plans, supported by the Chief Sustainability, Digital and Marketing Officer (who leads Planet Passionate and reports to the CEO) and the Group Head of Leadership and Development (who leads People Passionate). In 2025 the Board comprised four executive and seven non-executive members; Éimear Moloney serves as workforce engagement iNED and Eavan Saunders as CSR engagement iNED.

Reference: page 141

The Board, CEO and executive directors are informed on sustainability matters through internal reporting structures, with CSRD compliance updates provided at each of the four Audit & Compliance Committee meetings held during the year ended 31 December 2025. Management teams across the businesses assess sustainability progress and escalate material IROs through monthly management meetings. The Chief Sustainability, Digital and Marketing Officer gives the Board periodic updates on Planet Passionate progress, and the Board reviews material sustainability topics, including climate initiatives, resource efficiency and employee wellbeing, as set out in the Statement's SBM-3 section, incorporating them into Group decision-making. The Board also weighs sustainability IROs when overseeing strategy and approving major transactions, balancing potential fit with sustainability goals and short-term risk against long-term success factors.

Reference: page 141

Short-term incentives include an annual bonus with a Health & Safety metric (10% of base salary, 6.7% of total maximum bonus opportunity) and a customer Net Promoter Score metric (10% of base salary); together these represent 13.3% of the total maximum bonus opportunity. The long-term incentive plan allocates 15% of the vesting criteria for the annual performance share plan award to sustainability targets, focused on seven Planet Passionate environmental objectives such as reducing GHG emissions, increasing renewable energy use and rainwater harvesting, aligned with the Group's E1-4 GHG emission reduction targets. The Board and Remuneration Committee review these sustainability-linked incentives annually against the Group's evolving ESG priorities and long-term strategy; further detail on remuneration principles sits in the Report of the Remuneration Committee.

Reference: page 141

The Statement maps its due diligence disclosures against the core elements set out in ESRS guidance: embedding due diligence in governance, strategy and business model (General, page 144); engaging with affected stakeholders in all key steps (General, page 143); identifying and assessing adverse impacts (Environmental/Social, pages 144 and 194); taking actions to address those impacts (Environmental/Social, pages 168 and 196); and tracking the effectiveness of these efforts and communicating (Social, page 198). Executive director remuneration principles are set out separately in the Report of the Remuneration Committee.

Reference: page 142

Risk management for sustainability reporting is integrated across the businesses, with each business responsible for identifying and managing sustainability-related risks under the oversight of senior management, executive directors and the Audit & Compliance Committee. Sustainability risks are identified through monthly cross-functional business meetings and an annual risk review conducted by Internal Audit & Compliance, with findings submitted to the Audit & Compliance Committee and folded into the annual strategic review. To ensure data integrity, the Group applies standardised reporting procedures, cross-functional data reviews and oversight mechanisms to mitigate estimation errors and data gaps. Planet Passionate data is collated and reviewed at Group level by the Group Sustainability team and separately reviewed by Internal Audit & Compliance for accuracy, reliability and alignment with reporting requirements.

Reference: page 142

The Group's mission is to accelerate a net zero emissions built environment, pursued through four strategic pillars: Innovation, Planet Passionate, Completing the Envelope and Global. Its two global operating segments, Insulated Building Envelopes and Advnsys, offer complementary building envelope solutions across new-build and refurbishment markets, manufactured across 278 sites and sourcing key raw materials (metals, chemicals, mineral fibre, wood) from supply chain partners. Core product categories, insulated panels, insulation boards, roofing and waterproofing solutions, data centre infrastructure and lighting and ventilation solutions, serve retail, infrastructure, manufacturing and residential customers, distributed through direct sales and distribution channels. Downstream, the Group works with contractors, architects, developers, engineers and building owners. Total headcount and country breakdowns are reported under S1-6; segment revenue is in Note 2 of the Financial Statements.

Reference: page 143

The Group defines stakeholders as individuals or groups whose interests are affected or could be affected by its activities and products, and identifies employees, shareholders/investors, financial institutions, suppliers, customers and end-users, regulatory bodies, industry associations and community organisations/NGOs as key stakeholder groups. Engagement occurs through direct meetings, surveys, industry forums and working groups, aimed at understanding stakeholder views, needs and expectations. Stakeholder engagement is a critical input to the Group's ongoing due diligence and DMA processes (see IRO-1) and directly informs decisions on sustainability initiatives, resource efficiency measures and employee wellbeing, helping the business model stay adaptive to evolving stakeholder expectations and market dynamics.

Reference: page 144

Following the Group's decision to avail of the Quick Fix full topical disclosure deferral, the presentation of material IROs changed in 2025: IROs for the deferred topics, E4 Biodiversity and ecosystems, S2 Workers in the value chain, S3 Affected communities and S4 Consumers and end-users, are centralised in this ESRS 2 SBM-3 section, while material IROs for E1, E2, E3, E5, S1 and G1 continue to be described within their own topical sections alongside the associated policies, actions, targets and metrics. For E4, identified IROs include a negative actual impact from climate change as a driver of biodiversity degradation (own operations) and negative actual impacts from upstream pressures on biodiversity; for S2, S3 and S4 the material IROs relate to supply-chain human rights and ethical sourcing, potential negative impacts on communities connected to suppliers and customers, and product safety, quality and marketing integrity respectively. Year-on-year changes for the deferred topics are described in this section; changes for other topics are discussed in their topical disclosures.

Reference: page 148

The Group completed its first DMA in 2024 with internal and external stakeholders, covering impact materiality (effects on society and environment) and financial materiality (effects on the Group's performance) across short, medium and long-term horizons. The methodology followed five steps: scoping (review of operational segments, upstream/downstream activities, geography and key suppliers); identification (desktop research, peer benchmarking, internal and external expert input, each IRO mapped to ESRS topical standards, with impacts scored on severity/likelihood and risks/opportunities scored on financial thresholds); engagement (over 50 stakeholders including executives, customers, employees, NGOs and regulators, via surveys and interviews); consolidation (management validation); and reporting (material IROs identified across all ten ESRS topics). In 2025 the Group built on the 2024 DMA through targeted workshops with internal subject-matter experts to reassess the prior-year IRO universe, cross-check grievance-mechanism inputs and factor in acquisitions, peer reporting and regulatory developments; no material changes were made to the methodology itself.

Reference: page 151

The Group's DMA process (IRO-1) is the foundation for determining which information is material and included in the Statement. Appendix 1 lists all ESRS 2 and topical-standard disclosure requirements material to the Group, showing where each is addressed and, where information sits outside the Statement, incorporating it by reference to sections such as Our Business Model and Strategy, the Financial Statements or the Report of the Remuneration Committee. Appendix 4 lists the data points that derive from other EU legislation (per ESRS 2 Appendix B), showing where each can be found and which are assessed as not relevant, for example SBM-1's fossil fuel, chemical production, controversial weapons and tobacco cultivation involvement indicators, which are all marked not applicable to the Group.

Reference: page 163

To align the business model with a 1.5°C future and net zero carbon by 2050, the Group developed a transition plan integrated into its strategy, R&D investment, products and business model, approved by the CEO as the most senior person responsible for sustainability. Since the 2020 base year, the Group has cut Scope 1 and 2 GHG emissions by 70.3% and Scope 3 emissions by 24%, with Scope 1 and 2 now under 4% of total GHG footprint. Resilience actions cited include a Green Finance Framework for green bonds and loans, redeployment/upgrade of assets (over 400 decarbonisation projects since 2020), a product-mix shift toward lower-embodied-carbon solutions, and workforce reskilling. The Group states it invested no capex in coal, oil or gas-related activities, is not excluded from EU Paris-aligned benchmarks, and assessed it has no locked-in GHG emissions jeopardising its targets. Specific capex/opex allocations to the plan are withheld as commercially sensitive (page 139), though the Group funds it through equity and debt including a green revolving credit facility and green private placement notes.

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 149-150). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group used a two-pronged approach. Quantitatively, an external tool covering own operations and key suppliers examined nine physical hazards (flooding, wildfire, temperature extremes, water stress, tropical cyclone, drought, landslides) across 2020-2100 under four scenarios mixing SSPs and RCPs: RCP 8.5-SSP5, RCP 7.0-SSP3, RCP 4.5-SSP2 and RCP 2.6-SSP1 (the first is a high-emission scenario; none is explicitly named as a 1.5°C-aligned scenario such as IEA NZE 2050). Physical risk financial impact was not material in lower RCP-SSP scenarios; five transition risk types (carbon pricing, litigation, new technology, reputational damage, market) were examined across the same scenarios, with carbon-pricing exposure material only in the low (RCP 2.6-SSP1) scenario from the 2090s. Qualitatively, the Group used SSP1, SSP2 and SSP5 with RCP targets of 1.9, 3.4 and 6.0 w/m2 to model customer demand where quantitative data was unavailable. The analysis is also cross-referenced under E1-2 (2025 ESRS numbering).

Back-filled from ESRS 2 SBM-3 and the E1 business-model-resilience discussion in the FY2025 report (pages 150 and 162-163). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Based on its recently updated resilience analysis, combining quantitative and qualitative scenario work with internal building-materials expertise, the Group concluded its business model and strategy are resilient across all SSPs examined, including the worst-case SSP3 (lower demand for sustainable products), because insulating buildings is mandated in all scenarios. It states it did not identify key assets or activities incompatible with the transition to a climate-neutral economy, and that critical Financial Statement climate assumptions are largely compatible with the scenarios, though impairment testing is broader in scope. Adaptive capacity is illustrated through four levers: a Green Finance Framework securing capital access; asset redeployment/upgrade (over 400 decarbonisation projects since 2020); a product-mix shift toward lower-embodied-carbon solutions informed by scenario analysis; and workforce reskilling under the Group's strategic pillars. The Group will continue refining planning as demand-forecasting tools improve.

Reference: page 169

The Group's Environmental Policy contains a dedicated Climate Change Section (CCS) to manage, prevent, mitigate and remediate actual and potential climate impacts and to address related risks and opportunities, covering own operations and the upstream value chain. The CCS addresses climate change mitigation, adaptation, energy efficiency and renewable energy generation, and states alignment with the Paris Agreement; stakeholder views gathered through the DMA process informed its content. Managing directors (MDs) are responsible for implementation, and monitoring is carried out through the Planet Passionate programme, which sets the targets designed to help meet the policy's objectives. The CCS is published on the Group's website and made available to stakeholders responsible for implementation.

Reference: page 163

Scope 1 and 2 mitigation is pursued through five decarbonisation levers: process improvement and electrification (18 projects completed in 2025, ~2,234 tCO2e/year saved, 54 more planned to 2030 for ~53,824 tCO2e/year); onsite renewable energy generation (18 projects completed, ~150 tCO2e/year, 75 more planned including 17 significant projects for ~6,751 tCO2e/year); energy efficiency (over 50 projects completed, ~1,393 tCO2e/year, 73 more planned for ~3,518 tCO2e/year, plus ISO 50001 certification for sites over 5GWh/year, 50% certified by year-end); renewable energy contracts (21 projects completed, ~5,767 tCO2e/year, 13 more planned for ~3,035 tCO2e/year); and lower-GWP raw materials (scope 1 process-related emissions cut 96% versus 2020, ~1,963 tCO2e saved in 2025, ~3,000 tCO2e/year more planned). Scope 3 mitigation (90.3% of which sits in Category 1 purchased goods and services) uses three levers: data collection and reporting (over 40% of Category 1 emissions now calculated using primary data, 79% using physical rather than monetary emission factors); supplier engagement (over 63% of Category 1 emissions covered, all key chemical suppliers engaged, a 2025 Supplier Forum, four new MOUs with lower-carbon steel suppliers); and development of lower-impact products (35 lower-embodied-carbon products to date, 18 LEC products launched in 2025).

Reference: page 163

The Group has three SBTi-approved (July 2025), 1.5°C-aligned targets from a 2020 base year: a 65% absolute reduction in Scope 1 and 2 GHG emissions by 2030 (base year 882,481 tCO2e; 2025 emissions 261,793 tCO2e; 70.3% progress to date), a 42% absolute reduction in Scope 3 emissions by 2030 covering purchased goods and services, fuel and energy-related activities, use of sold products and end-of-life treatment (base year 9,030,178 tCO2e; 2025 emissions 6,869,845 tCO2e; 24% progress), and a 15% reduction in the carbon intensity of key raw materials by 2030 (base year 2.7361 tCO2e/t; 2025 figure 2.6257 tCO2e/t; 4.0% progress). All three base years were recalculated for structural changes and methodology improvements, detailed in Appendix 7. Targets are monitored monthly (Target 1) or quarterly and are tied to the decarbonisation levers described under E1-3; the Scope 3 targets are explicitly dependent on the pace of decarbonisation by key raw-material suppliers in the metals, chemicals and mineral fibre industries.

Reference: page 170

Total energy consumption was 2,640,702 MWh in 2025 (2024: 2,538,263 MWh), of which 37% came from fossil sources (2024: 41%) and 63% from renewable sources (2024: 59%). Fossil energy fell to 967,524 MWh from 1,030,361 MWh, while renewable energy rose to 1,673,178 MWh from 1,507,902 MWh, including 1,140,905 MWh of renewable fuel and 492,050 MWh of purchased renewable electricity/heat/steam/cooling. Total energy production was 837,433 MWh (2024: 815,385 MWh), almost entirely renewable (777,040 MWh). Energy intensity was 287 MWh per €m of net revenue in 2025 (2024: 295), against total net revenue of €9,199m; the Group treats its entire revenue base as falling within high climate impact sectors under Commission Delegated Regulation (EU) 2022/1288.

Reference: page 171

On an ESRS-aligned basis, gross Scope 1 emissions were 239,049 tCO2e in 2025 (2024: 228,086 tCO2e, +4.8%) and gross market-based Scope 2 emissions were 20,560 tCO2e (2024: 99,930 tCO2e, -79.4%), giving Scope 1 and 2 combined of 259,609 tCO2e. Scope 3 emissions were 7,299,427 tCO2e (2024: 6,869,309 tCO2e, +6.3%), of which Category 1 purchased goods and services was the largest component at 6,590,842 tCO2e. Total market-based GHG emissions were 7,559,036 tCO2e (2024: 7,197,325 tCO2e, +5.0%); total location-based emissions were 7,715,231 tCO2e (2024: 7,308,919 tCO2e, +5.6%). On a GHG Protocol-aligned basis (outside CSRD assurance scope), Scope 1 and 2 market-based emissions have fallen from an 882,481 tCO2e 2020 base year to 261,793 tCO2e in 2025. GHG figures cover CO2, CH4, N2O and HFCs; PFCs, SF6 and NF3 are excluded as not associated with the Group's inputs.

Reference: page 172

The Group did not purchase carbon credits from the voluntary market during 2025 and did not generate or apply GHG removals or storage from projects in its own operations or value chain. It states it does not procure carbon credits to count toward its carbon targets, focusing instead on decarbonisation within operations and the value chain; only after achieving its long-term science-based target does it intend to neutralise residual hard-to-abate emissions using high-quality, additional and permanent carbon credits, noting that nature-based solutions such as reforestation cannot guarantee the permanence required.

Reference: page 172

Since January 2023, the Group has applied an internal carbon charge of €70/tonne across all manufacturing, assembly and R&D sites for each energy-related tCO2e emitted, included in business P&L accounts and affecting business profitability and management remuneration. The charge covers Scope 1 and 2 emissions (excluding process and biogenic emissions); in 2025 it covered 226,464 tCO2e of Scope 1 emissions (95% of the total; 2024: 213,846 tCO2e, 94%) and 20,560 tCO2e of Scope 2 market-based emissions (100%; 2024: 99,930 tCO2e, 100%). The price was set through review of carbon pricing guidance, existing mechanisms and rates including the EU ETS trajectory, modelled against the Group's footprint and decarbonisation projects, and is credited with helping incentivise renewable energy contract conversions and forklift fleet decarbonisation.

Reference: page 174

The Pollution Section (PS) of the Group's Environmental Policy sets objectives for managing material pollution-related IROs, including pollution to air, water and soil (covering microplastics and pollution of living organisms and food resources) within operations. Because no material IROs related to substances of concern (SoC) or substances of very high concern (SVHC) were identified within operations, management of substitution/minimisation of such substances and incident/emergency prevention are not addressed in the PS, reflecting the topic's complexity and unique regional requirements. MDs oversee implementation, and the policy is published on the Group's website and made available to stakeholders.

Reference: page 174

Because pollution (including both sub-topics assessed) was not deemed material for the Group's own operations at Group level, no group-wide pollution actions or resources have been initiated. A consistent baseline is instead maintained through site-level environmental management systems aligned with ISO 14001, with 47% of manufacturing sites certified at end-2025 (2024: 50%). Pollution-related impacts and risks are addressed locally, with sites operating under environmental permits where required and monitoring and reporting air emissions, water discharges and potential soil contamination against applicable thresholds; no material fines were reported in 2025. The Group states it will continue evaluating internal monitoring processes and improving data quality on value-chain partners' pollution-related impacts.

Reference: page 174

The Group has not set a group-wide pollution target, on the basis that pollution to air, water and soil and pollution from substances of concern were not deemed material for its own operations at Group level following DMA assessment. Progress is instead tracked through ISO 14001 certification coverage across manufacturing sites (47% at end-2025, down from 50% in 2024) as a proxy for environmental management system implementation, alongside monitoring of environmental permit compliance and breach incidents (none material in 2025).

Reference: page 177

A dedicated Water Section (WS) within the Group's Environmental Policy manages, prevents, mitigates and remediates actual and potential water-related impacts and addresses risks and opportunities, covering all manufacturing, R&D and assembly facilities including those in water-stressed areas. The WS addresses water management at "priority sites", identified by water withdrawal (dependency), water consumption (impact) and water-stress status; it does not explicitly address water treatment and use/sourcing, product design or consumption-reduction commitments, since the approach depends on local context at priority sites. The SHREDD Policy addresses material upstream water impacts; the WS excludes sustainable oceans and seas, deemed not material. MDs oversee implementation, monitored through Planet Passionate; the policy is published on the Group's website.

Reference: page 177

Because impacts and dependency on water vary by site and local context, the Group prioritises resources at priority sites identified using water-stress exposure and dependency criteria (see the water heatmap on page 175) rather than a single group-wide reduction target. No priority sites were identified in 2025, so no specific group-level water actions were required that year. Voluntarily, as part of Planet Passionate the Group pursues a rainwater-harvesting action across all manufacturing, assembly and R&D sites, contributing toward reducing withdrawal from third-party providers and groundwater and easing pressure on local aquifers.

Reference: page 177

The Group has not set a target for its material water-related IROs in 2025, on the basis that a group-wide absolute-reduction target is neither efficient nor strategically relevant given how impacts and dependency vary by site; effectiveness of the Water Section policy is instead tracked through internal environmental data collection and reporting. Voluntarily, under Planet Passionate the Group has set a target to harvest 100 million litres of rainwater annually by 2030 across all manufacturing, assembly and R&D sites; this target was not designed to address the Group's material water impacts or risks but supports local water-system resilience.

Reference: page 180

The Circular Economy Section (CES) of the Group's Environmental Policy integrates circularity into environmental strategy and product development, outlining how the Group manages, prevents and mitigates actual and potential material impacts and addresses risks and opportunities. It sets objectives to increase use of secondary and responsibly sourced renewable raw materials and to follow the waste hierarchy for manufacturing waste, drawing on feedback from internal and external stakeholders (regulators, shareholders, customers, employees, industry associations, community organisations) gathered through the DMA. The CES directly informs the targets and actions run through the Planet Passionate programme; MDs are responsible for implementation, and the policy is published on the Group's website and shared with relevant stakeholders.

Reference: page 181

Actions run through the LIFECycle Product Circularity Framework across four themes. Input materials: in 2025 the Group increased supplier engagement to obtain product-specific recycled-content data, using approximately 1.05 million tonnes of recycled and renewable raw materials (against the 1.5 million tonne 2030 target). Factory processes: over 32 landfill-diversion projects were completed, including a return-to-supplier scheme at the Isometall site and a remanufacture partnership for insulation waste, cutting municipal waste to landfill by over 67% since 2020. Extended life models and cycling: 10 product takeback and recycling schemes are now facilitated in total, including three new schemes launched in 2025 (e.g. Joris Ide's Next Circle, the Reuse Panel scheme recovering over 30,000 m² of raised access floor products, and the BelterTech recycling scheme at the Deland, USA site). Lean Design for Circularity embeds durability, disassembly, recyclability and repairability considerations into product development, including a sustainable design review process at IKON.

Reference: page 181

The Group has three voluntary circular economy targets, all set for 2030 covering Group manufacturing, assembly and R&D sites: to use 1.5 million tonnes of recycled and renewable raw materials annually (progress to date: 1.05 million tonnes); to facilitate 20 product takeback and recycling schemes (progress: 10 schemes); and to achieve zero company waste to landfill, a 90% reduction from a 2020 baseline (progress: -6%, with the 2025 increase attributed to now-resolved legacy waste management from a 2024 acquisition). Targets are monitored quarterly by the Group Sustainability team and are linked to the LIFECycle framework's input materials, factory processes, and extended life models/cycling themes.

Reference: page 185

Across the Group's 278 manufacturing sites, total weight of technical materials used was 3,001,322 tonnes in 2025 (2024: 3,634,958 tonnes, restated for a corrected 347,266 tonne data input error), and total weight of biological materials was 678,387 tonnes (2024: 647,406 tonnes). Weight of secondary reused or recycled content rose to 395,475 tonnes (2024: 316,341 tonnes), or 13.2% of total inflows (2024: 8.7%). 97% of biological raw materials were certified as responsibly sourced by PEFC and FSC (2024: 97%). Packaging materials are excluded as not a material resource inflow; raw material data is collated monthly with the balance estimated from spend.

Reference: page 185

The Group's Key Product Groups (insulation solutions, insulated panels, structural steel products, facades, ceiling systems, raised access floors, daylighting solutions) show expected durabilities of 25-60 years depending on category, with recyclable content ranging from 0% to 100% depending on product family (page 187). Durability is designed in: insulation and insulated panel products have reference service lives up to 50 years. Circular design principles considered include disassembly (modular products such as insulated panels and raised access floor products can be safely disassembled for reuse or recycling) and recyclability (single-material products such as steel, aluminium or polycarbonate are generally recyclable by the relevant industry; insulated panels require manual separation of metal facer from insulation core at reclamation plants). Repairability is not reported as a metric, as no internationally recognised standards exist for classifying building-product repairability. Packaging is excluded from the E5-5 reporting boundary as not a material resource outflow.

Reference: page 187

Waste data is collected monthly at site level across all manufacturing, assembly and R&D sites under the Group's Environmental Data Reporting Procedure, covering both hazardous and non-hazardous streams and treatment methods. Total waste generated was 185,136 tonnes in 2025 (2024: 181,176 tonnes), of which 131,723 tonnes (71%) was diverted from disposal (2024: 118,354 tonnes, 65%) and 53,413 tonnes was directed to disposal (2024: 62,822 tonnes). Total non-recycled waste fell to 54,982 tonnes from 62,993 tonnes, and the total percentage of non-recycled waste dropped to 30% from 35%. Hazardous waste generated rose to 10,214 tonnes from 8,995 tonnes. The 2024 non-hazardous landfill figure was restated from 11,936 to 21,634 tonnes to correct an omission of stored waste related to a 2024 acquisition. Key waste streams, covering 91% of total waste by volume, are metals, wood and wood production waste, insulation materials, municipal/construction/demolition waste, chemicals, and paper and cardboard.

Reference: page 195

Policies apply to the Group, its subsidiaries, joint ventures and their directors, officers and employees across all business locations, published on the Group's website. Key policies include the Code of Conduct (responsible behaviour and legal compliance), the People & Organisation Policy (global principles for the People Passionate programme covering recruitment, onboarding, training, career progression, upskilling and leadership development), the Health & Safety Policy (implementing ISO 45001 to prevent injury and ill health), the Human Rights Policy (aligned with ILO conventions and UN principles, with breach-reporting mechanisms), and the Inclusion & Diversity Policy (equal opportunities and a zero-tolerance approach to discrimination, supported by the Board Diversity Policy). MDs are responsible for implementation across these policies, with anonymous reporting available through a global confidential independent hotline.

Reference: page 196

A Global Steering Group representing all businesses contributes to the design and implementation of the People Passionate programme and meets quarterly. In 2025 the Group continued collaborating with employee representatives to establish a European Works Council (EWC), representing over 13,200 Group employees across 24 countries, as a platform for engagement on business strategy, development, employment matters, investments and transnational issues. Engagement is otherwise managed locally, with survey frequency depending on the type of interaction and supported by a network of communication champions in each business; effectiveness is assessed through employee surveys and regular review meetings, with MDs responsible for ensuring active engagement. Insights from the People Passionate programme's first phase are used to identify workforce groups potentially vulnerable to impacts or marginalisation.

Reference: page 196

Employees are encouraged to report concerns directly to their line manager; where this is not comfortable or possible, concerns can be raised with Group legal teams or through EthicsPoint, a confidential and anonymous reporting tool covering misconduct in the workplace. All complaints, whether raised locally or via EthicsPoint, are investigated, though not all are substantiated. Further detail on how the anonymous, independently run hotline is protected against retaliation is provided under G1-1.

Reference: page 196

The People Passionate programme, endorsed by the CEO, runs its first phase from 2024-2026 and addresses workforce engagement, wellbeing, career development, health and safety, and ethical labour practices; a second phase (2027-2029) will be shaped by a comprehensive 2026 employee feedback exercise. Learning and development programmes span graduates (Yours to Shape), early career staff (Explore, Developing Talent), frontline managers (Ignite), team managers (Accelerate), senior leaders (Evolve, PEAK) and executives (an INSEAD partnership), plus an Explore Pilot and a Safety Leadership Programme piloted in 2025. On occupational health and safety, ISO 45001 certification was extended to 13 additional manufacturing sites in 2025, supported by a new Health & Safety Steering Committee, a training hub, quarterly regional virtual conferences and a health and safety metric added to executive bonus targets. On human rights, the Group refreshed its risk assessment with an external consultant, screening forced-labour and child-labour risk using the Global Slavery Index and UNICEF's Children's Rights in the Workplace indices, and concluded residual risk within its operations is not significant.

Reference: page 199

The People Passionate programme's first phase (2024-2026) does not carry specific quantitative targets or a base year; the Group tracks effectiveness through qualitative assessments such as surveys, feedback and management reviews. A comprehensive employee feedback exercise planned for 2026 will inform the development of measurable targets and baselines for the second phase (2027-2029), intended to keep the programme responsive to material own-workforce IROs.

Reference: page 199

Total employees at end-2025 were 29,081 (22% female, 78% male; 2024: 26,337), of which 27,450 were permanent and 1,480 temporary, plus 151 non-guaranteed-hours employees. Average number of employees was 27,955 (2024: 25,401); total leavers were 5,752 (2024: 4,520), giving a turnover rate of 20.6% (2024: 17.8%). Employee data reflects businesses controlled by the Group as of end-2024 plus estimates for 2025 acquisitions, defining top management as those one or two levels below the CEO. Countries representing over 10% of total employees are Poland (3,819), the United Kingdom (3,269) and the United States (2,940).

Reference: page 201

71% of the Group's total employees within the European Economic Area (EEA) were covered by collective bargaining agreements in 2025 (2024: 71%), reported for EEA countries only in line with the Quick Fix deferral for non-EEA data collection. The heatmap breakdown by coverage band for the EEA country representing over 10% of total employees (Poland) is disclosed for both collective bargaining coverage and social dialogue/workplace representation, for 2025 and 2024.

Reference: page 200

In top management (one to two levels below CEO, including MDs and direct reports), the male/female split was 195/41 in 2025 (83%/17%), up from 179/31 in 2024 (85%/15%). By age band, the Group had 4,929 employees under 30 (2024: 4,540), 15,571 aged 30-50 (2024: 14,206) and 8,581 over 50 (2024: 7,591). The Group states its current methodology does not support a gender breakdown of employee numbers at country level, but that it is developing data collection processes to provide this in future reporting cycles.

Reference: page 201

All employees are paid at least the national minimum wage applicable in their jurisdiction, as specified by national legislation or collective agreements; the adequate wage indicator compares the lowest wage paid (basic wage plus fixed additional payments) against local minimum-wage market data. The People & Organisation Policy commits to fair compensation, including overtime, in line with local laws, contracts or union agreements, with local wage standards monitored regularly for compliance. This approach is framed as mitigating salient human rights risks around wages and benefits under the Human Rights Policy, and the Group states it assesses global compensation packages against market benchmarks beyond minimum legal requirements.

Reference: page 202

The health and safety management system covers 88% of the workforce (2024: 84%). There was 1 fatality in 2024 and 0 in 2025. Total recordable work-related accidents (employees and non-employees combined) were 706 in 2025 (2024: 523), split as 506 employee and 200 non-employee accidents (2025 marks the first year non-employee accidents are disaggregated, so 2024 is not available on that basis). The total recordable rate of work-related accidents was 11.5 per million hours worked (2024: 12.9). In 2025 the Group changed its reporting boundary so that the coverage rate and total recordable rate metrics are based on employees with a contract of employment only, while total accidents and fatalities continue to include non-employees; as non-employee headcount data is unavailable, prior-year figures for the affected metrics have not been restated. Although the 2025 DMA found occupational health and safety risks and opportunities not material, the Group continues to report these metrics voluntarily.

Reference: page 203

Complaints of incidents of discrimination, including harassment, rose to 74 in 2025 (2024: 36); complaints filed through channels for people to raise concerns (excluding discrimination/harassment) were 138 (2024: 147). No complaints were filed to National Contact Points for OECD Multinational Enterprises in either year, no fines, penalties or compensation for discrimination-related damages were incurred, and no severe human rights incidents (including non-respect of UN Guiding Principles or OECD Guidelines) or related fines/penalties were recorded in either year. Data is gathered using the methodologies described under S1-6 (line-manager reporting) and G1-1 (EthicsPoint); not all complaints raised are substantiated, but all are investigated.

Reference: page 210

The Group's policies for managing business-conduct IROs, with ultimate responsibility held by business MDs, include the Code of Conduct, the Anti-Fraud, Bribery & Corruption Policy and the Conflicts of Interest Policy, all publicly available. The Code of Conduct sets out responsible, legally compliant behaviour, is supported by mandatory training for all staff including new joiners, and incorporates the Group's confidential independent hotline policy, with retaliation or reprisals explicitly prohibited; the hotline is operated through EthicsPoint, with reports overseen by the Group Head of Internal Audit & Compliance and the Company Secretary and outcomes presented to the Audit & Compliance Committee. The Anti-Fraud, Bribery & Corruption Policy is underpinned by the internal Group Accounting Manual, and identifies IT users as the highest corruption/bribery risk group. The Conflicts of Interest Policy is Board-owned. Corporate culture is further shaped by the People Passionate initiative and People & Organisation Policy; the Group states it has no animal welfare policies, as the topic is not material to it.

Reference: page 211

The Group builds long-term supplier relationships as part of its Planet Passionate strategic pillar, but states it does not have a specific policy to prevent late payments to SMEs, while committing to fair and timely payments generally. The Code of Conduct sets integrity, honesty and legal-compliance expectations for suppliers, carried into the Supplier Code of Conduct, with sustainability factors considered at supplier selection and through ongoing engagement; the Group reserves the right to terminate a supplier relationship for non-compliance. The SHREDD process (referenced in the Supplier Code of Conduct) assesses and manages human rights and environmental risks in the supply chain and is reviewed regularly to stay aligned with evolving regulatory standards.

Reference: page 211

The Anti-Fraud, Bribery & Corruption Policy, supported by the Code of Conduct and the internal Group Accounting Manual, governs prevention, detection and response to corruption and bribery, overseen by the Board, the Audit & Compliance Committee and the Internal Audit & Compliance team. Measures include fraud risk assessments, third-party due diligence and continuous training; mandatory training is delivered every two years to all employees, with particular focus on IT users as an at-risk function, achieving 100% coverage of identified at-risk functions in both 2024 and 2025. Allegations are raised through the confidential independent hotline and investigated independently by Internal Audit & Compliance; all fraud and cybercrime attempts, successful or not, are reported to the Audit & Compliance Committee at each meeting. Suspected or confirmed incidents must be promptly reported to the CFO, Group Head of Internal Audit & Compliance, Group Head of Legal, Group Financial Controller and Group Treasurer, with breaches subject to disciplinary action up to dismissal or prosecution.

Reference: page 211 (part of MDR-T/GDR-T disclosures)

The Statement, prepared under the 2023 ESRS, does not present a stated quantitative target for business conduct or anti-corruption. In its absence, the Group tracks effectiveness of its Anti-Fraud, Bribery & Corruption Policy through mandatory two-yearly training for at-risk functions (identified as all IT users, given their access to sensitive systems and data), reporting "maintaining 100% (2024: 100%) coverage of identified at-risk functions" (pages 211-212). Management teams across the businesses are responsible for monitoring training rollout rates and timely notification of employee training obligations, with delivery assigned to each MD supported by Group Legal, and outcomes (fraud attempts, hotline reports) reported to the Audit & Compliance Committee at every meeting. This tracking of training-coverage effectiveness stands in place of a formal numeric target for the G1 business-conduct topic.

Reference: page 213

The Group reported zero convictions for violations of anti-corruption and anti-bribery laws in both 2024 and 2025, and zero total fines for such violations in either year. Its framework for preventing, detecting and responding to corruption and bribery incidents (Anti-Fraud, Bribery & Corruption Policy, described under G1-3) includes a confidential independent hotline for anonymous reporting and a dedicated Internal Audit & Compliance team overseeing investigations for objectivity and impartiality, with findings reported regularly to the Audit & Compliance Committee.