Lagardère
Material Topics
Sustainability statement, in full
The complete text of Lagardère’s FY2025 sustainability statement is held here – 153 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
Role of the administrative, management and supervisory bodies
Reference: pages 80, 210, 230, 233. Section 2.1.4.1 states that composition, expertise and role "are described in section 3.2 of this Universal Registration Document", and sections 3.1/3.2 confirm that "the information presented in this section meets the GOV-1 disclosure requirements of ESRS 2" (pages 210, 242).
Bodies. A Board of Directors with two standing committees: the Audit Committee and the Appointments, Remuneration and CSR Committee (ARCSRC), which "has been tasked with these issues since 2015" (page 80). Both committees are chaired by women who are independent directors (page 230).
Composition (31 December 2025, page 230). "55.5% of the Board's members were women and 55.5% were independent (excluding employee directors, in accordance with statutory calculation methods)." Average age 61 (page 231). Two employee directors (Marie Flavion, Pascal Jouen) sit on the Board (page 236).
Sustainability expertise. The Board skills matrix (page 233) carries a dedicated CSR column, defined as "significant experience in sustainable development or in-depth knowledge of social, societal and environmental issues (including climate change)", alongside business expertise, international, finance, governance/ethics/compliance, executive management and digital/innovation. The Board reviews its own membership annually on the ARCSRC's recommendations.
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Sustainability matters addressed by the administrative, management and supervisory bodies
Reference: page 80.
"The Board of Directors reviews issues related to Lagardère's CSR and climate strategy." The ARCSRC validates and monitors the sustainability targets set by the Group; the CSR and Sustainable Development Department reported to it during 2025, and "the material matters identified through the Group's double materiality assessment and the associated impacts, risks and opportunities were closely monitored". A joint meeting of the ARCSRC and the Audit Committee was dedicated to the approval of the Sustainability Statement.
2025 work programme (page 80):
- Plenary session of ARCSRC and Audit Committee (March): presentation of the 2024 Sustainability Statement (all matters); focus on the Group's equity and diversity policy; focus on ESG non-financial rating agencies.
- ARCSRC (September): annual review of the Lagardère group CSR strategy; focus on the Louis Hachette Group social policy (equal treatment, working conditions, occupational health and safety).
- Audit Committee (December): description of sustainability reporting processes and internal control systems.
Management layer. The CSR and Sustainable Development Department reports to the Secretary General, a member of the Executive Committee. A Group-Division CSR committee meets twice a year with each division's CEO; a cross-functional CSR committee meets monthly with divisional CSR and HR directors.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: pages 81, 258, 266, 268. Sections 3.5.2.1 and 3.8.9 state that they meet "the GOV-3 disclosure requirements of ESRS 2".
Annual variable remuneration of the Chairman and CEO is split 70% quantitative financial criteria, 15% quantitative non-financial CSR criteria and 15% qualitative criteria (page 258).
2025 outcome (page 266). The three CSR criteria and their weights within maximum annual variable remuneration are carbon emissions (6%), anti-corruption training (6%) and proportion of women top executives (3%):
- Carbon emissions: achievement 0% of fixed remuneration, indicator value 4.23 against a trigger level of 3.97 - no amount was earned on this criterion.
- Anti-corruption training: 9% of fixed remuneration (the maximum), indicator 90 against a maximum level of 85%, €153,000.
- Women top executives: 4.50% of fixed remuneration (the maximum), indicator 47 against a maximum level of 47%, €76,500.
- Total non-financial criteria: 13.50% of fixed remuneration, €229,500 of a €2,101,359 total annual variable remuneration.
Long-term. The 2026-2028 performance share plan allocates 30% of shares to non-financial CSR criteria: CO2 emissions at end-2027 (10%), anti-corruption training at 31 December 2027 (10%) and women top executives at 31 December 2027 (10%) (page 268).
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 82 (section 2.1.4.2 "Statement on duty of care (GOV-4)"). The datapoints table (page 199) maps ESRS 2 GOV-4 paragraph 30 to section 2.1.4.2 and flags it Material.
Lagardère maps the Sustainability Statement against French Law No. 2017-399 of 27 March 2017 on the duty of care, which requires a plan covering five components: identification of risks of serious violations of human rights, health, safety and the environment; assessment of supplier and subcontractor practices; prevention or mitigation of risks; a whistleblowing and reporting mechanism; and monitoring and evaluation of measures implemented. "Lagardère established its duty of care framework in 2017. Updating work within the framework of the new parent company Louis Hachette Group was conducted in 2025 for operational implementation in 2026."
The cross-reference table maps the five core due diligence elements to: (a) sustainability criteria in corporate officer remuneration (sections 3.5.2.1, 3.5.1.2.B, 3.8.9) and section 2.1.4.1; (b) stakeholder engagement (2.1.2.3); (c) the double materiality assessment (2.1.3); (d) the Responsible Supplier Charter and EcoVadis assessment of high-risk suppliers (2.4.1.2.3), divisional action plans on diversity, working conditions, health and safety and value chain workers, and the Ethics Line (2.4.1.2.1); (e) social and environmental metrics, and on-site audits at Hachette Livre suppliers (2.3.2.2).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: page 83 (section 2.1.4.3).
Oversight. "The Board of Directors' internal rules, updated in 2024, assign this responsibility to the Audit Committee." In 2025, besides approving the 2024 Sustainability Statement, "a specific meeting was held to discuss the internal control of non-financial data". An operational steering committee, in place since 2023 and coordinated by the CSR and Sustainable Development Department, "met on a quarterly basis in 2025", bringing together Risk, Compliance, HR and Operations across Group and divisions.
Systems. "Data are collected from the divisions via two centralised information systems: Acuredge, which reports social data, and Anaplan... used to collect environmental data. These systems feature automated and blocking controls to help prevent anomalies and incidents."
Controls. Subsidiaries are responsible for collection, reliability and traceability. Consistency checks are run at consolidated level by each division's Corporate team, "with an additional independent check then carried out by the CSR and Sustainable Development Department for the Group as a whole".
Internal audit. "In 2025, an initial internal audit was conducted on the governance system for the Sustainability Statement", covering risk management in data collection and framework compliance, producing a 2025-2026 continuous improvement roadmap.
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 64-66, 72.
Lagardère "is engaged in the business of publishing, production and broadcasting content (media, entertainment, etc.) and of distributing products and services (concessions in travel hubs)" (page 64). The reporting scope covers Lagardère Publishing, Lagardère Travel Retail and Lagardère Live, identical to the financial statements scope (page 59). Headcount at 31 December 2025 was 38,127 across some 50 countries (page 141).
CSR strategy (page 66). In 2025 Louis Hachette Group, Lagardère's parent, defined a CSR strategy entitled "Cultures in motion" on four pillars: fostering a culture of impact (decarbonisation; circular economy for publishing and travel retail; biodiversity for publishing only), of talent, of openness and of trust.
Value chain (page 72). Mapped per division across upstream, own operations and downstream - Travel Retail from agricultural inputs and forestry through packing to retail and dining, then waste management; Publishing from forestry and sawmills through paper and printing to distribution. "The activities of Lagardère SA (Corporate function)... do not involve any actors along the upstream or downstream value chain."
The datapoints table (page 199) records SBM-1 paragraph 40(d) involvement in fossil fuel, chemical production, controversial weapons and tobacco as Non-material.
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 66-70. Listed in the ESRS content index under S1, S2 and S4, referenced to section 2.1.2.3 (pages 197-198).
"Lagardère set up a panel of stakeholder representatives in 2015. This advisory body meets at least once a year and comprises 13 members (including 12 from outside the Group)... The panel has met 13 times since it was set up" (page 67). It was reorganised in 2024 to align its membership with the double materiality assessment, and in 2025 "stakeholder consultation was extended to Louis Hachette Group".
July 2025 Stakeholder Forum (page 68): the challenges and opportunities of the Group's promotion of reading; how investors incorporate ESG criteria; and trends in Diversity and Inclusion. Members' views on the Louis Hachette Group social policy "were incorporated when the policy was finalised in October 2025". Recommendations were shared with the heads of division at the July 2025 mid-year CSR Committee meetings.
Engagement table (pages 69-70) covers social partners and employees, rating agencies, suppliers, shareholders, society, consumers and professional bodies. 2025 ESG ratings: Sustainalytics "Low Risk" 12.87 (from 14.23 in 2024), ranking No. 4 in its category; EthiFinance 70/100, a 14-point improvement. Lagardère Travel Retail joined the LESS platform for supplier CO2 data.
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: pages 74-79.
"Some 40 matters were identified... based on ESRS 1 AR16 of the CSRD. Of these, 20 were considered material... From an initial universe of 20 pre-selected matters, 12 were assessed as material" (page 74): climate change, circular economy, biodiversity, equal treatment and opportunities, working conditions, health and safety at work, value chain workers, consumer health and safety, contribution to education and access to culture, freedom of expression and pluralism, data protection, and prevention of corruption (pages 75-77).
Non-material (page 77): "the impacts, risks and opportunities identified in connection with affected communities (S3), pollution (E2) and water and marine resources (E3) were assessed as non-material for the Group."
IRO table (pages 78-79). "The Group has identified a total of 17 material IROs", each with type, value chain position, time horizon and divisions concerned. They "mainly arise from the Group's own activities... and along its upstream value chain".
No update in 2025. "the conditions justifying an update to the double materiality assessment had not been met. Accordingly, the material impacts, risks and opportunities are identical to those presented in the 2024 Sustainability Statement" (page 77). Climate-specific content is also presented under E1-2 and E1-3 (2025 ESRS numbering).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 71-73 (section 2.1.3.1).
"The Lagardère group's double materiality was assessed using two separate processes: one relating to the risks and opportunities associated with the Group's environmental matters (financial materiality), and the other relating to the impacts of the Group's activities on sustainability matters for all its stakeholders (impact materiality)." It was run by the CSR and Sustainable Development Department with the Risk and Finance Departments and "validated by the Audit Committee and the ARCSRC".
Method. Impact materiality considers "scale, scope, irremediable character and likelihood of occurrence", drawing on ENCORE, WRI, Yale, the Basel and Rotterdam Conventions, SHBD, the World Justice Project, UNICEF and the World Bank (page 72). Financial materiality uses likelihood and magnitude on the Group's gross risk matrix (page 73). Each IRO is scored 1 to 4 and "is considered material when its score is strictly greater than 2"; scores are consolidated per matter, weighted by revenue or headcount.
Integration. "the material ESG risks selected and integrated into the Group risk map are consumer health and safety... and corruption" (page 73). Climate-specific risk identification and scenario analysis also appears under E1-2 (2025 ESRS numbering).
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: pages 60, 197-199.
The statement carries a real ESRS content index. Section 2.6.1 "Table of material matters (IRO-2)" (pages 197-199) lists, per topical standard, each disclosure requirement covered and the section where it sits: E1 (E1-1 to E1-6 plus SBM-3, IRO-1), E4 (E4-1, E4-2, E4-3 plus SBM-3, IRO-1), E5 (E5-1 to E5-5 plus IRO-1), S1 (S1-1 to S1-6, S1-8, S1-9, S1-10, S1-14, S1-16, S1-17 plus SBM-2, SBM-3), S2 (S2-1 to S2-5), S4 (S4-1 to S4-5) and G1 (G1-1 to G1-5 plus GOV-1, IRO-1). Section 2.6.2 lists the datapoints arising from other EU legislation with SFDR, Pillar 3, Benchmark and EU Climate Law references and a Material/Non-material flag.
Declared omissions (BP-2, page 60). "In accordance with the simplifications introduced by Commission Delegated Regulation (EU) 2025/1416 (the 'ESRS Quick Fix')... disclosure requirements related to anticipated financial effects are not reported for 2025." Named social omissions cover S1-7, S1-8 (non-EEA countries), S1-11, S1-13 (the career development review datapoint), S1-14 (work-related ill-health, days lost, non-employee workers) and S1-15. The percentage of employees with disabilities (S1-12) and average training hours per employee and by gender (S1-13) "are nonetheless reported on a voluntary basis" (page 61).
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: pages 87-91, 102 (section 2.2.1.3).
The plan is "embedded into its global strategy... aligned with a 1.5°C pathway for Scopes 1 & 2 combined (46% reduction in direct emissions), and with a 'well below 2°C' scenario for Scope 3 (28% reduction in indirect emissions). The plan has been validated by the General Management of each division and presented to a joint meeting of the Board of Directors, attended by members of the Audit Committee and the Appointments, Remuneration and CSR Committee" (page 87).
Ambition. An absolute 28% reduction by 2030 against a 2019 base year: 46% for Scopes 1 and 2 (1% of total emissions) and 28% for Scope 3 (99%) (page 88).
Gap. "The action plan... paves the way for a 25% reduction in emissions, i.e., covering more than 90% of the target set" (page 89); the Group intends to close the rest "in a pragmatic way".
Scope. Publishing, Travel Retail, News and Radio, over 90% of 2025 revenue; Lagardère Ressources, Live Entertainment, Paris Racing, Labs and category 3.15 Investments are excluded (page 90).
Locked-in emissions (page 102). Publishing, News and Radio "do not have any assets or products sold that generate GHG emissions over their lifetime that would be material". For Travel Retail the only such assets are "energy consumed in stores under long-term lease... fully covered by the transition plan".
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Back-filled from section 2.2.1.1.2 "Analysis of climate scenarios and business model resilience" (pages 84-86). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Classification. Physical: higher paper prices, disruption of airport operations, damage to buildings. Transition: higher paper prices and a decline in air traffic (pages 85-86).
Scenarios (page 84). Three, each named with a temperature projection: a "Paris-aligned pathway" under 1.5°C in 2100 based on IPCC SSP1-2.6; an "intermediate pathway" of around 2.7°C based on SSP2-4.5; and a "continuous pathway" of around 4°C based on SSP5-8.5. "The results from the intermediate scenario (2.7°C) for 2030 were used to score transition risks." Horizons are 2025, 2030 and 2050.
Methodology. Physical risk was assessed "on a selection of sites representing more than 70% of the net carrying amount of right-of-use assets... more than 50% of the Group's revenue", covering nine hazards (extreme rainfall, heatwaves, drought, storms, flooding, cold, hail, wind, wildfires) under SSP5-8.5 (page 85). Transition risks cover the TCFD categories, with stakeholders mobilised in 2024 to qualify exposure (page 86).
Timing. Carried out in 2023 and 2024; "The findings of the analyses conducted in 2023 and 2024 remained relevant for 2025" (page 85), so it was not refreshed this year.
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Back-filled from sections 2.1.3.2.2 (page 77), 2.2.1.1.2 (pages 84-86) and 2.2.4.1 (page 132), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.
Result. "In 2024, a climate risk exposure and vulnerability analysis based on three scenarios demonstrated the resilience of Lagardère's activities. It covered the Group's entire reporting scope" (page 84).
Quantified implications (page 86). For Publishing the analysis gives "an estimated increase in the price of paper of around 30% by 2050 for the three scenarios, which represents a moderate financial effect... before taking adaptation measures into account". For Travel Retail a 1.5°C scenario "assuming a 3% annual decline in air traffic volume (the most unfavourable scenario for the business model)... resulted in a significant reduction in revenue and earnings... The assumption of a decline in air traffic was used in the division's sensitivity tests, which did not identify any impairment."
Conclusion. "The financial impacts resulting from the transition risks identified... were therefore deemed non-material. This study corroborates the financial and resilience analyses of the Lagardère group's strategy and business model" (page 86). Significant areas of uncertainty are not set out as a distinct disclosure.
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: pages 87-88 (section 2.2.1.3.1 "Lagardère group climate policy (E1-2)").
The Group's environmental commitment covers "climate change, renewable energy sourcing, energy efficiency, resource stewardship (especially paper and plastics) and an environmentally responsible approach to the food chain... Lagardère's commitment to reducing its carbon footprint is enshrined in its environmental policy. Divisional teams are responsible for embodying and driving this policy forward".
Caveat stated by the company. "The emission reduction targets... are contingent on the continuation and strengthening of public policies and regulatory initiatives around the world. Policymakers and scientific experts alike have questioned the feasibility of these targets."
Divisional expression. "In 2025, Hachette Livre increased its decarbonisation targets, aiming to reduce its greenhouse gas emissions by 50% by 2030 compared with 2019 levels (the '50/30' strategy)", the earlier 30/30 targets having been "met and exceeded by 2024, with an overall reduction of 35%". Travel Retail "drew up a comprehensive decarbonisation plan in 2024", constrained by a model "that remains dependent on the efforts of its suppliers" (page 88).
Climate governance runs through a Carbon Steering Committee of Group and divisional CSR, Finance and Operations, set up in 2024 and held quarterly in 2025.
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 89-102 (section 2.2.1.3.3 "Policies implemented (E1-3)").
Page 92 tabulates each action with timeframe, carbon impact and supporting CapEx/OpEx. Selected 2030 figures, tCO2eq:
- Travel Retail renewable electricity sourcing 37,629; energy efficiency 3,570 (CapEx €500k); fleet electrification 1,421. Publishing renewable electricity 2,275, energy efficiency 74, fleet 502; News and Radio fleet 108.
- Travel Retail suppliers' carbon commitment 267,159, KPI 60% of purchasing volume from suppliers with a decarbonisation commitment; shift to responsible consumption 219,779, KPI 12.5% cuts in beef and white meat volumes versus 2024.
- Publishing paper intensity and printing and binding intensity, tracked at 604 kgCO2eq per metric ton of paper and 360 kgCO2eq per metric ton of printed paper in 2025 (pages 95-96); over-production at a 61.7% rate.
2025 delivery. Publishing consolidated the Assas and Odeon sites onto Vanves and cut Spanish electricity use 13% year on year (page 93); "82% of emissions related to paper and printing activities were calculated using emission factors provided by suppliers" (page 94). Travel Retail "invested €250 thousand to replace store lighting systems across European countries with the latest generation of LED lamps", joined the LESS platform, and reports "nearly 60% of LTR's suppliers had an SBTi-validated pathway" (pages 97-98).
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: pages 88-89 (section 2.2.1.3.2 "Climate pathway and targets (E1-4)").
Targets table (page 89). Scopes 1 and 2 market-based: baseline scenario 1.5°C, -46% by 2030 from a 2019 base value of 96 ktCO2eq. Scope 3: baseline scenario WB2C, -28% by 2030 from a 2019 base value of 2,313 ktCO2eq. "Emissions linked to item 3.15 are excluded"; the targets cover the Publishing, Travel Retail, News and Radio scope, and the Scope 1 and 2 target splits 33% Scope 1 and 96% Scope 2.
Method and its limits. "Although the Group has not yet embarked on an official certification process, these medium-term targets for Scopes 1 & 2 were defined in 2022 using the cross-sector Absolute Contraction Approach (ACA) defined by the Science-Based Target initiative" (page 88). Separately, Travel Retail "had its greenhouse gas reduction targets validated by the Science Based Targets initiative (SBTi)" in 2025, pledging -42% Scopes 1 and 2 and -25% on part of Scope 3 by 2030 (page 97).
Baseline caution. For Scope 3 "a principle of prudence was systematically applied to estimates... This approach resulted in a probable overestimate of emissions for the 2019 base year"; the 2025 methodology work "will be assessed in 2026. The decarbonisation pathway and the 2019 baseline have not been revised at this stage".
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: pages 102-105 (section 2.2.1.4.1).
2025 Group totals (page 104), 2024 in brackets. Total energy consumption 300,938 MWh (296,980), up 1%. Fossil sources 68,770 MWh (70,848), a 23% share (24%): crude oil and petroleum products 13,597 MWh (17,379), down 22%; natural gas 40,944 MWh (39,112), up 5%; purchased fossil-sourced electricity and heat 14,230 MWh (14,357). Coal: zero.
Nuclear. 782 MWh (3,132), a 0% share, down 75%.
Renewables. Purchased electricity, heat, steam and cooling from renewable sources 231,209 MWh (217,244); self-generated non-fuel renewable energy 177 MWh (120); renewable fuel including biomass 0 MWh (5,635). Total renewable 231,386 MWh (222,999), a 77% share (75%).
High climate impact sector. "The activities of the Lagardère Travel Retail division are included in category G47 - Retail trade, except of motor vehicles and motor bikes, of the European classification of economic activities (NACE). As a result, the division is subject to the reporting obligations applicable to sectors with a high climate impact" (page 103). Energy intensity from those activities per net revenue: 38 MWh/€m in 2025 against 39 in 2024, down 3%.
Basis. Actual invoice data for ten months with the last two estimated; Travel Retail store consumption is estimated per square metre because "the division's entities often do not have direct access to their energy consumption" (pages 102-103).
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 105-110 (section 2.2.1.4.2).
Full Lagardère scope, 2025 versus restated 2024 (page 110), tCO2eq. Scope 1 12,815 (12,956); Scope 2 location-based 79,042 (77,722); Scope 2 market-based 3,499 (6,326); Scope 3 excluding 3.15 1,644,723 (1,848,489); category 3.15 Investments 199,934 (253,713). Total location-based 1,936,514 (2,192,880); market-based 1,860,971 (2,121,484). GHG intensity per net revenue fell 23%, to 207 tCO2eq/€bn location-based.
Largest Scope 3 categories (pages 107-109). Purchased goods and services 1,206,824 (down 14%); upstream transportation and distribution 144,782 (up 16%); end-of-life treatment of sold products 132,999 (down 15%); employee commuting 32,566.
Coverage. Collection "covers 100% of its financial scope for Scopes 1 & 2, and approximately 60% of its scope for Scope 3" (page 107). Scope 3 represents "95% of its location-based emissions and 99% of its market-based emissions" (page 109). Excluded: categories 1.3-1.5 and 3.8, 3.10 and 3.13 for the whole scope; 3.11 for Travel Retail; 3.15 for Publishing (page 106).
Restatement. 2024 was restated for a new extrapolation method and product-weight refinements, cutting reported 2024 Scope 3 by 8.7% (page 107); "the 2019 GHG emissions have not been revised to date; they will be updated in 2026". The auditors added an emphasis of matter on these Scope 3 uncertainties (page 195).
E4 – Biodiversity and Ecosystems
E4-1Transition plan on biodiversity and ecosystemsReported
Transition plan on biodiversity and ecosystems
Reference: pages 131-132 (section 2.2.4.1 "Biodiversity matters at Lagardère"), listed in the ESRS content index as DR E4-1, transition plan and consideration of biodiversity and ecosystems in strategy and business model (page 197).
"As a publisher, Lagardère Publishing uses natural forest resources upstream in its value chain. In the long term, the material risk... consists of higher paper costs due to fines for suppliers' non-compliance with laws protecting biodiversity... the costs borne by the operators could be passed on to the price of the raw materials purchased by the paper manufacturers, and ultimately affect the operating cost of the paper purchased" (page 131). Scope limitation stated by the company. "The double materiality assessment highlighted the materiality of the risk of an increase in the cost of biological raw materials for the Lagardère Publishing division only. As a result, the scope of reporting on the 'Biodiversity and ecosystems' topic does not include the Group's other divisions" (page 131).
Affected communities. "To date, no communities have been identified as likely to be affected by Lagardère Publishing's activities... due particularly to the responsible sourcing policy in force."
The report presents this as consideration of biodiversity in strategy and business model; no separate biodiversity transition plan is disclosed.
E4-2Policies related to biodiversity and ecosystemsReported
Policies related to biodiversity and ecosystems
Reference: page 132 (section 2.2.4.2.1 "Lagardère Publishing's responsible paper sourcing policy (E4-2)").
"As part of its paper sourcing policy, which has been in place for over ten years, Lagardère Publishing has implemented a number of actions to reduce the pressure caused by its activities on biodiversity. The branch favours the use of paper certified FSC... or PEFC..., which guarantee the absence of illegal deforestation."
"These certifications ensure compliance with sustainable forest management principles, such as adherence to international treaties, protection of the rights of indigenous peoples, support for the well-being of local communities... They also help to preserve biodiversity and associated elements, such as water resources, soil and natural habitats."
The division "has also set up traceability mechanisms for the wood fibres used in its papers, as well as audit programmes based on random sampling in the main countries where it operates". Effectiveness is measured "by monitoring the rate of certified and recycled paper supplies", and the policy "is coordinated by the Manufacturing Technical Department".
The datapoints table maps the ESRS E4-2 datapoint on policies to address deforestation (paragraph 24(d)) to section 2.2.4.2 and flags it Material; the sustainable land/agriculture and oceans/seas datapoints are Non-material (page 202).
E4-3Actions and resources related to biodiversity and ecosystemsReported
Actions and resources related to biodiversity and ecosystems
Reference: pages 132-133 (section 2.2.4.2.2 "Fibre testing and forest certification recognition programmes (E4-3)").
Certified supply. "In 2025, 99% of paper supplied to Lagardère Publishing was certified or recycled paper" (page 132). The division "asks its suppliers to ban certain grades of paper that do not meet the requirements set (traceability, fibres from sustainably managed forests, etc.)... particularly those originating in countries identified as being at risk".
Fibre testing. "In the United States, Hachette Book Group (HBG) is continuing its fibre testing programme. For each new paper containing fibres not yet listed... samples are sent to a laboratory to ensure that the papers in question, particularly those originating from Asian markets, are produced by suppliers who respect their environmental commitments... that no high-grade exotic wood is mixed into the weave." "In 2025, 23 testing campaigns were conducted, with 100% of fibres analysed receiving approval." Expected results. "the prevention of deforestation and 99% of paper purchased either certified or recycled" (page 133).
Awareness. For around 15 years operating staff have run a supplier and printer awareness policy encouraging certification; "In France... over 99% of paper purchases are from ISO 14001-certified paper manufacturers" (page 133).
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: pages 116-118 and 121, sections 2.2.3.2.1 and 2.2.3.2.2, both headed "Circularity policies (E5-1)".
Lagardère Publishing runs three policies overseen by the CSR, Technical and Operations Departments, "headed by members of the division's Executive Committee": a publishing efficiency policy that "aims to reduce the requirement for virgin resources"; a responsible purchasing policy; and a low-plastic strategy. Sustainable paper sourcing "guarantees the purchase of FSC- or PEFC-certified paper and, where publications permit, the use of recycled paper" (pages 116-117).
Lagardère Travel Retail works from "two key commitments: 1) reducing food waste and 2) using responsible packaging and consumables. These commitments are applicable to all Lagardère Travel Retail division entities, through their own-brand stores (i.e., 70% of stores, with the remaining stores operated by partner brands) in some 50 countries" (page 121). The FLOW (Fighting to Limit Our Waste) programme, launched at end-2023, is "organised around five pillars: measure, engage staff, anti-waste SOPs, in-store promotions and excess food management" (page 121). The packaging policy covers consumables, checkout bags, water bottles and freight packaging, with virgin plastics banned since 2023.
E5-2Actions and resources related to resource use and circular economyReported
Actions and resources related to resource use and circular economy
Reference: pages 118-123 (sections 2.2.3.2.1 and 2.2.3.2.2, "Implementation: key actions to promote circularity (E5-2)").
Publishing. Actions run across France, Spain, the UK and the US, "some 80% of the division's business"; "No significant costs have been identified in connection with the implementation of these actions" (page 118). They cover paper wastage-rate control, format optimisation, and the eco-design programme - Eco-Design Week since 2021 and the biennial Eco-Challenge, extended to the UK in 2025 as "Green Shoots" (page 119). Low-plastic actions in France target box sets, book lamination and logistics film. In Spain, Grupo Anaya eliminated plastic from small-shipment packaging and halved pallet-wrapping plastic, saving "an estimated 13.8 metric tons per year"; at Hachette UK "75% of damaged pallets are reintroduced into the supply chain through the reuse of timber" (page 120). Travel Retail. FLOW tools have reached "three countries... the Platform solution, and eight countries... the Marketplace solution across more than 444 restaurants, saving over 125,000 meals from the bin" (page 123). In 2025 the division "achieved its target of transitioning all purchasing for its direct operations to eco-responsible bags" and switched to 100% recycled cardboard at the central Duty Free warehouse.
E5-3Targets related to resource use and circular economyReported
Targets related to resource use and circular economy
Reference: pages 115-117, 121-122 (sections 2.2.3.2.1 and 2.2.3.2.2, "Targets set (E5-3)").
Lagardère Publishing - plastics. "a reduction pathway and an action plan have been defined for 2030, with the target of an overall 25% reduction in plastic use in France against a 2019 baseline. This scope includes box sets (product and packaging), audiobooks, book lamination, individual protective film for books and plastic used in logistics" (page 117). It is "a voluntary target... the first operational implementation of this policy within Hachette Livre in France", monitored by annual consolidated measurement of plastic volumes using category-specific methods. "In 2026, the approach will be extended to other Group subsidiaries, notably in Spain, the United Kingdom and the United States."
Lagardère Publishing - publishing efficiency. Effectiveness is tracked by the pulp rate, "the ratio of the number of books pulped divided by the total number of books produced", assessed annually (page 116).
Lagardère Travel Retail - rPET. "The division has set a voluntary target: 75% of water bottles sold made from 100% recycled PET (RPET) by the end of 2025, at all stores of its consolidated entities. This target uses 2023 as the base year, when 59% of water bottles sold were made from 100% RPET" (page 122). The 2025 metric reports 75% (page 135), so the target was met.
E5-4Resource inflowsReported
Resource inflows
Reference: pages 123-127 (section 2.2.3.3 "Management of resource inflows: paper, plastics and logistics (E5-4)").
Lagardère Publishing (page 125), 2025 with 2024 and 2023. Paper purchased and supplied 169,078 metric tons (162,733; 133,207), of which 99.6% FSC- or PEFC-certified (98%; 97%) and 0.3% recycled (2%; 3%). Cardboard 5,394 metric tons (5,164; 5,388), 6% recycled (0%). Plastic 213 metric tons (258; 229), 0% biobased and 13% recycled (2%). Paper purchases "cover 100% of the Lagardère Publishing (trade publishing) scope... and Partworks"; cardboard and plastic cover the four main entities, "almost 80% of Lagardère Publishing's revenue".
Lagardère Travel Retail (page 127). Checkout bags 4,357 kg (2024: 5,540), 99% from sustainable sources (39%), of which 69% recycled (31%). Consumables excluding bags 3,122 kg (1,791), 54% from sustainable sources (18%). Logistics cardboard 881 metric tons (2,514), 55% recycled (50%). Plastic bottles made from recycled rPET 75% (63%). Data cover Duty Free Global, France, Italy and North America, "representing over 50% of the division's revenue", then extrapolated to the whole division.
Declared partial disclosure (page 63). "In the context of reporting on... resource inflows for products distributed (E5-4 paragraph 31a, b), Lagardère Travel Retail continues, as in the previous year, only to disclose information on single-use packaging and plastic water bottles sold."
E5-5Resource outflowsReported
Resource outflows
Reference: pages 128-130 (section 2.2.3.4, "Monitoring and management of waste from operations (E5-5)").
Products and durability. "The Lagardère Publishing division's resource outflows are the books it sells. These products, which do not expire or become obsolete, are highly durable... However, issues arise as to end-of-life and the circularity of books in the case of unsold titles and product returns... all pulped titles are recycled and reused to make recycled paper" (page 128).
Travel Retail outflows. "the division's main resource outflows are products sold at stores... identical to resource inflows, with the exception of the Dining business, which processes raw food products." The main waste sources are "cardboard and plastic used in logistics operations (8,605 metric tons)", then "consumables and checkout bags (some 6,258 metric tons). As these are taken away and discarded by travellers, it is impossible to trace their end-of-life", then food waste (page 129).
Traceability limits. For both divisions, "it is not possible to trace the treatment of this waste when it is directed to disposal"; an "average end-of-life" category is used for untraced streams. Travel Retail "plans to survey and monitor reporting by its concession grantors (e.g., SNCF, ADP, etc.), who are responsible for waste management and treatment within the concessions" (page 130).
E5-5(was E5-5-Waste)WasteReported
Waste
Reference: pages 129-130 and the summary table on page 135 (section 2.2.3.4).
Lagardère Publishing (page 129), metric tons, 2025 with 2024 and 2023. Waste not directed to disposal: hazardous WEEE recycled 0 (1; -); non-hazardous recycled 24,791 (27,968; 24,058). Total not directed to disposal 24,791 (27,969; 24,058). Waste directed to disposal, non-hazardous at average end-of-life: 227 (120; 212). "Electrical and electronic equipment (WEEE) is the only type of hazardous waste." Non-hazardous waste is cardboard and plastic from logistics; pulped unsold books count in the recycled category. Box-set production waste in France "is recycled (50%) and incinerated (50%)" (page 128).
Lagardère Travel Retail (page 130), metric tons, 2025 with 2024. Not directed to disposal: WEEE recycled 3 (4); food composted 713 (1,254); logistics recycled 5,256 (4,658); total 5,972 (5,916). Directed to disposal: logistics at average end-of-life 3,349 (4,520); consumables 6,258 (8,236); food incinerated 2,411 (2,926); total 12,017 (21,594). Data were collected in France, North America and Italy, "representing 50% of the division's revenue", then extrapolated to the full division.
The datapoints table maps the E5-5 non-recycled waste (paragraph 37(d)) and hazardous and radioactive waste (paragraph 39) datapoints to section 2.2.3.4 and flags both Material (page 202).
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 136, 143, 150, 154 (sections 2.3.1.1, 2.3.1.2, 2.3.1.6.2, 2.3.1.7.2, 2.3.1.8.2).
"In 2025, a social policy was established at the level of Louis Hachette Group... The social policy applies to all Lagardère group employees, including franchise staff who have an employment contract with Lagardère Travel Retail" (page 136). Three material social matters sit under it: equal treatment and opportunities, working conditions, and health and safety at work.
Human rights (page 136). The Group commits to the UN Guiding Principles on Business and Human Rights, the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work "which deals in particular with the elimination of forced or compulsory labour and the abolition of child labour", and the OECD Guidelines.
Equal treatment (page 143). The policy commits to treating every employee fairly, tolerating "no unlawful discriminatory practices", promoting a workplace "free from any form of harassment, exploitation, abuse or violence", and gender balance at all levels.
Working conditions (page 150) and health and safety (page 154). Commitments cover job security, working time and remuneration, ensuring "that no employee is paid less than the applicable legal or contractual minimum wage", plus a policy to "reduce health and occupational risks through preventive action and training".
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: pages 136-138 (section 2.3.1.3 "Social dialogue (S1-2, S1-8)").
"Lagardère promotes an open and constructive culture of social dialogue, in line with the legal frameworks and social practices in force in each of the countries where it operates... The Lagardère group upholds freedom of association and the effective recognition of the right to collective bargaining within the framework of the regulations and practices applicable in its host countries."
Group level (page 137). "As from 2025, employee representative bodies operate at the level of Louis Hachette Group... through the Group Employees' Committee, created in 2025." It has 30 full members appointed by the trade unions, meets once a year at the invitation of the Chairman and CEO, "operates exclusively within France", and receives information on business, financial position and employment trends. "During the ordinary meeting, a presentation is made for each business addressing CSR-CSRD issues." "The Group Secretary General's office is responsible for ensuring that these interactions actually take place."
"A European Works Council is in the process of being set up... a Special Negotiation Taskforce was set up to create a body representing European employees (in France and in the 16 European Union countries in which the Group operates)... its operating procedures... have not yet been adopted."
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Processes to remediate negative impacts and channels for own workers to raise concerns
Reference: pages 139-140 (section 2.3.1.4) and 184-185 (section 2.4.1.2.1).
"Lagardère group employees can report any behaviour or facts relating to the Group's activities that they perceive to be unlawful or in violation of the applicable policies and procedures on working conditions, health and safety, equal treatment and/or equal opportunities. These reports can be made directly to line managers, Human Resources departments or Compliance Officers, or through the whistleblowing platform set up by the Group" (page 139).
The Ethics Line "operates in various languages and can be accessed 24/7 on the Group's Intranet and Internet sites" (page 184). "The conditions of use guarantee the confidentiality of exchanges, allow reports to be submitted anonymously, include a commitment not to retaliate against the whistleblower, and offer protection for the user and the person(s) targeted by the report." Report managers "are appointed on the basis of their expertise and independence" (page 185).
"The information collected through the platform is used by the Corporate Human Resources Department and the Group Compliance Department to determine the requisite and appropriate actions to be taken" (page 140). The datapoints table maps the S1-3 grievance mechanism datapoint (paragraph 32(c)) to sections 2.3.1.4 and 2.4.1.2.1 and flags it Material (page 202).
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 144-148 (2.3.1.6.3), 151-153 (2.3.1.7.3) and 155-157 (2.3.1.8.3).
Diversity and anti-discrimination (pages 144-147). Hachette Livre's diversity self-assessment web app in France; Hachette UK's "Changing the Story" programme, whose Board of 14 representatives was relaunched in 2025 and which is being rolled out in the United States; a Lima airport programme in Peru that has supported 24 young people since 2022. On harassment, "In 2024, a training module was made available to all employees on the Group's e-learning platform and remained accessible in 2025... At the end of these two years, 82% of the Group's employees had completed this training" (page 145). On disability, Hachette Book Group "carried out an accessibility audit of all its premises in 2025", and Travel Retail was awarded "Level 3 Disability-Confident Leader certification" at Luton airport.
Working conditions (pages 151-153). A cross-division mobility committee met five times in 2025; the cross-division mentoring programme's sixth class had 25 mentees; parental measures were extended at Hachette UK in January 2025.
Health and safety (pages 155-157). Annual risk assessments per subsidiary, DUERP restructuring in France, first-aid training (70 employees since 2021, 11 in 2025 at News and Radio) and a Vigipirate-aligned security plan.
All three sections state the actions require no significant OpEx or CapEx.
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 143-144 (section 2.3.1.6.2), with the working conditions and health and safety positions at pages 153 and 157.
One target is set, on gender balance. "an annual target has been in place since 2021 regarding the proportion of women among top executives, enabling the Group to monitor policy implementation. The Stakeholder Forum, ARCSRC and the Board of Directors, three bodies on which employees are represented, are involved in defining and monitoring performance in relation to this target" (page 144).
The target table (page 144) gives: target 47%, type relative, scope "Group (all consolidated companies)", baseline figure 42%, base year 2020, 2025 result 47%. The narrative tracks the series: "the proportion of women among top executives has risen from 42% at end-2020 to 44% in 2021, 45% at end-2022, 46% at end-2023 and 2024 and 47% at end-2025, in line with the target set". In 2025 women "represented 62% of the total permanent workforce and 59% of managers".
No targets on the other two S1 matters. For working conditions, "To date, no targets have been set for this sustainability matter. The effectiveness of the actions and policies put in place is tracked using the metrics disclosed in this report" (page 153). For health and safety, "To date, no targets have been set for health and safety at work" (page 157). Both state that effectiveness is tracked through the disclosed metrics instead.
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: pages 141-142 (section 2.3.1.5) and the summary table on pages 181-182.
Headcount at 31 December 2025 (page 141), with 2024 and 2023. Total employees 38,127 (38,214; 35,725). By gender: women 23,800 (23,981; 22,764), men 14,319 (14,230; 12,961), other 3 (3; -), not reported 5 (0; -). "The 'Other' category corresponds to employees who identify as third gender or gender neutral."
By contract type (page 141). Permanent 33,112 (33,574; 31,316); non-permanent 3,606 (3,383; 4,409); non-guaranteed hours 1,409 (1,257; -).
By region (page 142). France 6,090; Europe excluding France 16,545; Americas 12,203; Asia-Pacific 2,770; Africa 519. Country detail is given for France 6,090 (6,117; 5,869) and the United States 9,746 (10,531; 10,091), the two countries with 50 or more employees representing at least 10% of the Group total.
Turnover (page 142). Employees who left during the year 11,994 (12,809; 13,348); turnover rate 36% (39%; 45%). The rate uses permanent employees only, because "Given the high volume of temporary employment contracts in the Travel Retail sector, including these contracts in the calculation would make the indicator unrepresentative."
Headcount is reported at 31 December and differs from the average annual headcount in the financial statements (page 62).
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: page 139 (section 2.3.1.3), listed in the ESRS content index as DR S1-8, collective bargaining coverage and social dialogue, against section 2.3.1.3 (page 198).
Metrics (page 139), 2025 with 2024. Employees covered by collective bargaining agreements 66% (67%). For EEA countries with more than 50 employees representing more than 10% of the total, France falls in the 80-100% band for both collective bargaining coverage and workplace representation. The summary table (page 181) adds France-scope coverage of 100% (100%) and workers' representative coverage of 97% (96%).
Partial omission declared. BP-2 states that under the ESRS Quick Fix transitional provisions "all data points relating to collective bargaining and social dialogue regarding employees in non-EEA countries (S1-8)" are not reported for 2025 (page 60). The disclosure is therefore complete for the EEA and withheld outside it.
The qualitative social dialogue disclosure sits in the same section, covering the Group Employees' Committee created in 2025, the European Works Council under negotiation, and entity-level arrangements including works councils in Germany and Austria and union representatives in 35 Italian stores (pages 137-138).
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: page 148 (section 2.3.1.6.4 "Performance metrics (S1-9; S1-16)").
Age distribution (page 148), 2025 with 2024 and 2023. Under 30: 11,388 (11,748; 11,127). 30 to 50: 17,904 (18,042; 16,313). Over 50: 8,835 (8,424; 8,285).
Top executives (page 148). Number of women top executives 171 (173; 177); percentage of women top executives 47% (46%; 46%). This is the metric behind the Group's single S1 target, which set 47% for 2025 from a 42% baseline in 2020 (page 144).
Related diversity metrics. Percentage of managers trained in diversity during the year 21% (23%; 22%) (page 148). Percentage of employees with disabilities 2.9% (2.7%; 1.97%), disclosed voluntarily under S1-12 (page 182).
Context given at page 144: in 2025 women "represented 62% of the total permanent workforce and 59% of managers". The full workforce gender split at 31 December 2025 was 23,800 women, 14,319 men, 3 other and 5 not reported (page 141).
The report does not define the "top executives" population by management level in this section, and gives no gender distribution at each of the top two management levels separately.
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: page 152 (section 2.3.1.7.3 "Actions implemented in 2025 (S1-4, S1-10)"), listed in the ESRS content index against section 2.3.1.7.3 (page 198).
"In accordance with the S1-10 disclosure requirements, Lagardère has published an 'adequate wage' analysis for the second year running. This involves comparing the remuneration guaranteed by the Company with the minimum wage defined by local legislation or by any collective bargaining agreements. Where no legal or contractual minimum wage provision exists, the remuneration paid is compared to wage benchmarks for each country concerned that enable employees to cover their basic needs. Lagardère relied mainly on the ILOSTAT database for this analysis."
Named exception. "this database does not define an adequate wage for the United Arab Emirates. In addition, there are no regulations or collective bargaining agreements applicable to all Lagardère Travel Retail employees in that country, nor a relevant benchmark index... Lagardère has therefore chosen to base its analysis on a comparative study of observed pay practices, based on data shared by nine companies specialising in recruitment and human resources."
Conclusion. "Further to this analysis, the Group confirms that all its employees receive remuneration that is equal to or higher than these benchmarks." No percentage of employees paid below an adequate wage is given, because none are.
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: page 157 (section 2.3.1.8.4), listed in the ESRS content index against section 2.3.1.8.4 (page 198).
Metrics (page 157), 2025 with 2024 and 2023. Employees covered by the Group's health and safety management system 94% (94%; -). Employee fatalities from work-related accidents 1 (1; -); from work-related ill health 0 (0; -). Work-related accidents 1,187 (1,089; 464). Days lost 16,982 (17,802; 18,159). Frequency rate 17.52% (15.62%; 8.61%).
Explanations given. The 2023-to-2024 jump follows a methodology change: from 2024 the Group records "all work-related accidents that occur during the year, irrespective of whether they result in time off work", and includes all contract types rather than permanent only. The 2025 rise "is primarily attributable to an increase in accidents considered to be non-severe", noted at Publishing in Spain and the UK and Travel Retail in Italy. "Nevertheless, severe accidents have decreased overall across all activities, as shown by the continuing fall in days lost due to accidents at work (down 4.6% compared with 2024 and down 6.5% compared with 2023)" (page 158).
Partial omission declared (page 60). Under the ESRS Quick Fix, "data points relating to cases of work-related ill-health, the number of days lost due to work-related ill-health and non-employee workers (S1-14)" are not reported for 2025.
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: pages 148-149 (section 2.3.1.6.4).
Metrics (page 148), 2025 with 2024. Gender pay gap 14% (15%). Annual total remuneration of the highest paid individual divided by the median annual total remuneration for all other employees: 124 (97).
Breakdown by employee category (page 148). Top executives 29%, managers 5%, other 4%, total 14%. By division (page 149). Lagardère Publishing 6%, Lagardère Travel Retail 16%, Lagardère Live 9%, total 14%.
Company commentary (page 149). "Introduced in 2024 in accordance with the ESRS S1-16 disclosure requirement, the gender pay gap metric... remains a fairly new indicator... The gender pay gap comes out at 14%, which means that the average salary of male employees is 14% higher than that paid to women employees on average. This pay gap is calculated at the level of a group which operates in a wide variety of business sectors... and in more than 50 countries."
Basis (page 62). The pay ratio uses direct remuneration - cash benefits, benefits in kind and the fair value of annual long-term incentives - with the highest-paid individual excluded from the median sample. Arnaud Lagardère's director's fees of €44,380 were excluded from his 2025 remuneration for this calculation.
The Group's French weighted equal pay index was 91/100 in 2025, against 93 in 2024 (page 146).
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: page 140 (section 2.3.1.4), listed in the ESRS content index (page 198).
Metrics (page 140), 2025 with 2024. Incidents of discrimination including harassment 120 (62). Other complaints filed 15 (9). Fines, penalties and compensation paid 0 (0). Severe human rights incidents connected to the Group's workforce 0 (0), with fines and compensation of 0 (0). Both series are footnoted "Data reported for the first time in 2024".
Outcomes disclosed. "Out of the 120 incidents of discrimination, including harassment, reported in 2025, 20 were deemed substantiated, 81 unsubstantiated and seven are in the process of being dealt with. Out of the 15 other incidents reported in 2025, three were deemed substantiated, nine unsubstantiated and three are in the process of being dealt with. These 15 complaints related to health and safety, as well as the violation of human rights and fundamental freedoms."
Explanation of the increase. "The substantial year on year increase in the number of incidents is due to better identification of reports submitted outside the Group's dedicated whistleblowing system. Confirmed reports, the number of which fell slightly in 2025, were the subject of various management measures... which in some cases led to dismissal."
The three outcome categories sum to 108 of the 120 incidents reported; the statement does not account for the remaining 12.
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Policies related to value chain workers
Reference: pages 158-160 (section 2.3.2.2 "Policies and actions implemented in 2025 (S2-1, S2-3, S2-4)").
"The Group's strategy towards its external partners is based on two key measures: a Responsible Supplier Charter, which must be signed by new contractors working with a Group company... [and] a joint project with EcoVadis to conduct regular assessments of the social, environmental and ethical performance of its suppliers and subcontractors" (page 158).
The Charter, "applicable to all Lagardère group activities and territories, invites suppliers to align themselves with the Group's demanding criteria in terms of social and environmental values and business ethics... it imposes a minimum standard in countries where there is insufficient legislation to protect workers". Suppliers undertake to comply with standards on child and adolescent labour, forced or compulsory labour, working time, undeclared work, minimum wages, equal treatment, health and safety and social relations (page 188), and are encouraged to seek SA 8000, OHSAS 18001 or ILO-OSH 2001 certification (page 159).
Stated gap. Both divisions declare the same limitation: "Lagardère Publishing does not have a formal policy as required by ESRS, as the general objectives relating to this matter are not yet integrated into ESRS-compliant documentation" (page 159), and the identical wording appears for Lagardère Travel Retail (page 160).
S2-2Processes for engaging with value chain workers about impactsReported
Processes for engaging with value chain workers about impacts
Reference: page 159 (section 2.3.2.2), listed in the ESRS content index against section 2.3.2.2 (page 198).
Stated absence of a general process. "To date, the Group and its divisions have not adopted a general process for engaging with workers in the value chain. A whistleblowing platform, accessible to all the Group's external stakeholders, nevertheless allows value chain workers to raise concerns and enables the Company to implement the necessary remedial actions."
"Consistent with the Group's commitments to promote and respect human rights, as set out in its Responsible Supplier Charter, the whistleblowing platform can also be used to report any cases of non-compliance with human rights affecting workers in the value chain. The ethics whistleblowing line is described in section 2.4.1.2.1 of the Sustainability Statement, which notably details how value chain workers are made aware of the platform along with the protection mechanisms and the investigative processes."
Awareness of the channel is created "to workers in the value chain: a reference in the Responsible Supplier Charter, a posting on the Group's website" (page 184).
Indirect engagement runs through the Stakeholder Forum, where "A Lagardère Travel Retail supplier and a printer working with Lagardère Publishing are members" (page 69).
S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concernsReported
Processes to remediate negative impacts and channels for value chain workers to raise concerns
Reference: page 159 (section 2.3.2.2) and pages 184-185 (section 2.4.1.2.1), both cited in the ESRS content index (page 198).
The Ethics Line is open to "all of its employees, shareholders, service providers, suppliers and customers" and can be used to report "any behaviour or fact relating to the Group's activities that the person submitting the report perceives to be unlawful or contrary to the Group's policies, procedures or the Anti-corruption Code of Conduct... or to present a threat or harm to the general interest" (page 184). It runs in several languages, is accessible 24/7, allows anonymous reports and carries a non-retaliation commitment.
2025 outcome (page 159). "Four incidents relating to workers in the value chain were reported in 2025. One incident concerned health and safety and three incidents related to discrimination. All four reports were classified as unsubstantiated."
Monitoring of remediation is described at page 161: actions "are monitored and evaluated, mainly through the whistleblowing platform set up by the Group, on-site audits carried out by Lagardère Publishing and the assessment of suppliers 'at risk' with EcoVadis... If necessary, additional actions will be recommended to limit any negative impact on workers in the value chain. No material negative impact required specific action in 2025."
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
Taking action on material impacts on value chain workers
Reference: pages 159-161 (section 2.3.2.2).
Risk targeting. EcoVadis assessments focus on high-risk categories and countries. "For Lagardère Travel Retail, suppliers in two countries are particularly concerned by the EcoVadis assessment: China (99% of purchasing expenditure classified as 'at risk') and Senegal. For Lagardère Publishing, the countries concerned are China (89% of purchasing expenditure classified as 'at risk'), Mexico, India and Morocco" (page 159).
Lagardère Publishing (pages 159-160). "Worldwide, Lagardère Publishing carries out annual compliance audits at certain suppliers' premises and production sites, with sanctions imposed in the event of non-compliance. This measure is supplemented by EcoVadis documentary audits." Hachette UK is a member of the Book Chain Project and publishes an annual Anti-Slavery and Human Trafficking Transparency Statement.
Lagardère Travel Retail (page 160). The Responsible Offer programme requires suppliers to clear pre-requisites: "In 2025, more than 60 brands had met these pre-requisites by securing a B-Corp certification, an EcoVadis badge or medal, or a positive response to the ESG questionnaire." Product criteria include the fair trade label.
Both divisions state the actions involve no significant OpEx or CapEx.
S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: pages 158 and 190 (sections 2.3.2.1 and 2.4.1.2.3), listed in the ESRS content index against section 2.3.2.1 (page 198).
Target used. The S2 summary table on page 158 records the target as "Have 80% of group-wide expenditure related to suppliers presenting high CSR risks assessed in 2025 (see section 2.4.1.2.3)". The target table at page 190 sets the trajectory: 67% of expenditure related to at-risk suppliers assessed in 2024, 80% in 2025, 85% in 2026, type relative, scope "All 'at risk' suppliers of Lagardère Publishing, Lagardère Travel Retail, Lagardère News and Lagardère Radio", baseline 31% in 2021.
2025 result: 91% (page 190), against 61% in 2024 and 54% in 2023 (page 192), so the 80% target was exceeded.
No S2-specific target. The company states plainly: "The Group has not set a target for the 'Workers in the value chain' sustainability matter, as local action at division level is considered the best way to address this issue" (page 159). The EcoVadis coverage target therefore does the work of an S2 target through the supplier assessment programme rather than through an outcome measure for value chain workers.
S4 – Consumers and End-users
S4-1Policies related to consumers and end-usersReported
Policies related to consumers and end-users
Reference: pages 162, 164, 166, 177-178 (sections 2.3.3.1.2, 2.3.3.1.3, 2.3.3.2.2, 2.3.3.3.2, 2.3.3.4.2).
Food safety (Travel Retail, page 162). "The division's policy is based primarily on Food Safety Guidelines, which are distributed to all countries in which it operates. These regularly updated guidelines are based on European food safety standards. They impose strict rules that are sometimes even more demanding than local regulations in certain countries - notably Africa and China." The policy runs in three stages: preventing, detecting and limiting non-compliance; defining corrective action plans; and managing crises in real time. It is "developed and managed centrally by Lagardère Travel Retail's Quality Control team, with the support of SGS, Eurofins and EcoSure".
Data protection (News and Radio, pages 177-178). A personal data protection policy aligned with the GDPR covers procedures, governance, the processing register, legal compliance, training, user requests, security risks and data breaches, with a Data Protection Officer appointed for dealings with the CNIL.
Declared gaps. Lagardère Live Entertainment "does not have a formal policy as required by ESRS, as the general health and safety objectives are not yet integrated into ESRS-compliant documentation" (page 164); Hachette Livre states the same for education and access to culture (page 166).
S4-2Processes for engaging with consumers and end-users about impactsReported
Processes for engaging with consumers and end-users about impacts
Reference: pages 163, 165, 179 (sections 2.3.3.1.2, 2.3.3.1.3, 2.3.3.3.2, 2.3.3.4.2).
Travel Retail (page 163). "Lagardère Travel Retail has not established a specific process for engaging with its consumers or their potential representatives. Given that its main customers are located in transit points such as train stations and airports, it is more difficult to establish a stable, recurring basis for engagement." Surveys are run during tenders before outlets open.
Travel Retail feedback tools (page 163). The WellDone platform's Visibilishop module "centralises customer reviews from well-known platforms such as Google, Tripadvisor, Yelp and The Fork", with an "overall average score of 4.20 out of 5 in November 2025, compared with 4.19 at the end of 2024".
Live Entertainment (page 165). "Lagardère Live Entertainment has not set up any formal engagement platform with spectators", but each entity has a customer service department, and since end-2025 it "has conducted satisfaction surveys among audiences, service providers, productions and venue employees".
News and Radio (page 179). "Engagement with consumers occurs on a daily basis via the contact address... to which consumers can send requests to exercise their rights", with effectiveness assessed "by tracking rights requests and the responses they receive".
S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concernsReported
Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reference: pages 163, 165, 179-180 (sections 2.3.3.1.2, 2.3.3.1.3, 2.3.3.3.2, 2.3.3.4.2).
Travel Retail (page 163). "A specific procedure has been defined for local managers of Dining activities to handle consumer feedback and manage the products at issue. Local managers pass on information internally to the Quality Control managers at head office when incidents have had a major impact on consumer health and safety." Reviews are answered by local managers through the WellDone platform.
2025 outcome (page 163). "Three consumer-related incidents were reported through the whistleblowing mechanism in 2025. One of the incidents concerned discrimination and two related to health and safety. One incident was deemed substantiated, the other two as unsubstantiated."
Live Entertainment (page 165). "Every incident in venues is reported to Lagardère Live Entertainment's Legal Department and General Management, who analyse it and implement the necessary corrective measures... A report is drawn up after each event." "There were no material negative impacts relating to the health and safety of consumers that required specific action in 2025."
News and Radio (pages 179-180). A single dedicated e-mail address lets consumers exercise rights of "access, rectification, erasure, limitation, deletion, portability, objection and withdrawal of consent", escalated to the DPO.
S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actionsReported
Taking action on material impacts on consumers and end-users
Reference: pages 162-166, 171-172, 177-179.
Food safety (pages 162-163). Four pillars: daily hygiene and safety checks digitalised through Eezytrace, TraQ'Food in France and KTI in the United States; an annual audit plan of "four audits per year based on a common audit grid specific to each business line", two external with SGS, Eurofins or EcoSure and two internal, plus head-office administrative audits ("19 countries audited in 2024 and 22 in 2025") - "bringing the total number of audits carried out in the Dining network to over 93,000 in 2025"; laboratory analyses of products, surfaces and people at least twice a year at every food-preparation outlet; e-learning rolled out to Cambodia and Peru in 2025; and full deployment of the WellDone platform across Dining. Spectator safety (pages 164-165). All venues are type L category 1 public-access buildings subject to the 25 June 1980 decree; annual evacuation training; a first responder team at the Arkea Arena and a doctor on call at the Paris venues; safe places since 2024; and ten hearing-risk prevention campaigns a year with Acuitis.
Education, culture and pluralism (pages 166-172). Accessibility work at Hachette Livre - 29,018 audiobooks in the catalogue at end-2025, 100% of digital books in ePub3 Level 1 and 98% Level 2 (page 182) - plus the Hachette Foundation for Reading and the Jean-Luc Lagardère Foundation.
S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: pages 162, 165, 166, 177 (sections 2.3.3.1.2, 2.3.3.1.3, 2.3.3.2.2, 2.3.3.3.2, 2.3.3.4.2).
One quantified target, on food safety (page 162). "Specific targets are set to make sure that the health and safety criteria established by Lagardère Travel Retail are respected. For example, a minimum score of 85% is required for internal and external audits carried out locally at all Dining points of sale. In 2025, 1,302 food safety audits were carried out, resulting in an average score of 91.9% across all assessments. This percentage is calculated using a standard audit grid applicable to all countries... The target is renewed each year, subject to the same requirements."
A customer satisfaction aim is also stated: "Lagardère Travel Retail is aiming for an average customer satisfaction score of 4.5 out of 5", against 4.20 in November 2025 (page 163).
No target on the other three S4 matters. For spectator safety, "No target has been set for this sustainability matter, as no objective is required to manage it. Actions are carried out and supervised at local level" (page 165). The material IRO summary tables for contribution to education and access to culture (page 166) and for data protection (page 177) both show a dash in the Target column, so no target is set for either.
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 184-186 (section 2.4.1.2.1 "Ethical business conduct at Lagardère (G1-1)").
Corporate culture. "Ethical business conduct is a strategic priority for the Lagardère group, and is anchored in its corporate culture. 'Fostering a culture of trust' is the fourth pillar of the Group's CSR strategy, which commits to growing its business in accordance with the leading quality, compliance and ethical standards." Arnaud Lagardère states in the Anti-corruption Code of Conduct, "compliant with the UN Convention against Corruption (UNCAC)", that the Group's success is "based on a set of strong principles and values... an integral part of our identity".
Policy set. "The rules laid down within the Group for the conduct of its business with all its stakeholders are set out in the Anti-corruption Code of Conduct, the Responsible Supplier Charter and the guidance on lobbying."
Whistleblowing. A secure Ethics Line open to "all of its employees, shareholders, service providers, suppliers and customers", multilingual and 24/7, allowing anonymous reports, with "a commitment not to retaliate against the whistleblower". Beyond that procedure, "the Group Internal Audit Department may be asked to investigate incidents relating to business conduct", with the Audit Charter guaranteeing "the fundamental principles of integrity and impartiality in investigations" (page 185).
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers
Reference: pages 188-190 (section 2.4.1.2.3), listed in the ESRS content index (page 199).
Responsible Supplier Charter. Drawn up on the OECD Guidelines and ILO conventions, it is "a key element of this strategy... a component of the supplier relations policy, headed by its Secretary General". It rests on five pillars: social values; environmental values, including compliance with "Regulation (EU) 2023/1115" on deforestation-linked commodities; ethical business conduct; reducing the risks of economic dependence, under which suppliers undertake to avoid "voluntarily maintaining themselves in a situation of economic dependence with the Lagardère group"; and CSR performance assessment (pages 188-189).
"The Charter is intended to be included in tender documents and specifications... as well as in several types of contracts... which must stipulate that its provisions have contractual value." "The ability of suppliers to sign up to and comply with the rules... is a determining factor when deciding to... continue a business relationship."
EcoVadis (page 189). Assessments target the highest-risk categories, most exposed countries and largest spend. "Depending on the results obtained, certain suppliers may be asked to implement action plans", and the score sets the reassessment frequency. 91% of at-risk supplier expenditure was assessed in 2025, against 61% in 2024 and 54% in 2023 (pages 190, 192).
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: pages 185-188 (section 2.4.1.2.2 "Prevention of corruption (G1-1, G1-3, G1-4)").
Policy. "The Group's anti-corruption policy is based on its Anti-corruption Code of Conduct, which was updated in January 2023. Its general aim is to reiterate the Group's ethical standards and its 'zero tolerance' of corruption." It is supported by "a new IT system for third-party due diligence, which the Group rolled out across all its entities in 2025", and by an anti-corruption risk map "updated for all the Group's activities in 2025". The Group Secretary General is responsible for the policy; the Chief Compliance Officer is its operational head (page 185).
Functions at risk (page 186). "Purchasing, Sales, the people in charge of sponsorship and patronage, and the business development teams in charge of calls for tenders." "The Risk, Compliance and Internal Control Department submits an annual progress report on its anti-corruption and internal control systems to the Audit Committee, which prepares a report for the Board of Directors."
Training (pages 186-188). A 30-minute e-learning module "translated into some ten foreign languages", requiring a minimum score of 80%, mandatory for new joiners and repeated every two years. "The baseline workforce in 2025 was 16,493 employees, 10,790 of whom occupy at-risk functions." Coverage: 14,886 trained overall (90%) and 9,847 in at-risk functions (91%).
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct (part of MDR-T/GDR-T disclosures)
Reference: pages 186-187 and 190. The statement was prepared under the 2023 ESRS, where G1 had no standalone targets DR, so business conduct targets fell under MDR-T. Lagardère sets two, each with a trajectory, baseline, scope and result.
Anti-corruption training completion (pages 186-187). "As part of the monitoring of actions to prevent corruption, the Group sets an annual target for the employee completion rate of the anti-corruption training module. Initially set at 70% in 2024, this target has been gradually increased and has been set at 80% for end-2026." The target table gives: 70% at 31/12/2024, 75% at 31/12/2025, 80% at 31/12/2026, type relative, scope "Workforce covered by the Lagardère group's social reporting, excluding the cases listed above", baseline 87% in 2024, 2025 result 90%. "In 2025, 90% of the baseline workforce had completed the training module, well above the initial target of 75%." The target "is monitored by the Group's Human Resources and Compliance teams", and "The Audit Committee is informed of these monitoring arrangements."
Supplier assessment coverage (page 190). "67% of expenditure related to 'at risk' suppliers assessed in 2024; 80%... in 2025; 85%... in 2026", type relative, scope all at-risk suppliers of Publishing, Travel Retail, News and Radio, baseline 31% in 2021, 2025 result 91%.
The G1 summary table (page 192) tracks both.
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: pages 186-188 (section 2.4.1.2.2) and the summary table on page 192, listed in the ESRS content index as DR G1-4, confirmed incidents of corruption or bribery (page 199).
Metrics (pages 188, 192), 2025 with 2024. Number of convictions for violation of anti-corruption and anti-bribery laws: 0 (0). Amount of fines for violation of anti-corruption and anti-bribery laws: 0 (0). Both are footnoted "Data reported for the first time in 2024".
Detection and handling (page 186). "Preventive procedures... include training, third-party assessments and controls. Potential incidents of corruption are detected through the whistleblowing procedure and related controls. Where allegations are confirmed, they are dealt with by means of sanctions, remedial measures and action plans." Investigations remain strictly confidential and independent.
"Non-compliance with anti-corruption procedures and standards and incidents of corruption are remedied by action plans and disciplinary sanctions. The analysis resulting from the internal investigation enables the remedial action(s) and sanction(s) provided for by internal rules or their local equivalent to be defined on the basis of the confirmed facts."
The report gives a nil return on convictions and fines; it does not separately state a number of confirmed incidents.
G1-5Political influence and lobbying activitiesReported
Political influence and lobbying activities
Reference: pages 190-192.
Prohibition. "all Group employees... and all entities forming part of the Group, are prohibited from making any: direct political contributions as defined in ESRS G1-5, i.e., any 'financial or in-kind support provided directly to political parties, their elected representatives or persons seeking political office'... [or] indirect political contributions" (page 190). The standard's definitions of donations, loans, sponsorships and advertising are quoted in full.
Registers (page 191). The Group discloses its French HATVP register entry and its European Union Transparency Register identifier, RT 534834216948-42.
Topics (pages 191-192). Areas span live performance regulation; radio and press matters including neighbouring rights and press distribution; travel retail customs and duty-free rules; and publishing copyright. 2025 focused on the Protocol to Eliminate Illicit Trade (MOP 4), copyright exceptions, tax-free shopping in the UK and artificial intelligence - "transparency regarding the content used to train AI engines, recognition of a right to opt out and remuneration of copyright holders".
Revolving door. "No members have been appointed to the Board of Directors of Lagardère SA in the past two years who have held comparable positions in public administration... in the two years preceding their appointment" (page 192). No monetary lobbying spend is disclosed.