NOS

The role of the administrative, management and supervisory bodies

Worker representation in governance and supervisory bodies

(GOV-1_03) The composition of governance, management, and supervisory bodies does not currently include direct representation of salaried workers or other employees. The company's governance structure follows the reinforced Latin model, in which members of the Board of Directors, Executive Committee, and associated committees are elected by shareholders or appointed based on their competencies and experience relevant to their roles.

Nevertheless, the company promotes policies and initiatives to enhance representation and diversity in its management positions, including a commitment to achieving 40% female leadership representation by 2030. The company also ensures structured dialogue with employees through internal communication channels and inclusion-promoting practices.

Competencies and training of governance and supervisory bodies

(GOV-1_04 / GOV-1_15 / GOV-1_16 / GOV-1_17) Members of the company's governance, management, and supervisory bodies possess extensive experience relevant to the sectors, products, and geographical markets in which the company operates.

The Board of Directors comprises 15 members with decades of experience in telecommunications, information technology, corporate management, and innovation, covering essential competencies for operating in the company's markets. The Executive Committee includes professionals with specialised backgrounds in technology infrastructure, telecommunications services, marketing, financial management, and compliance, all of which are critical for the company's strategic and operational development. Some members also have direct experience in international markets and managing complex operations, ensuring a global vision aligned with the company's ambitions.

The company's governance, management, and supervisory bodies recognise the importance of ensuring adequate expertise to oversee sustainability matters. To ensure this capability, the company adopts the following approaches.

Recruitment and appointment of qualified members

The selection and appointment process considers diversity of expertise, as outlined in the Internal Policy for the Selection of Governance and Supervisory Body Members, including specific knowledge in sustainability and ESG (Environmental, Social, and Governance). This ensures that members possess relevant experience to oversee the company's critical strategic issues.

Continuous skills development

The competency matrix of the Board of Directors is regularly updated and complemented by continuous training, ensuring that governance bodies have the specialised knowledge required to oversee ESG matters. Through the NOS Campus Corporate Academy, dedicated training programmes are provided to develop competencies in strategic areas, including Advanced Analytics, Generative Artificial Intelligence (Generative AI), and ESG practices. These programmes are regularly updated to incorporate the latest trends and regulatory requirements, strengthening the Board's ability to supervise sustainability-related issues.

Internal Support Committees

In addition to the recruitment and appointment of members with suitable profiles, the company strengthens its ESG oversight capacity through internal support committees, such as the Corporate Governance and Sustainability Committee. This committee, composed of members of the governance bodies, ensures alignment with regulatory requirements and monitors the implementation of ESG initiatives, guaranteeing compliance with ESRS standards and the company's strategic objectives.

External Consultancy and Support

To complement its internal expertise, the company engages external consultants and auditors whenever necessary, ensuring the quality and robustness of strategic decisions related to sustainability.

Through these measures, the company ensures that its governance, management, and supervisory bodies are well-equipped to oversee and promote sustainable practices, contributing to compliance with ESRS standards and the creation of long-term value.

Governance bodies, structures, and defined responsibilities for ESG management

(GOV-1_08 / GOV-1_09 / GOV-1_10 / GOV-1_11) NOS structures its sustainability management within an integrated framework of governance bodies, committees, and departments, ensuring a coordinated and cross-functional approach to ESG strategy implementation. In addition to these governance bodies and committees—whose sustainability-related responsibilities are described and available for reference on the company's website—the operational execution of the ESG strategy is carried out by business units and dedicated structures, operating under the supervision of NOS governance bodies and committees. This coordination ensures effective strategic alignment, enabling a consistent and integrated implementation of the company's sustainability commitments.

Oversight of ESG impacts, risks, and opportunities

(GOV-1_12 / GOV-1_13 / GOV-1_14) Detailed information on the oversight of ESG impacts, risks, and opportunities at NOS can be found in the Corporate Governance Report, section III. Internal Control and Risk Management.

Diversity of the Board of Directors

(GOV-1_01 / GOV-1_02 / GOV-1_05 / GOV-1_06 / GOV-1_07) The composition of the Board of Directors reflects the company's commitment to diversity and inclusion, incorporating a range of experiences and profiles that ensure effective strategic oversight.

The Board of Directors is composed of 15 members, comprising 7 executive members and 8 non-executive members, ensuring a balance between operational leadership and strategic oversight.

This distribution ensures a balance between operational leadership and strategic oversight. Regarding gender diversity, the composition of the Board of Directors is as follows:

• 66.67% male members (10 members)
• 33.33% female members (5 members)

In 2024, the gender diversity index within the Board of Directors was 0.50.

Integration of sustainability-related performance in incentive schemes

Overview

NOS recognises the importance of aligning the incentive schemes and remuneration policies of its executive directors with the sustainability objectives defined in its strategic plan. The company has implemented mechanisms that integrate ESG (Environmental, Social, and Governance) aspects into performance evaluation and the variable incentive schemes of governance, management, and supervisory body members.

Roles covered

The sustainability-linked incentive schemes apply to executive directors.

Variable remuneration structure

NOS executive directors have a variable remuneration component, corresponding to 50% of the total remuneration, which is determined based on two types of indicators:

1. Collective business performance indicators (70% of the variable component): Includes metrics related to the overall performance of the company across different business areas.

2. Qualitative individual performance indicators (30% of the variable component): Includes the achievement of ESG objectives set out in the company's strategic plan.

Sustainability KPIs and weighting

Although ESG objectives are part of the qualitative assessment, there are currently no specific KPIs exclusively defined for direct evaluation of remuneration.

ESG objectives represent 30% of the variable component, which itself represents 50% of total remuneration. This means ESG objectives account for approximately 15% of total remuneration for executive directors.

Link to sustainability objectives

The performance of executive directors is evaluated considering the ESG objectives defined in NOS's strategic plan. These objectives, aligned with the company's sustainability commitments, include qualitative aspects that reflect the integration of sustainability principles into business management and operations.

However, sustainability-related performance metrics are not used as specific reference indices in the calculation of variable remuneration.

Approval and review process

The conditions associated with the incentive schemes of executive directors are approved by the Board of Directors, based on the recommendations of the Remuneration Committee. This approval process ensures that the incentive schemes are aligned with the company's strategic objectives, including those related to sustainability.

The review of the conditions is conducted periodically, ensuring continuous adaptation to the organisation's needs and market developments, while maintaining NOS's commitment to ESG principles and sustainable performance.

Performance period and target structure

Not disclosed.

Threshold/target/maximum performance definition

Not disclosed.

Disclosure of payout against sustainability KPIs

No disclosure of actual payout against sustainability KPIs in the reporting period.

NOS Strategy and Business Model

NOS is the leading national Telecommunications and Entertainment Group, with two main business areas:

Telecommunications (1,629.1 M€ Revenue, 720.9 M€ EBITDA)

NOS is the leader in Portugal in mobile network quality and 5G coverage, reaching more than 99.6% of the population, and has one of the largest fibre optic (FttH) infrastructures, present in thousands of households. As a convergent operator, it offers an integrated and innovative ecosystem of fixed and mobile solutions – internet, television, entertainment, voice, and data – for both residential and business customers, with a strong focus on the best user experience and technological innovation.

In the residential market, particularly in subscription TV services, NOS stands out for its innovation in entertainment, with services such as UMA TV and the NOS TV App, which are widely recognised by consumers for their quality. Additionally, we have introduced services such as eSIM and integrated home security solutions.

For the business segment, NOS provides a comprehensive portfolio of advanced solutions, including telecommunications, IoT, Cloud, and cybersecurity, tailored to the needs of each sector. Our next-generation network supports various digital transformation projects, such as smart cities and sustainable mobility.

Media and Entertainment (102.2 M€ Revenue, 46.7 M€ EBITDA)

NOS Cinemas: With 218 screens across Portugal, NOS Cinemas is the leader in film exhibition nationwide, as well as in screening alternative content (opera, ballet, theatre, football, concerts, and other live or recorded events).

NOS Audiovisuais: Operates in the distribution of audiovisual works, both in Portugal and in Portuguese-speaking African countries (PALOP), particularly Angola and Mozambique.

Value Chain

NOS operates through multiple business areas including telecommunications infrastructure, content distribution, retail services, and entertainment venues. The company maintains strategic partnerships and joint ventures including Sport TV (25% stake), ZAP (30% stake), and Dreamia (50% stake).

Interests and views of stakeholders

Stakeholder engagement model

NOS recognises the importance of continuous and structured stakeholder engagement to promote shared value creation and strengthen trust-based relationships. This commitment is reflected in the company's stakeholder engagement model, which is permanently implemented and aligned with international best practices. This model is based on four guiding principles, covering different levels of engagement, ranging from monitoring to cooperation, enabling the identification of concerns, expectations, risks, and opportunities.

Key stakeholder groups

The mapping and prioritisation of NOS's stakeholders is conducted in accordance with the AA 1000 SES standard, based on the criteria of influence and dependence. This process takes place before each stakeholder consultation cycle and is reflected in the company's management structure, development strategy, and operational policies. The stakeholder categories include:

B2C and B2B Customers

• We place our customers at the centre of our actions and decisions, continuously striving to efficiently and effectively meet their needs.
• We connect families, businesses, and the country through cutting-edge telecommunications services.
• We constantly surprise our customers with relevant innovation, anticipating their needs.

Shareholders and Investors

• We uphold a culture of operational excellence, discipline in asset management, and rigour in delivering results.
• We honour our commitments to shareholders, maintaining a solid financial performance.
• We are optimistic about the future and ambitious in the goals we set as a company.

Employees

• We uphold a non-negotiable commitment to ethics, rigor, inclusion, and meritocracy at all times and in every context.
• We promote a sustainable balance between personal and professional life, laying the foundation for work models adapted to the new reality and more sustainable practices.
• We invest in talent retention, training, and attraction, ensuring that we have the necessary skills to meet both today's and tomorrow's challenges.
• We believe in the value of diversity and are committed to strengthening our efforts toward an even more inclusive future.

Partners and Suppliers

• We are fair and transparent in our relationships with all partners, striving to reach agreements that maximise value for all parties.
• We expect our partners to uphold values that align with our own.

Regulatory and Government Authorities

• We work closely with regulatory authorities, ensuring compliance with established guidelines.
• We continuously invest in technology and sustainability, contributing to the country's development and societal well-being.
• We maintain an open dialogue with key regulatory bodies, going beyond compliance to increase awareness in the telecommunications sector.

NGOs and Local Communities

• The community is at the heart of our actions.
• We promote social and digital inclusion through educational projects and sustainable initiatives, aiming to reduce inequality and improve the quality of life within society.

Institutions

• We lead innovation and sustainability in the industry, investing in advanced technologies and ESG practices, ensuring that our operations and partnerships foster sustainable growth and competitiveness.

Media

• We build strong and trustworthy relationships with the media, recognising their essential role as a source of information, knowledge dissemination, and public debate.
• We maintain regular and proactive communication with the media.

Purpose of stakeholder engagement approach

We have developed a stakeholder engagement model, which we implement on a permanent basis, to enhance shared value creation and establish trust-based and responsive relationships.

The stakeholder categories that are integrated in the NOS stakeholder relationship model reflect the main influence and dependency relationships with the stakeholders, considering the characteristics of NOS' business. The model is organised into four guidelines, which cut across different levels of engagement, from monitoring to cooperation. These allow us to map the current concerns and future expectations of the stakeholders, which may substantiate new risks or opportunities, and to use them as input for informed decision-making. They also enhance the creation of shared value and the establishment of trusting and responsive relationships. It is also our purpose, within the scope of accountability towards our stakeholders, to report, with materiality and balance, and cooperate in building a more sustainable value chain, and therefore promoting shared value.

A systematic and responsive interaction allows identifying and anticipating risks and opportunities and establishing the necessary bonds of trust to enhance the creation of shared value in the long term. Implementation of the stakeholder engagement model is conducted by each of the functional areas responsible for interfacing with each category of stakeholder. The satisfaction of critical stakeholders regarding NOS, such as customers, is one of the criteria included in the performance evaluation of employees with customer interface responsibilities.

Stakeholder engagement process

1. We stay attentive – understanding what matters most to our stakeholders

The regular and systematic engagement of our key stakeholders allows us to understand how we impact them, as well as their expectations and needs. The subsequent analyses we conduct allow us to capture an integrated view of our impacts, which we use to support business management. Stakeholder consultation is carried out by each of the functional areas. For some stakeholder categories, such as shareholders, it is centrally managed by the investor relations and sustainability department. For others, such as customers, NOS conducts ongoing consultations across different customer segments. Stakeholder consultation is conducted by different functional areas, taking into account the customer segment and the reason or purpose of the consultation, which may occur in a post-sales context or as part of a standardised consultation process. NOS uses the Net Promoter Score (NPS) as one of the key indicators to measure customer satisfaction. Additionally, there are specific customer satisfaction surveys, conducted in response to specific events in the customer journey.

NOS also conducts an employee satisfaction index. The results of these indicators are analysed in dedicated forums, involving senior management and administration. The process of analysing these results allows us to monitor progress across multiple parameters and identify opportunities for improvement in the management model and existing programmes/initiatives to enhance performance.

Key stakeholder concerns and views

3. We communicate – the channels we use to engage with our stakeholders

Stakeholder engagement relies on a variety of channels, selected based on the engagement objective and the target audience. In this regard, we complement the use of broad-reaching channels, such as our website, with more targeted approaches, such as roadshows for investors. Additionally, we select the most suitable tools for different levels of engagement. When the priority is informing, we use annual report publications or internal and market-focused publications. To gather feedback, we conduct employee climate surveys, customer satisfaction studies, and supplier/partner satisfaction assessments. In cases where stakeholder participation is required, engagement takes place through onboarding sessions for new employees or regulatory meetings.

The frequency of communication also depends on the objective of interaction. For this reason, we use communication channels that operate continuously or daily, such as our website, apps, or physical stores. Meanwhile, other mechanisms function on a campaign-based model, following a specific periodicity—annually or even multi-annually—such as the stakeholder consultation process used to identify priority sustainability topics.

Stakeholder consultation has taken place during the planning phase of each new strategic cycle, with the latest occurring in 2024, in preparation for the 2025 strategic cycle. In other cases, consultations may occur on demand, in response to specific needs, such as direct interactions with regulators.

While functional departments/areas are responsible for managing relationships with specific stakeholder groups—for example, Human Resources with employees or Procurement with suppliers—and do so in coordination with the Executive Committee members overseeing their respective areas, the implementation of the stakeholder engagement approach remains a company-wide responsibility. This engagement is led by the management team's commitments to stakeholders and is supported by a variety of communication and interaction mechanisms.

4. Moving forward together – our partnerships, alliances, and strategic external initiatives

We challenge ourselves to do better, in cooperation with other organisations. The partnerships we establish allow us to act in alliance with our stakeholders, promoting a more inclusive and sustainable society, aligned with science-based climate targets and Human Rights.

The flagship initiatives that NOS has signed, as well as the partnerships it supports or promotes, drive its strategic commitment to sustainability, in line with the spirit of SDG 17. Our commitment to sustainability is endorsed at the highest level of the organisation and is reflected in the various international and national initiatives that NOS has subscribed to over the years, under the leadership of the CEO, and to which the company remains committed. These initiatives reinforce the commitments undertaken by the management team and are based on principles and commitments for responsible and proactive action in the environmental, social, and governance domains. They are further supported and complemented by our internal policies and codes of conduct.

The initiatives and partnerships are structured into the following categories: Sustainable Society, Climate, Human Rights, Strategic Partnerships, and Cultural Support.

1. Sustainable Society

NOS has subscribed to and joined a range of initiatives that promote a more sustainable economy and society. In addition to cross-sector initiatives, which bring together companies and organisations from various economic sectors, we have also engaged in sector-specific initiatives tailored to our industry.

ZERO1

• The ZERO1 Project, NOS's flagship digital empowerment initiative, was created in partnership with ENSICO with the goal of bringing free computing education to schools across the country.

MUDA

• NOS is a founding member of MUDA – Movement for Active Digital Engagement, which was launched in 2017 to promote active digital citizenship among Portuguese citizens.

Membership in GRACE

• [Details not provided in excerpt]

Integration of stakeholder views into strategy and business model

NOS conducted an external stakeholder consultation to identify potential material topics. The process involved employees, suppliers and partners, customers, media, and the community, allowing the incorporation of diverse perspectives in defining the company's strategic priorities.

The identified impacts on communities not only influence but also continuously inform and shape the adaptation of NOS's strategy and business model. To ensure this alignment, the company has developed a stakeholder engagement model, implemented on a permanent basis, which enhances the creation of shared value and establishes relationships based on trust and responsive dialogue. The company employs regular and systematic mechanisms to assess stakeholders' needs and expectations, the impacts affecting them, the values they attribute, and the areas requiring improvement. The results of these mechanisms are systematised and analysed alongside sectoral trends and governance, environmental, and social benchmarks, ensuring a comprehensive mapping of stakeholder-identified impacts. This analysis enables NOS to gain a detailed understanding of the dynamics at play and align its actions with the values and principles that guide its activities.

The commitments made to stakeholders are periodically reassessed and adjusted based on insights gathered through these mechanisms. These inputs are prioritised and considered in defining strategic priorities, supporting the development of continuous improvement plans, cooperation dynamics, and partnerships. The identified priorities are integrated into operational management and the development of new initiatives. When significant impacts are identified, NOS implements specific approaches to prevent, mitigate, or remedy adverse consequences, ensuring that its strategy remains aligned with community needs.

This dynamic process ensures that NOS's strategy and business model remain continuously aligned with community needs, promoting resilience, inclusion, and sustainable value creation. By adopting this approach, the company consolidates a more responsible business model that is adaptable to changes in the social, environmental, and economic context.

Distinction between affected stakeholders and users of sustainability information

All materially impacted communities, whether directly affected by NOS's operations or its value chain, are included within the company's disclosure scope. This commitment ensures that no community is excluded, covering specific, geographic, or other groups. Detailed information on these communities, the impacts they face, and the approaches adopted by NOS is transparently documented, reflecting the company's seriousness in managing its material impacts.

Furthermore, NOS recognises that material impacts may affect communities at different points in the value chain, whether they are direct beneficiaries of the company's initiatives or face challenges arising from its activities. The company implements actions aimed at mitigating risks, generating opportunities, and creating shared value, fostering a positive and sustainable impact on the communities with which it interacts.

Initiatives that result in positive material impacts include promoting digital inclusion, technological innovation, and literacy, as well as actions aimed at protecting human rights and promoting environmental sustainability. These activities benefit communities across both ends of the value chain, reinforcing NOS's commitment to responsible, effective, and transparent management.

Monitoring and tracking mechanisms

To track and monitor the issues raised and addressed, NOS relies on two central elements of its management system: the ESG Scorecard and the Integrated Management System.

ESG Scorecard: Following the approval of NOS's 2025-2030 sustainability strategy, an ESG Scorecard was implemented, structured around key strategic pillars. This tool facilitates progress tracking and evaluation, systematically presenting results to the Executive Committee and the Board of Directors. A set of strategic KPIs enables the monitoring of strategy implementation, associated performance, and achievement of objectives.

Integrated Management System: Continuous improvement of processes and activities is a key element of NOS's organisational culture and the sustainability of its operations. Part of the company's commitment is to adopt market best practices, supported by internationally recognised management systems that adhere to this philosophy.

NOS's certified management systems cover the following areas:

• Integrated Management System:
  • ISO 9001: Quality Management System
  • ISO 14001: Environmental Management System
  • ISO 45001: Occupational Health and Safety Management System

Additionally, the company operates under the following Certified Management Systems:

• ISO 27001: Information Security Management System
• ISO 20000: IT Service Management System

Within the scope of these certified management systems, impact identification processes are implemented, along with programmes and initiatives to address these impacts. These systems are subject to audits and follow a continuous improvement cycle, ensuring the prevention and mitigation of the key negative impacts associated with NOS's business operations.

Communication channels for affected communities

NOS provides dedicated and accessible channels for affected communities, ensuring their effectiveness by leveraging business relationships to broaden the reach and impact of these initiatives. This commitment is reflected in the way the company establishes and maintains inclusive and responsive engagement with all stakeholders.

In addition to broad communication platforms, such as the website and mobile applications, NOS employs specific tools tailored to the characteristics of each affected community. These tools include permanent and accessible communication mechanisms, facilitating continuous dialogue and the structured collection of feedback. Furthermore, consultation processes are systematically conducted during strategic planning, ensuring that the needs of the most vulnerable communities are adequately incorporated into decision-making.

With this structure, NOS reinforces its commitment to amplifying the voices of affected communities, ensuring meaningful and responsive engagement at all stages of its decision-making process.

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

Material sustainability topics

As part of the preparation for its new strategic cycle, NOS conducted a broad reflection process aimed at identifying the most relevant sustainability topics for its operations. This process considered our business positioning and vision, the key sustainability drivers, the ESG impacts associated with our operations, and the expectations of our stakeholders.

The 2025-2030 Sustainability Strategy was developed based on the results of the stakeholder consultation with internal and external stakeholders, conducted in 2024, and an analysis of contextual factors such as regulatory challenges, market dynamics, investor expectations, compliance requirements, and the commitments made by the organisation. This process allowed us to identify four guiding pillars of our approach and 33 material IROs, which reflect the key impacts, risks, and opportunities of our business across ethical, environmental, and social dimensions.

The Sustainability Strategy is aligned with the Sustainable Development Goals (SDGs), highlighting those that are most interconnected with our business and where we can generate or influence a more significant impact. The approach adopted ensures the integration of ESG considerations into our decision-making process and strengthens our capacity to create sustainable value for both the business and our stakeholders.

Double Materiality Matrix

E1 - Climate Change: Impacts, Risks and Opportunities

Identification and assessment of climate change impacts

The main climate-related negative impact of NOS is the emission of greenhouse gases (GHG). NOS has conducted a comprehensive mapping of these emissions across its entire value chain:

• Own operations
• Supply chain
• Distribution, use, and end-of-life of products and services placed on the market

The process was carried out in accordance with the requirements of The GHG Protocol methodology for defining organisational and operational boundaries, in-scope GHGs, and emission sources to be included.

The company maintains a complete corporate emissions inventory, compiled annually and externally verified. It also assesses the potential evolution of emissions through projections that are periodically updated to incorporate the most recent business planning information and the implementation of reduction measures outlined in its climate transition plan.

NOS also evaluates the positive climate impact of the digital solutions it places on the market and that help reduce its clients's emissions (climate enabling effect).

Main climate risks and opportunities

The risks and opportunities related to climate change are integrated into NOS's risk management model. We have identified the material risks and opportunities and continue to deepen their characterisation to enhance the assessment of the climate resilience of our strategy and business model.

Identification and assessment of physical risks

The identification and assessment of climate-related physical risks uses elements of NOS's Enterprise Risk Management methodology, enabling for the identification of associated risks and opportunities and the definition of response actions. Climate-related physical risks are classified within the NOS Bussiness Risk Model (BRM) as operational risks and security and continuity risks. Depending on their nature, the analysis is conducted over different time horizons: short-term (e.g. exposure of the telecommunications network to wildfire risk) or medium/long-term (e.g. structural increase in average summer temperatures and its impact on the technical infrastructure).

The evaluation is conducted periodically, using predefined criteria to assign probability and impact levels, enabling risk prioritisation and the definition of appropriate responses. Risks exceeding the acceptance threshold (≥25) are integrated into the Annual Action and Resource Plans, approved by the Executive Committee. The assessment incorporates a climate projection-based approach for Southern Europe and the Mediterranean, based on IPCC scenarios, including high-emission scenarios (IPCC SSP5-8.5). However, the company has not yet carried out a comprehensive climate scenario analysis, and this process is currently under preparation.

NOS has defined time horizons for the assessment of physical risks, considering the lifespan of critical assets and strategic planning processes:

• Short-term (<1 year): includes the budget cycle and immediate risks, such as wildfires and extreme weather events already evident in the operating geography
• Medium-term (1-5 years): aligned with strategic planning and corporate objectives, includes risks such as regulatory changes and shifts in consumer preferences
• Long-term (>5 years): covers the analysis of structural impacts, such as rising average temperatures and their effects on network infrastructure and data centres

The analysis of asset and business activity exposure to climate-related physical risks uses consistent criteria to determine probability, magnitude, and duration of impacts, considering data from past events and future projections. A more granular exercise will be conducted as part of the climate scenario analysis currently under preparation.

Identification and assessment of transition risks and opportunities

NOS identifies and assesses climate transition risks and opportunities, focusing on regulatory risks, shifts in consumer preferences, and opportunities related to energy efficiency and sustainable finance. These risks and opportunities are analysed within the NOS BRM, considering three time horizons:

• Short-term (<1 year): immediate risks such as existing climate regulation and energy

Resilience of strategy and business model

Resilience analysis

The analysis of the resilience of NOS's strategy and business model to climate change is currently based on the assessment of:

i) the climate risks and opportunities to which the company is exposed;

ii) the respective implemented response mechanisms (risk management and mitigation processes, as well as opportunities maximisation).

This analysis incorporates elements of NOS's Enterprise Risk Management (ERM) methodology, including the Business Risk Model (BRM), which serves as a proprietary risk dictionary (taxonomy and risk drivers). The process enables the identification of risks, opportunities associated with risk-enhancing factors, the impacted business strategy pillar, and the definition of response actions to manage the most relevant risks.

The analysis covers the entire value chain of NOS's various business segments and recognises both climate change mitigation (GHG emissions from NOS's operations and value chain) and adaptation (resilience of telecommunications and IT infrastructure to acute and chronic physical impacts).

The characterisation of transition risks considered carbon price projections in public policy scenarios aligned with 1.5ºC decarbonisation pathways. The characterisation of physical risks took into account climate projections for Southern Europe and the Mediterranean region produced by reference entities. The analysis was conducted over short-, medium-, and long-term time horizons, defined based on the nature of the risk, as well as business processes and the lifespan of the company's critical assets.

Results

The company's strategy and business model possess resilience characteristics against the physical, regulatory, and market consequences of climate change, according to the conducted analysis.

The identified climate risks and opportunities influence our business strategy—shaping the products and services we bring to market and how we manage our operations and value chain—as well as our resource planning (revenues, capital costs, and operational costs).

NOS has adopted a science-based target, validated by the Science-Based Targets initiative, which aligns with a 1.5ºC scenario: a 90% reduction in operational emissions by 2030. The implementation of this target is supported by a comprehensive energy efficiency programme and new renewable electricity procurement models (currently under definition), which reduce exposure to major transition risks.

The exposure to physical risks is minimised through: i) Acute risks – strengthening Business Continuity Management and Network and Services Supervision processes, including enhanced fire risk management and response measures for extreme weather events; ii) Chronic risks – specific cooling management measures for key technical facilities.

Opportunities in products and services are captured through: i) The continuous expansion of NOS's portfolio of solutions that reduce customer emissions; ii) The energy efficiency programme across operations, leveraging resource efficiency opportunities; iii) The adoption of a Sustainability-Linked Financing Framework, which integrates the company's Science-Based Targets, enables access to new capital market opportunities, and enhances NOS's brand value and reputation.

NOS has the capacity to implement further adjustments to its strategy and business model, if necessary, to reinforce its resilience to climate change. NOS's climate transition plan positively impacts the company's access to funding. The sustainable financing framework, aligned with Sustainability-Linked Loan Principles (SLLP) and international best practices, establishes conditions linked to performance.

Compatibility of assets and activities with climate transition

NOS has not identified any assets or business activities that are incompatible with the climate transition. The company's key assets (technical infrastructure) and products (customer equipment) generate only indirect emissions from electricity consumption, which are minimised through the use of renewable electricity and energy efficiency measures. Furthermore, the company has activities covered by the European Union Taxonomy, with segments of its portfolio recognised as contributing to both climate change mitigation and adaptation.

E5 - Resource Use and Circular Economy: Impacts, Risks and Opportunities

The identification of impacts, risks, and opportunities related to resource use and circular economy is based on mapping the NOS value chain:

Own operations: The company assessed its main physical assets (telecommunications network and other technical infrastructure, logistics centre, back-office buildings, retail network, and cinema theatres) as well as the activities associated with these assets. NOS continuously monitors: material consumption at its logistics centre; the level of digitalisation of invoicing processes (for both suppliers and customers) and cinema ticketing; the production and routing of waste generated by its operations to licensed operators; and the sale of network components with reuse potential in secondary markets.

Upstream value chain: The most relevant product and service supplies from a circularity perspective (network equipment, customer equipment, and materials used in the logistics process) have been identified. The company has Life Cycle Assessment (LCA) results for most of the fixed customer equipment models it uses (TV set-top boxes and routers) and for an increasing percentage of mobile customer equipment (mobile phones). For fixed equipment, NOS also engages with manufacturers to reduce material use and increase the incorporation of recycled materials (e.g., recycled plastic in TV set-top boxes, routers, and remote controls).

Downstream value chain: The use and end-of-life of customer equipment have been assessed. NOS continuously monitors: the volumes and characteristics of mobile and fixed equipment provided to customers; the performance of its own take-back, refurbishment, and resale systems (already implemented for fixed equipment and being expanded for mobile equipment); and its contribution to integrated management systems for electrical and electronic equipment placed on the market.

A more detailed analysis is underway, covering each of NOS' business processes, to identify: i) Inputs and outputs of material resources; ii) Improvement opportunities related to reducing consumption, circular product and process design, using recycled and/or reused materials, and aligning waste management practices with the waste hierarchy. This analysis will serve as the foundation for defining NOS' circularity strategy, including its action plan, resource allocation, new performance targets, and monitoring metrics.

S1 - Own Workforce: Impacts, Risks and Opportunities

NOS's strategy regarding our employees reflects our commitment to responsible labor practices, aligned with the highest standards of sustainability and business ethics. For NOS, "own workforce" includes:

• Salaried employees: Workers with a direct contractual employment relationship with the company
• Independent workers: Individual contractors providing services directly to the company or workers supplied by entities engaged in temporary employment activities (NACE code N78)

We recognize that responsible management of our people requires a comprehensive approach that addresses the following key subtopics:

Working conditions: We are committed to providing safe and dignified working conditions that align with best labor practices. This includes strict compliance with national and international regulations, as well as the implementation of policies that promote workplace well-being, health, and safety.

Equal treatment and opportunities for all: We foster an inclusive and equitable culture, ensuring that all employees have access to fair opportunities while actively preventing and combating direct and indirect discrimination. Diversity and inclusion are central to our ESG strategy, and we are committed to measuring and reporting progress in this area.

Other labor-related rights: We ensure respect for fundamental labor rights, including freedom of association, the right to collective bargaining, and protection against any form of exploitation or harassment. These principles are reinforced through internal policies and ongoing compliance monitoring within our operations and supply chains.

Our strategic approach is directly aligned with NOS's Sustainability Management System (SBM), integrating the internal team as a key pillar for generating sustainable value. We believe that responsible people management is not only an ethical imperative but also a driver of innovation, productivity, and organizational resilience.

Mitigating negative impacts

NOS recognizes that inadequate working conditions, excessive work hours, or uncompetitive wages can negatively impact employees' quality of life and health. To mitigate these risks, the company has implemented:

• Fair and competitive wages, ensuring equity and competitiveness within the sector
• Flexible work policies, including adjustable schedules and hybrid work models that facilitate work-life balance
• Comfortable and well-adapted workspaces, providing a healthy and functional environment that enhances overall well-being

Promoting opportunities to boost productivity and motivation

NOS is committed to creating work conditions that enhance employee motivation and productivity. This commitment is reflected in:

• Work flexibility policies that promote a healthy balance between personal and professional life
• Mental health initiatives, such as well-being programs and support networks
• Diversity and inclusion initiatives, ensuring the right to self-expression while linking motivation to respect for each employee's individuality

These practices contribute to talent retention, reduced turnover, lower recruitment and absenteeism costs, and increased productivity and revenue.

Investing in skills development to retain talent

Continuous training and professional development are key pillars of NOS's strategy. This commitment leverages the opportunity to build a skilled, efficient, and productive workforce through:

• Technical training programs and digital/AI skill development, essential to keep up with digital transformation and future challenges
• Career plans and internal growth opportunities, reinforcing NOS's attractiveness as an employer of choice

These initiatives not only drive the company's productivity and growth but also enhance employee satisfaction and extend their average tenure within the organisation. This reinforces NOS's attractiveness as a leading employer while reducing costs associated with recruitment and the integration of new talent.

Material risks and opportunities

Investments in innovation and digital transformation create opportunities for upskilling and reskilling, strengthening employee competencies and enhancing market adaptability. Simultaneously, diversity, inclusion, and respect policies contribute to a positive and sustainable organizational environment.

However, competitive pressures and efficiency demands may pose challenges to employee health and well-being. NOS addresses these risks through mental health programs, continuous training, and a strong commitment to psychological safety.

S2 - Workers in the Value Chain: Impacts, Risks and Opportunities

NOS acknowledges that real and potential impacts on workers within its value chain stem directly from its strategy and business model, making responsible supply chain management essential. As such, the company is committed to ensuring that its network of suppliers and partners—both direct and indirect—aligns with its ethical, social, and environmental principles, guaranteeing not only the quality of products and services provided but also a continuously improving and more sustainable value proposition.

NOS's strategy defines priority products and services and the types of suppliers required to achieve its objectives, fostering strategic alignment through rigorous ethics and human rights criteria. To uphold this commitment, NOS requires its suppliers and partners to:

• Respect ethical principles and human rights: They must comply with the NOS Code of Ethics, the Code of Conduct for Corruption Prevention, the Sustainability Requirements for Suppliers and Partners, and the NOS Human Rights Policy
• Promote the dissemination of these values: They are encouraged to communicate and enforce the same high standards throughout their own supply chains, regardless of geographic or social complexities
• Ensure compliance with international human rights standards: Even in countries facing legal or social challenges, suppliers must uphold the rights outlined in the International Bill of Human Rights and International Labour Organization (ILO) conventions
• Avoid the use of minerals from conflict zones or any raw materials associated with exploitative practices or human rights violations
• Protect the environment and Indigenous peoples: Suppliers must secure free, prior, and informed consent from local communities before operating in certain areas and must minimize environmental impacts, particularly in protected areas or sensitive ecosystems
• Guarantee decent working conditions: They must ensure fair remuneration, workplace safety, and compliance with applicable labor laws

To reinforce the implementation of these principles, NOS has established monitoring mechanisms and corrective measures, including specific contractual clauses, regular audits, and secure, confidential reporting channels, enabling any irregularities to be reported and addressed effectively.

The identified impacts within the value chain inform and contribute to the continuous adaptation of NOS's strategy and business model. This commitment is reflected in the adoption of practices that ensure ongoing alignment with the company's sustainability and corporate responsibility principles, including:

• Active communication and collaboration with suppliers: NOS maintains regular dialogue with its direct suppliers, encouraging them to adopt policies and processes that align with its ethical principles. This collaboration aims to improve working conditions and promote sustainable practices across the entire supply chain
• Regulatory compliance and adaptation: The company continuously adjusts to national and European legislation, as well as international standards—including the International Bill of Human Rights and ILO conventions. This alignment reinforces the integration of sustainability and corporate responsibility values into NOS's business model
• Procurement Manual with supplier requirements: NOS has developed an internal Procurement Manual exclusively for its employees, outlining guidelines, recommendations, and rules for the responsible acquisition of products and services. This document ensures that the entire value chain follows directives that align with the company's internal policies
• Impact of fiscal and wage policies: The state budget and its associated measures directly influence fiscal and wage structures, affecting lower-skilled roles and workers

S3 - Affected Communities: Impacts, Risks and Opportunities

The actual and potential impacts on affected communities are deeply linked to NOS's strategy and business model, which are guided by strategic cycles focused on creating sustainable value and mitigating adverse effects. The company's actions are centred on what is most relevant for value creation, ensuring a positive and meaningful impact. The company's Sustainability Strategy, aligned with the United Nations Sustainable Development Goals (SDGs), directly reflects this approach and significantly contributes to 11 out of the 17 SDGs, given their strong interconnection with NOS's activities and positioning. This alignment translates into the company's ability to generate value and promote the sustainable development of society.

The 2025-2030 strategic cycle, NOS's fourth sustainability cycle, is structured around four fundamental pillars, two of which are directly related to communities:

"For a More Connected Society": aims to connect all communities safely and responsibly to next-generation networks. This commitment seeks to maximise the benefits of technological innovation and digital literacy, tackling isolation, reducing social and economic inequalities, promoting digital inclusion, and improving the quality of life for all populations.

"More for Our People": highlights NOS's role as a benchmark in protecting and promoting human rights, both within its internal operations and in managing relationships across its value chain, ensuring adherence to fundamental principles.

Additionally, the pillars "In the Name of the Planet" and "Responsible Leadership" complement this strategy. The first is committed to reducing environmental impact by fostering an organisational culture that leverages technology to minimise customers' environmental footprint and ensure business resilience in the face of climate change. This approach also extends to the company's value chain, reinforcing NOS's commitment to broadly reducing environmental impacts. The second positions NOS as a role model in ethical behaviour, strict compliance with fair competition rules across its markets, and transparency in both internal operations and relationships with partners and stakeholders.

The identified impacts on communities not only influence but also continuously inform and shape the adaptation of NOS's strategy and business model. To ensure this alignment, the company has developed a stakeholder engagement model, implemented on a permanent basis, which enhances the creation of shared value and establishes relationships based on trust and responsive dialogue. The company employs regular and systematic mechanisms to assess stakeholders' needs and expectations, the impacts affecting them, the values they attribute, and the areas requiring improvement. The results of these mechanisms are systematised and analysed alongside sectoral trends and governance, environmental, and social benchmarks, ensuring a comprehensive mapping of stakeholder-identified impacts.

S4 - Consumers and End Users: Impacts, Risks and Opportunities

The actual and potential impacts on consumers and end users are deeply interconnected with NOS's strategy and business model. The company adopts a customer-centric approach, developing next-generation telecommunications services that connect families, businesses, and communities, including those in more remote areas. This commitment translates into a continuous effort to provide efficient and effective solutions to meet the needs of consumers and end users, maximising shared value creation.

Managing both positive and negative impacts is a core pillar of NOS's operations, integrated into its governance structure, development strategy, policies, and operational programmes. This strategic alignment is guided by the United Nations Sustainable Development Goals (SDGs) and is reflected in NOS's 2025-2030 strategic cycle, particularly in the pillars "For a More Connected Society" and "Responsible Leadership". The former focuses on safely and responsibly connecting communities to next-generation networks, promoting digital inclusion, technological literacy, and the reduction of inequalities. The latter underscores the importance of ethical and transparent practices, ensuring that the company's operations align with social responsibility values.

NOS's strategy is shaped by ongoing analysis of macroeconomic trends and material risks and opportunities, ensuring value creation for its stakeholders.

The company offers an extensive portfolio of next-generation fixed and mobile telecommunications, as well as IT solutions tailored to different market segments:

• Consumer market (families and individual users)
• Enterprise market (ranging from small and medium-sized enterprises to large economic groups)
• Wholesale market (provision of wholesale data and roaming services at both national and international levels)

Accordingly, consumers and end users impacted by NOS's activities fall into the category (ii) users of services that may affect their rights to privacy, personal data protection, freedom of expression, and non-discrimination and, in the case of business customers, (iii) users who rely on accurate and accessible information regarding products or services.

User security and privacy

NOS recognises the challenges and risks associated with personal data privacy and information security, including the threat of cyberattacks that could compromise customers' sensitive data. These risks include threats such as ransomware, malware, and phishing, which have the potential to disrupt critical systems, leading to intrusions, data breaches, modifications, destruction, or other threats, whether from internal or external sources.

To mitigate these risks, in 2024, NOS reinforced its security and privacy measures, implementing robust cybersecurity solutions and strengthening vulnerability management practices. These measures include:

• Continuous threat monitoring and regular audits to ensure compliance with security standards
• Investment in artificial intelligence and machine learning for the early detection of malicious activity
• Ongoing awareness and training programmes for employees to foster a strong digital security culture

NOS also adopts an inclusive approach to ensure that all consumers and end users are considered and protected, with a particular focus on children and young people. The company provides features designed to promote a safe and inclusive digital environment.

G1 - Business Conduct: Impacts, Risks and Opportunities

Business Conduct is a key pillar of the company's ESG strategy, guiding the management of impacts, risks, and opportunities in an ethical, responsible, and transparent manner. Aligned with our Sustainable Business Model (SBM), this approach reflects the company's commitment to organizational practices that promote integrity, responsibility, and alignment with strategic objectives.

In the context of materiality analysis and the criteria set by the ESRS, the following priority subtopics of Business Conduct have been identified, which guide the company's actions:

• Corporate culture, which is based on values of integrity and ethics, promoting an inclusive and responsible working environment
• Political context and representation of interest groups, ensuring transparent and ethical interaction with institutional and political stakeholders, aligned with our corporate values
• Supplier relationship management, including payment practices, promoting a value chain based on ethical and sustainable relationships, with fair payment practices

The management of these subtopics is integrated into the company's internal processes to identify, assess, and mitigate impacts and risks. Regarding corporate culture, we continually reinforce the communication of ethical policies and practices at all levels of the organization. With regard to the political context, we ensure the rigorous monitoring of representation and lobbying activities, ensuring alignment with our ESG commitments and complete transparency. Lastly, in supplier management, we implement ESG criteria in selection and evaluation policies, ensuring that our value chain reflects our ethical and sustainability standards.

This approach to Business Conduct strengthens organizational resilience and the trust of our stakeholders, contributing to a sustainable business model aligned with the Sustainable Development Goals (SDGs).

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

Overview of the double materiality assessment process

At the beginning of each strategic cycle, and as part of its preparation, NOS conducts a broad reflection process aimed at identifying the most relevant sustainability topics within the context of its business. This analysis considers positioning and business vision, key sustainability drivers, and the priorities of stakeholders. Based on the findings of this double materiality analysis, NOS proceeds to define a new strategic positioning, identifying priority action pillars and corresponding commitments. At the same time, the key topics that will be the main focus of sustainability reporting throughout the cycle are established. During 2024, this process was conducted to prepare the current 2025-2030 strategic cycle.

Value chain mapping

IRO-1_01: The impacts, risks, and opportunities related to NOS's operations were identified across all departments and countries where NOS operates. The Double Materiality Analysis incorporated the entire upstream and downstream value chain. To ensure a comprehensive assessment of potential impacts, risks, and opportunities, NOS defined and characterised all activities included in its value chain.

NOS's value chain was grouped into three categories: upstream value chain, own operations, and downstream value chain. For each category, the main business activities, geographies, and stakeholders involved were determined. This analysis served as a basis for identifying potential impacts, risks, and opportunities and provided guidance on which stakeholders should be engaged in the Double Materiality Analysis process.

In the identification and evaluation of impacts, risks, and opportunities, their position within the value chain was classified as follows:

• Upstream value chain: Includes suppliers, service providers, strategic partners, network infrastructure, technology, and logistics, which contribute to the supply of essential goods and services for NOS's operations.

• Own operations: Covers telecommunications infrastructure, data centres, network operation and maintenance, NOS offices and stores, as well as the activities, products, and services directly managed by the company.

• Downstream value chain: Refers to the distribution and use of NOS services, including individual and corporate customers, commercial partners, and the broader community, as well as customer support and the social and environmental impacts of the services provided.

Stakeholder consultation

NOS conducted an external stakeholder consultation to identify potential material topics. The process involved employees, suppliers and partners, customers, media, and the community, allowing the incorporation of diverse perspectives in defining the company's strategic priorities.

Step-by-step methodology

IRO-1_02

Preparation of the Double Materiality Analysis

In the initial phase, NOS defined the scope of activities to be included in the Double Materiality Analysis (DMA), covering both its direct operations and its value chain. Based on this framework and the identified stakeholders, internal Subject Matter Experts (SMEs) were selected to participate in the process. The selection of SMEs considered their experience in different areas of sustainability, as well as their involvement in risk management and NOS's financial and sustainability reporting.

Identification of Impacts, Risks, and Opportunities

The identification of impacts, risks, and opportunities (IROs) was based on NOS's business model and sector, following the guidelines set by the ESRS. To build the list of potential IROs, NOS relied on the following elements:

• Priority topics identified in the previous Materiality Analysis;
• Sector benchmark analysis;
• External stakeholder consultation;
• Internal expertise of SMEs.

Materiality Assessment and Validation

The identified impacts, risks, and opportunities underwent a qualitative and quantitative assessment by SMEs, considering the scales and quantitative thresholds defined by NOS. This analysis was based on internally established criteria, ensuring the coherence and robustness of the process.

After consolidated validation by the SMEs and the project team, the results were approved by the Executive Committee.

Impact materiality assessment methodology

IRO-1_03 / IRO-1_04 / IRO-1_05 / IRO-1_06

As part of the identification and assessment of impacts, risks, and opportunities (IROs), NOS analysed all impacts associated with its business activities and value chain, categorising them based on their position within the chain: upstream value chain, own operations, and downstream value chain.

To ensure a comprehensive and representative assessment, the process was supported by the expertise of Subject Matter Experts (SMEs) and the insights gathered from external stakeholder engagement, ensuring that various perspectives were incorporated into the definition and evaluation of impacts.

Assessment criteria

The impact assessment followed a structured approach, considering the nature, origin, and time horizon of the identified impacts. Impacts were classified as positive or negative, real or potential.

• Real impacts: Those that have already occurred or currently exist.
• Potential impacts: Those that may occur in the future.

Additionally, impacts were categorised according to their relationship with NOS:

• Directly caused by NOS's operations, products, or services.
• Resulting from NOS's contribution, but not exclusively caused by its operations, products, or services, occurring in conjunction with third parties.
• Linked to NOS's operations, products, and services through business relationships.

Real impacts were assessed based on severity, while potential impacts were analysed considering severity and likelihood. Severity was defined as the sum of three factors: scale, scope, and irremediability. The assessment was conducted separately for positive and negative impacts, ensuring they were not offset against each other.

Scoring scales

In compliance with ESRS standards, quantitative scales were defined for assessing the materiality of impacts, risks, and opportunities.

• Impacts were assessed on a scale of 1 to 5, considering the scale, scope, remediability, and probability of occurrence.

The quantitative results of the impact assessment were determined by summing the scale, scope, and remediability scores, multiplied by the quantitative probability factor. The final value was then compared with the established materiality threshold, ensuring that the material impacts were consistent with NOS's strategy.

This framework ensures that the assessment aligns with NOS's strategy and enables a consistent and comparable analysis of impacts across the value chain.

Human rights perspective

Additionally, all negative impacts were assessed from a human rights perspective. To prioritise the severity of these impacts, particularly concerning NOS's workforce, supply chain workers, affected communities, and consumers, the probability of potential negative impacts was automatically set to 1.

Time horizons

The time horizon for impacts was classified into three categories:

• Short-term (<1 year)
• Medium-term (1-5 years)
• Long-term (>5 years)

Financial materiality assessment methodology

IRO-1_07 / IRO-1_08 / IRO-1_09 / IRO-1_10

As part of the identification and assessment of impacts, risks, and opportunities (IROs), NOS analysed the financial risks and opportunities associated with its business activities and value chain, categorising them based on their position within the value chain.

Furthermore, when reviewing identified material risks and opportunities, NOS considered interdependencies between impacts, risks, and opportunities, ensuring an integrated approach aligned with best risk management practices.

Scoring criteria

For evaluation, quantitative scales were defined:

• Risks and opportunities were assessed on a scale of 1 to 5, based on magnitude and probability of occurrence.

The quantitative results were determined by multiplying the magnitude score by the probability factor, then compared against a predefined materiality threshold, ensuring that identified risks and opportunities were aligned with NOS's strategy.

The analysis of financial risks and opportunities was conducted based on magnitude and likelihood of occurrence. Magnitude was defined by the potential impact on revenues and costs.

This framework ensures that the assessment aligns with NOS's strategic direction and enables a consistent and comparable analysis of impacts across the value chain.

Alignment with internal risk management

In the evaluation of risks and opportunities, comparability was ensured with the non-financial risk assessment methodology already used by NOS's risk management team. Thus, the financial values for magnitude, scale, and probability follow NOS's internal financial risk assessment criteria, ensuring consistency and integration with the company's broader risk analysis frameworks.

Inputs to the assessment

IRO-1_11 / IRO-1_12 / IRO-1_13

To guarantee that NOS's Double Materiality Analysis results were robust and well-founded, Subject Matter Experts (SMEs) were involved throughout the identification and evaluation of impacts, risks, and opportunities (IROs). SMEs were selected based on their expertise in specific sustainability areas, ensuring a technical and multidisciplinary approach.

Additionally, NOS's Risk and Compliance team, responsible for its corporate risk management methodology (Enterprise Risk Management), played a key role in defining the methodological approach, particularly in the structuring of financial materiality scales and thresholds. This ensured alignment with NOS's internal risk analysis frameworks. The Risk and Compliance team also actively participated in the evaluation and validation of risks and opportunities, reinforcing coherence and integration of the process with NOS's global strategy.

IRO-1_14 / IRO-1_15

Beyond external stakeholder consultations and sector benchmarking, SMEs provided both qualitative and quantitative data to support the exercise, ensuring a comprehensive assessment based on tangible insights. Simultaneously, the risk management team contributed expertise on potential risks and opportunities, ensuring that the evaluation process remained methodologically consistent with NOS's internal criteria.

Frequency and review

NOS has been monitoring sustainability topics for several years, conducting a Materiality Analysis in 2020 to identify priority topics. However, this was the first Double Materiality Analysis conducted in compliance with ESRS standards, making it incomparable with previous reporting cycles.

Materiality conclusions for specific ESRS topics

Materiality of ESRS E2, E3, and E4

As a result of the Double Materiality Analysis, NOS concluded that the topics covered by ESRS E2 (Pollution), ESRS E3 (Water and Marine Resources), and ESRS E4 (Biodiversity and Ecosystems) are not material to the company.

ESRS E2 - Pollution

NOS's business does not involve industrial processes or significant emissions of pollutants into the air, water, or soil. The environmental impact of its operations primarily results from energy consumption and direct and indirect greenhouse gas (GHG) emissions, as well as the use and end-of-life disposal of electrical and electronic equipment. These topics are already covered in ESRS E1 (Climate Change) and ESRS E5 (Resource Use and Circular Economy).

While pollution is not considered a material topic, NOS has implemented mitigation measures for its key impacts, including:

• Reducing its operational carbon footprint through energy efficiency measures in its facilities, progressive electrification of its fleet, and increasing renewable energy consumption.
• Responsible management of electrical and electronic waste, ensuring that decommissioned equipment is either recycled or reintegrated into the value chain.

ESRS E3 - Water and Marine Resources

NOS does not operate in sectors with high water consumption and has no activities directly impacting marine resources. All water consumed comes from municipal supply systems, with no self-extraction or use of natural water sources. All wastewater is discharged into municipal sanitation systems, with no direct discharges into the environment.

While water is not considered a material topic, NOS implements practices to monitor and optimise water use across its facilities, technical infrastructure, retail stores, and cinemas. These measures include:

• Rainwater harvesting system at the Parque das Nações building, used for irrigation and fire suppression;
• Installation of timed faucets and flow restrictors in retail stores;
• Replacement of chillers with more efficient air conditioning systems, reducing both energy and water consumption.

ESRS E4 - Biodiversity and Ecosystems

The presence of telecommunications infrastructure can impact landscapes and biodiversity, particularly in non-urban areas and high conservation value sites. However, NOS implements planning and operational measures to prevent or minimise these effects, ensuring that biodiversity is not a material topic.

Materiality of ESRS E1, E5, and G1

Detailed information on the double materiality analysis process (IRO-1) for E1, E5, and G1 can be found in sections "1.3.2.1.2 Material impacts, risks and opportunities and their interaction with the strategy and business model (ESRS 2 SBM-3/IRO-1)", "1.3.2.2.1 Management of impacts, risks and opportunities (IRO-1)" and "1.3.4.1.1 Management of impacts, risks and opportunities (IRO-1)".

Topic-specific IRO-1 information

Climate Change (E1)

NOS adopts a structured and systematic approach to identifying and assessing material impacts, risks, and opportunities related to climate change. This approach is aligned with internationally recognised external methodologies and the internal Enterprise Risk Management (ERM) methodology, which includes a Business Risk Model (BRM) that serves as a dedicated dictionary of risks and risk drivers.

Identification and assessment of climate change impacts

E1.IRO-1_01 / E1.SBM-3_01: The main climate-related negative impact of NOS is the emission of greenhouse gases (GHG). NOS has conducted a comprehensive mapping of these emissions across its entire value chain:

• Own operations;
• Supply chain;
• Distribution, use, and end-of-life of products and services placed on the market.

The process was carried out in accordance with the requirements of The GHG Protocol methodology for defining organisational and operational boundaries, in-scope GHGs, and emission sources to be included.

The company maintains a complete corporate emissions inventory, compiled annually and externally verified. It also assesses the potential evolution of emissions through projections that are periodically updated to incorporate the most recent business planning information and the implementation of reduction measures outlined in its climate transition plan.

NOS also evaluates the positive climate impact of the digital solutions it places on the market and that help reduce its clients's emissions (climate enabling effect).

Climate change risks and opportunities

E1.SBM-3_01: The risks and opportunities related to climate change are integrated into NOS's risk management model. NOS has identified the material risks and opportunities and continues to deepen their characterisation to enhance the assessment of the climate resilience of the strategy and business model.

Identification and assessment of physical risks

The identification and assessment of climate-related physical risks uses elements of NOS's Enterprise Risk Management methodology, enabling the identification of associated risks and opportunities and the definition of response actions. Climate-related physical risks are classified within the NOS Business Risk Model (BRM) as operational risks and security and continuity risks. Depending on their nature, the analysis is conducted over different time horizons: short-term (e.g. exposure of the telecommunications network to wildfire risk) or medium/long-term (e.g. structural increase in average summer temperatures and its impact on the technical infrastructure).

The scenario analysis will be conducted in accordance with the Task Force on Climate-Related Financial Disclosures (TCFD) guidelines, including the definition of critical assumptions, time horizons, and the integration of existing risk response strategies (actions and resources for climate change mitigation and adaptation).

Compatibility of assets and activities with climate transition

E1.IRO-1_14: NOS has not identified any assets or business activities that are incompatible with the climate transition. The company's key assets (technical infrastructure) and products (customer equipment) generate only indirect emissions from electricity consumption, which are minimised through the use of renewable electricity and energy efficiency measures. Furthermore, the company has activities covered by the European Union Taxonomy, with segments of its portfolio recognised as contributing to both climate change mitigation and adaptation.

Resource Use and Circular Economy (E5)

E5.IRO-1_01 / E5.IRO-1_02: The identification of impacts, risks, and opportunities related to resource use and circular economy is based on mapping the NOS value chain:

Own operations: The company assessed its main physical assets (telecommunications network and other technical infrastructure, logistics centre, back-office buildings, retail network, and cinema theatres) as well as the activities associated with these assets. NOS continuously monitors: material consumption at its logistics centre; the level of digitalisation of invoicing processes (for both suppliers and customers) and cinema ticketing; the production and routing of waste generated by its operations to licensed operators; and the sale of network components with reuse potential in secondary markets.

Upstream value chain: The most relevant product and service supplies from a circularity perspective (network equipment, customer equipment, and materials used in the logistics process) have been identified. The company has Life Cycle Assessment (LCA) results for most of the fixed customer equipment models it uses (TV set-top boxes and routers) and for an increasing percentage of mobile customer equipment (mobile phones). For fixed equipment, NOS also engages with manufacturers to reduce material use and increase the incorporation of recycled materials (e.g., recycled plastic in TV set-top boxes, routers, and remote controls).

Downstream value chain: The use and end-of-life of customer equipment have been assessed. NOS continuously monitors: the volumes and characteristics of mobile and fixed equipment provided to customers; the performance of its own take-back, refurbishment, and resale systems (already implemented for fixed equipment and being expanded for mobile equipment); and its contribution to integrated management systems for electrical and electronic equipment placed on the market.

A more detailed analysis is underway, covering each of NOS' business processes, to identify: i) Inputs and outputs of material resources; ii) Improvement opportunities related to reducing consumption, circular product and process design, using recycled and/or reused materials, and aligning waste management practices with the waste hierarchy. This analysis will serve as the foundation for defining NOS' circularity strategy, including its action plan, resource allocation, new performance targets, and monitoring metrics.

Business Conduct (G1)

Business Conduct is a key pillar of the company's ESG strategy, guiding the management of impacts, risks, and opportunities in an ethical, responsible, and transparent manner. Aligned with the Sustainable Business Model (SBM), this approach reflects the company's commitment to organizational practices that promote integrity, responsibility, and alignment with strategic objectives.

In the context of materiality analysis and the criteria set by the ESRS, the following priority subtopics of Business Conduct have been identified, which guide the company's actions:

• Corporate culture, which is based on values of integrity and ethics, promoting an inclusive and responsible working environment;
• Political context and representation of interest groups, ensuring transparent and ethical interaction with institutional and political stakeholders, aligned with corporate values;
• Supplier relationship management, including payment practices, promoting a value chain based on ethical and sustainable relationships, with fair payment practices.

The management of these subtopics is integrated into the company's internal processes to identify, assess, and mitigate impacts and risks. Regarding corporate culture, NOS continually reinforces the communication of ethical policies and practices at all levels of the organization. With regard to the political context, NOS ensures the rigorous monitoring of representation and lobbying activities, ensuring alignment with ESG commitments and complete transparency. Lastly, in supplier management, NOS implements ESG criteria in selection and evaluation policies, ensuring that the value chain reflects ethical and sustainability standards.

Transition plan for climate change mitigation

Approach to climate transition

(E1-1_01/E1-1_02/E1-1_13) NOS's climate transition strategy is based on two key commitments: (i) increasing the energy and carbon efficiency of its operations and value chain; and (ii) contributing to the decarbonisation of the economy through innovative products and services that reduce customer emissions. These commitments are supported by continuous investment in the technological modernisation of our technical infrastructure and the enhancement of its resilience to the physical risks of climate change.

NOS's climate commitments are formally integrated into NOS 2025-2030 business strategy and into its Sustainability-Linked Financing Framework, which governs our issuance of sustainable financing instruments.

The climate transition strategy is aligned with NOS's financial and strategic planning, both influencing and being influenced by technological advancements in assets, operational efficiency projects, sourcing options, access to financing conditions, and the development of our product and service portfolio. A growing focus is placed on digital solutions that enable customer emissions reductions (enabling effect).

Scope and target alignment

NOS's 2030 decarbonisation targets have been approved by the Science-Based Targets initiative (SBTi) and are fully aligned with the objectives of the Paris Agreement:

• 90% reduction in Scope 1+2 emissions: Science-Based Target aligned with a 1.5ºC pathway, compatible with a decarbonisation trajectory specific to the Information and Communication Technologies (ICT) sector¹.
• 30% reduction in Scope 3 emissions: Science-Based Target aligned with a well-below 2ºC pathway, compatible with the global decarbonisation trajectory defined by the SBTi².

¹ Guidance for ICT Companies Setting Science Based Targets. ITU, GeSI, GSMA and SBTi, 2020 ² Absolute Contraction Approach, SBTi 2020

Decarbonisation levers and progress in implementation

(E1-1_03/E1-1_15) NOS's decarbonisation plan is structured around the following key levers:

Own operations (Scope 1 and 2 emissions):

• Increasing energy efficiency through a company-wide programme covering the telecommunications network, data centres, buildings, stores, fleet, and cinemas.
• Reducing reliance on fossil fuels by electrifying the company fleet and progressively increasing the consumption of electricity from renewable sources.

Value chain, both upstream and downstream (Scope 3 emissions):

• Reducing emissions associated with the procurement of goods and services, prioritising the carbon footprint reduction of new equipment and increasing the reuse of used equipment.
• Reducing emissions related to product and service usage, ensuring that customer equipment is increasingly energy efficient and promoting the use of energy-saving features.

Maintaining an adapted and resilient network

NOS's operations – particularly its technical infrastructure – are exposed to the physical risks of climate change. We have identified and assessed these risks and strengthened specific mitigation measures in our Business Continuity Management (BCM) programme and Network and Services Supervision processes, including:

• Resilience and response capacity assessment of our network and systems against failures, disruptions, or external events.
• Contingency procedures for extreme weather conditions.
• Identification of technical facilities located in high wildfire risk areas, with additional vegetation clearing procedures.
• Strengthening energy autonomy for critical facilities.
• Enhanced maintenance criteria in key technical rooms, adapted to the expected impacts of climate change in Portugal, including a higher number of extreme heat days and increased average temperatures.

In 2024, a specific risk assessment project continued for the main technical rooms across the country, including specific analyses for fire and flood risk, two of the main climate-related physical risks identified for our network operations.

Investments supporting the execution of the transition plan and alignment with the taxonomy regulation

(E1-1_04/E1-1_06/E1-1_08) The investments associated with the decarbonisation levers in NOS's climate transition plan are recognised under the European Taxonomy for environmentally sustainable activities. In 2024, a total of €38.4 million in CAPEX (9% of consolidated CAPEX) was classified as eligible but not aligned under the Taxonomy, covering energy efficiency measures, renewable energy production, and investments in data centres and the 5G mobile network.

NOS's economic activities fall under the Delegated Regulations on Climate Change Mitigation and Adaptation, according to the Taxonomy Regulation. The company generates revenue from activities classified as eligible for adaptation objectives (8.3 - Broadcasting and radio programming; 13.3 - Film, video, and television production, sound recording, and music publishing) and for mitigation objectives (8.1 - Data processing, hosting, and related activities; 8.2 - Data-driven solutions for reducing greenhouse gas (GHG) emissions). In 2024, NOS allocated a total of €55.3 million in eligible CAPEX and OPEX for the development of these activities, as well as for the acquisition of goods and services from supporting eligible activities (7.3 - Installation, maintenance, and repair of energy-efficient equipment, among others), aimed at increasing alignment with the Taxonomy criteria for climate adaptation and mitigation objectives.

Governance

(E1-1_14) The climate transition plan was developed under the supervision of the Chief Financial Officer (a member of the Executive Committee and the Board of Directors with direct responsibility for climate-related matters) and approved by the Executive Committee.

Its implementation is regularly evaluated by the Corporate Governance and Sustainability Committee, which is composed of non-executive directors and one executive director.

Exposure to fossil fuels, locked-in emissions, and compatibility with climate transition

(E1-1_01/E1-1_07/E1-1_12) NOS does not generate, nor does it plan to generate, revenue from activities related to coal, oil, or gas and has no assets that are incompatible with climate transition. The company is not excluded from the EU Paris-aligned benchmarks, as it does not generate revenue from fossil fuel extraction, exploration, distribution, or refining, nor from electricity generation with a carbon intensity above 100 g CO₂e/kWh.

There are no significant locked-in emissions associated with the company's main assets (technical infrastructure) and products (customer equipment). In both cases, their operation generates exclusively indirect emissions from the electricity consumed, and these emissions are significantly reduced through the measures outlined in the climate transition plan: consumption of renewable electricity (assets); and the combined effect of increasing energy efficiency and reduced average carbon content of the grid electricity in Portugal (customer equipment).

Detailed emission reduction targets

Operational emissions (Scope 1 and 2)

The target covers 100% of NOS's Scope 1 and 2 GHG emissions across all business segments, in line with the GHG emissions inventory reporting boundaries. Scope 2 emissions are accounted for and monitored using the market-based method. The inventory is prepared according to the GHG Protocol methodology, adopting a financial control consolidation approach, with no control (financial or operational) over any activities or entities outside the consolidation perimeter. The target includes all GHGs applicable to the company's activities (CO2, N2O, CH4, and HFCs).

The monitoring metric (KPI) is the total Scope 1 and 2 emissions, expressed in tCO2e, based on Global Warming Potential (GWP) values used in the most recent edition of the National Emissions Inventory prepared by the Portuguese Environment Agency (currently IPCC 5th Assessment Report).

Scope 1 emissions include: Mobile combustion of fossil fuels (petrol and diesel in the company's passenger and light commercial fleet); stationary combustion of fossil fuels (natural gas heating in some back-office buildings and cinema theatres, and diesel in emergency generators); and fugitive emissions of fluorinated gases (from air conditioning equipment and fire suppression systems). Scope 2 emissions include: emissions associated with the production of electricity purchased from third parties for consumption in the company's facilities; emissions associated with the production of thermal energy (heat and cooling) purchased from third parties and consumed in some back-office buildings and cinema theatres. Scope 2 emissions are accounted for using the market-based method and represent approximately 85% of total Scope 1 and 2 emissions (baseline year values).

The target was modelled using the SBTi ICT Sector Guidance⁵ methodology and is aligned with decarbonisation pathways for the telecommunications and information technology sector compatible with a 1.5ºC global warming scenario. This alignment ensures compliance with national (Portuguese Climate Law), European (Fit for 55 package and European Climate Law), and international (Paris Agreement) climate policy objectives. It was formally approved as a Science-Based Target 1.5ºC by the SBTi in 2021.

The reference for measuring performance is the total Scope 1 and 2 emissions of NOS in 2019. The year 2019 was chosen as the baseline because: i) it represents a period in which the company's business segments, geographies, asset types, and product and service portfolio are considered representative in terms of GHG emissions; ii) it corresponds to the first reporting year for which NOS has a complete GHG emissions inventory, including all applicable Scope 3 emissions, with independent external verification. The company has maintained a complete and verified Scope 1 and 2 emissions inventory since 2015, but chose 2019 as the reference year to ensure consistency in the timeframe of its targets across all emission scopes.

Baseline (2019): 50,383 tCO₂e
Target (2030): 5,038 tCO₂e
Reduction: 90% compared to the 2019 baseline

The target was approved as a Science-Based Target 1.5ºC by the SBTi, aligning with the global objective of limiting global warming to 1.5ºC.

⁵ Guidance for ICT Companies Setting Science Based Targets. ITU, GeSI, GSMA and SBTi, 2020.

Value Chain Emissions – Upstream and Downstream (Scope 3)

The target covers 100% of NOS's Scope 3 GHG emissions across all business segments, in accordance with the accounting boundaries of the company's GHG emissions inventory. The inventory is prepared in line with the The GHG Protocol methodology, adopting a financial control consolidation approach, meaning that no financial or operational control is exercised over any activity or entity outside of from the reporting scope. The target includes all applicable GHGs related to the company's activities (CO₂, N₂O, CH₄, and HFCs).

The monitoring metric (KPI) is the total Scope 3 emissions, expressed in tCO₂e, based on Global Warming Potential (GWP) values used in the latest edition of the National Emissions Inventory prepared by the Portuguese Environment Agency (currently IPCC 5th Assessment Report).

The target includes 100% of emissions across all applicable Scope 3 categories defined by The GHG Protocol and relevant to NOS's activities. For Category 4 (upstream transportation and distribution) and Category 9 (downstream transportion and distribution), emissions are reported together due to operational data limitations. Categories 10 and 13 do not apply to NOS, as the company's products and services are not subject to further processing after sale, and NOS does not lease facilities to third parties.

The target was modeled using the SBTi Absolute Contraction Approach⁶ and aligns with a global decarbonization trajectory compatible with a well-below 2ºC warming scenario. This also ensures alignment with climate policy objectives at the national (Portuguese Climate Law), European (Fit for 55 legislative package and European Climate Law), and international levels (Paris Agreement). It was formally approved as a Science-Based Target Well-Below 2 Degrees by the SBTi in 2021.

The reference point for performance measurement is NOS's total Scope 3 emissions in 2019. The 2019 baseline was chosen because: i) it represents a period in which the company's business segments, geographies, asset types, product and service portfolio, and overall scale of activities are considered representative in terms of GHG emissions; ii) it corresponds to the first reporting year for which NOS has a complete Scope 3 GHG inventory with independent external verification. Choosing 2019 as a baseline ensures consistency in the timeframe of NOS's emission targets across all scopes.

Baseline (2019): 310,880 tCO₂e
Target (2030): 217,616 tCO₂e
Reduction: 30% compared to the 2019 baseline

⁶ Absolute Contraction Approach, SBTi 2020.

Carbon Neutrality of NOS's Own Operations

The target covers 100% of NOS's Scope 1 and 2 GHG emissions across all business segments, in accordance with the accounting boundaries of the associated reduction target (SBT).

The monitoring metric (KPI) is the total Scope 1 and 2 emissions, calculated according to the monitoring methodology associated with the reduction target, deducted from the residual neutralized emissions.

This target was established within the European Green Digital Coalition, of which NOS is a founding member. It complies with the SBTi requirements for the approval of carbon neutrality targets for Scope 1 and 2, assuming neutralization only for residual emissions after achieving the 90% reduction target by 2030, approved by SBTi as a Science-Based Target 1.5ºC.

NOS is currently awaiting detailed eligibility criteria for the instruments to be used for residual emissions neutralization and will align its application with international best practices.

Fleet electrification

The target covers 100% of NOS's own vehicle fleet, including passenger and light commercial vehicles, both used exclusively for operational support and assigned to employees for professional and personal use.

The monitoring metric (KPI) is the ratio between the number of electrified vehicles (disaggregated into plug-in hybrid vehicles and fully electric vehicles) and the total number of vehicles in the fleet at the end of the year.

The target year (2030) is aligned with NOS's Science-Based Target, approved by the SBTi. The target format does not involve defining a baseline year.

Renewable electricity consumption

The monitoring metric (KPI) is the ratio (expressed as % MWh/MWh) between the consumption of electricity generated from renewable sources (renewable self-generation and procurement from third parties of electricity certified through appropriate attribute tracking systems) and total electricity consumption.

The recognition criteria for renewable electricity accounting are aligned with the technical requirements of the RE100 initiative.

2024 performance

In 2024, total Scope 1 and 2 (market-based) emissions recorded a 24% reduction compared to 2023.

For Scope 1, the 12% decrease resulted from a reduction in fuel consumption in the company's car fleet (electrification and more efficient combustion engines) and a decrease in fluorinated gas leaks during equipment maintenance operations.

For Scope 2, the 25% decrease was driven by a reduction in electricity consumption (-3%, as a result of energy efficiency measures) and a 23% reduction in the average carbon content of the electricity purchased⁴.

In 2024, Scope 3 emissions decreased by 11% compared to 2023.

Upstream, the reduction (-21%) was driven by an 8% decrease in emissions associated with the production of products, services, and capital goods purchased during the year (categories 1 and 2). The carbon footprint of the production and transportation of customer equipment decreased globally, reaching 44 kg CO2e per device for mobile phones, 10 kg CO2e per device for set-top boxes, and 28 kg CO2e per device for routers. Additionally, the use of refurbished equipment, particularly in the fixed segment, reduced purchasing needs. For other procurement categories, the evolution was determined by changes in expenditure (CAPEX and OPEX). Together, categories 1 and 2 accounted for 64% of total Scope 3 emissions.

Downstream, the reduction (-11%) resulted from the evolution of emissions associated with electricity consumption in third-party facilities (category 8) and the electricity consumption of customer equipment sold or provided by NOS (category 11). In both cases, the decrease benefited from the lower average carbon intensity of electricity consumed in Portugal. Categories 8 and 11 combined accounted for 27% of total Scope 3 emissions.

⁴ Scope 2 emissions calculated using the location-based method recorded a 32% decrease compared to 2023, driven by a 3% reduction in electricity consumption and a 31% decrease in the average carbon content of the electricity grid in Portugal.

Carbon credits and removals

Parallel to this – voluntarily and not included in the emissions inventory – we mitigate an amount of emissions equivalent to our Scope 1, outside the value chain. This is achieved through carbon sequestration from a reforestation project in fire-affected areas in Northern and Central Portugal, which we continue to support. This initiative combines carbon capture, biodiversity protection, and natural wildfire resistance enhancement. This exercise allows us to gain insights into the use of this type of instrument. NOS is awaiting the definition of detailed eligibility criteria for instruments to be used for the neutralisation of residual emissions and will align its use with international best practices.

Next steps

NOS has not yet conducted a comprehensive climate scenario analysis. This process is currently under preparation and will be developed in 2025 with the support of specialised expertise. A quantitative analysis of the potential financial impacts of risks and opportunities will be conducted under different physical, regulatory, and market climate change scenarios, completing the climate resilience assessment of our strategy and business model and reducing uncertainty, particularly in the long-term financial quantification of physical risks (beyond 5 years).

The scenario analysis will be conducted in accordance with the Task Force on Climate-Related Financial Disclosures (TCFD) guidelines, including the definition of critical assumptions, time horizons, and the integration of existing risk response strategies (actions and resources for climate change mitigation and adaptation).

Policies related to climate change mitigation and adaptation

NOS has two key corporate policies related to climate change mitigation and adaptation:

NOS Sustainability Policy

Climate change mitigation:

• The fight against climate change through the implementation of mitigation measures is one of the guiding principles of the environmental pillar (In the Name of the Planet) of the Policy

Climate change adaptation:

• The fight against climate change through the implementation of adaptation measures is one of the guiding principles of the environmental pillar (In the Name of the Planet) of the Policy

Energy efficiency:

• Reducing energy consumption and associated emissions, as well as implementing sustainable mobility practices, are guiding principles of the environmental pillar (In the Name of the Planet) of the Policy

Renewable energy:

• Reducing emissions associated with energy consumption is one of the guiding principles of the environmental pillar (In the Name of the Planet) of the Policy
• Given NOS's emissions profile (90% of scope 1 and 2 GHG emissions are associated with electricity consumption), the use of renewable electricity is the key measure for reducing carbon emissions in its own operations

Other climate-related principles:

• Pollution prevention
• Rational use of resources and proper waste management
• Biodiversity and ecosystem protection
• Promoting the circularity of NOS's business through the reuse, resale, or recycling of network and customer equipment, positively influencing the entire value chain, with additional benefits in emissions reduction and climate change mitigation

Sustainability Requirements for NOS Suppliers and Partners

Climate change mitigation:

• The Requirements establish that, whenever requested, Suppliers and Partners must collaborate in setting and achieving energy consumption or emissions reduction targets defined under NOS's sustainability strategy
• The Requirements include a recommendation that Suppliers and Partners monitor the energy consumption associated with activities carried out for and/or at NOS and adopt measures to improve the energy and carbon efficiency of the goods and services provided to the company

Reference to detailed description: A detailed description of these policies can be found in section "1.3.1.12 Policies (MDR-P)"

Actions and resources in relation to climate change policies

Energy Efficiency Programme

Scope: Own operations (technical infrastructure, support activities, retail network, cinema theatres)

Time horizon: Ongoing; new measures planned from 2025 onwards

Resources allocated (2024):

• Total investment: €10.2M
• Expected outcomes: Estimated reduction of approximately 1,400 tCO2e in 2024
• Additional measures (2025 onwards): Estimated annual reduction of approximately 1,000 tCO2e

Key results (2024): 3% reduction in total energy consumption across NOS operations

Technical Infrastructure

Actions:

• Implementation of energy efficiency measures in telecommunications network and Data Centres
• Deployment of intelligent energy management features (Power Saving Features, PSF) in 5G mobile access network sites based on analytical usage prediction models
• Replacement of HVAC, backup, and power conversion systems with high-efficiency equipment in main technical rooms
• Expansion of free cooling solutions (using outside air instead of mechanical cooling)
• Cold aisle containment solutions planned for 2025
• Network-sharing agreement signed in 2024 for fibre optic network (complementing existing mobile access network-sharing in remote regions)

Outcomes (2024):

• 2.5% decrease in technical infrastructure energy consumption despite 20% increase in data traffic
• First phase of PSF (completed 2023): consumption reductions between 3% and 8% depending on site typology

Support Activities (Back-office Buildings)

Actions:

• Space consolidation
• In-house thermal energy production through heat pumps
• Modernisation of HVAC systems and elevators

Outcomes (2024): 10% reduction in energy consumption (2023-2024)

Fleet Electrification

Actions:

• Continuation of electrification plan for company car fleet

Outcomes (2024):

• Electric vehicles: 44% of total fleet by year-end
• Total energy consumption: 9% decrease vs 2023

Retail Network

Actions:

• Installation of automated systems to shut down test equipment and display units after store closing hours
• Replacement of HVAC systems with more energy-efficient models
• Lighting overhaul completed in 2023

Outcomes (2024): Energy consumption growth contained to +4% vs 2023, despite increase in number and size of stores

Cinema Theatres

Actions:

• Replacement of HVAC systems with more energy-efficient technologies
• Replacement of projection systems with next-generation, energy-efficient equipment

Outcomes (2024):

• 4% reduction in total energy consumption vs 2023
• Elimination of natural gas requirement for heating

Renewable Electricity

Scope: Own operations

Actions:

• Sourcing from suppliers providing electricity with higher share of renewable energy sources
• Exploring different market options and contractual models, including long-term agreements
• Investment in self-generation of renewable electricity

Resources (included in €10.2M total investment above): Energy efficiency programme includes investment in renewable electricity self-generation

Link to targets: Contributes to Scope 2 emissions reduction

Taxonomy-Eligible Investments

Scope: Own operations

Resources allocated (2024):

• €38.4 million in CAPEX (9% of consolidated CAPEX) classified as eligible but not aligned under EU Taxonomy
• Coverage: energy efficiency measures, renewable energy production, data centres, 5G mobile network
• €55.3 million total in eligible CAPEX and OPEX for development of eligible activities and acquisition of goods/services from supporting activities

Link to policy: Aligned with climate transition plan and Taxonomy Regulation (Climate Change Mitigation and Adaptation)

Scope 3 Emissions Reduction

Scope: Upstream and downstream value chain

Upstream (Categories 1 & 2 - Purchased Goods and Services)

Actions:

• Reduction in carbon footprint of customer equipment production and transportation
• Use of refurbished equipment, particularly in fixed segment

Outcomes (2024):

• Mobile phones: 44 kg CO2e per device
• Set-top boxes: 10 kg CO2e per device
• Routers: 28 kg CO2e per device
• Categories 1 and 2: 64% of total Scope 3 emissions
• Upstream emissions: 21% reduction vs 2023

Downstream (Categories 8 & 11)

Outcomes (2024):

• Categories 8 and 11: 27% of total Scope 3 emissions
• Downstream emissions: 11% reduction vs 2023
• Overall Scope 3: 11% reduction vs 2023

Carbon Sequestration (Voluntary, Outside Value Chain)

Scope: Not included in emissions inventory

Actions:

• Support for reforestation project in fire-affected areas in Northern and Central Portugal
• Initiated 2021, continued through 2024
• Locations: Fundão, Mangualde, Meda, Pampilhosa da Serra

Outcomes:

• Mitigation of emissions equivalent to Scope 1
• Combined benefits: carbon capture, biodiversity protection, natural wildfire resistance enhancement

Link to policy: NOS awaiting definition of detailed eligibility criteria for neutralisation instruments and will align with international best practices

Targets related to climate change mitigation and adaptation

1. Energy Efficiency of Telecommunications Services

Target metric: Energy consumption per data traffic (kWh/TB)
Target value: -80% reduction (from 66 kWh/TB to 13 kWh/TB)
Target year: 2030
Intermediate target: -70% by 2025
Baseline year: 2019
Baseline value: 66 kWh/TB
Scope: 100% of energy consumption associated with telecommunications services (mobile and fixed networks, support services, back-office buildings, retail network, company fleet, both own and third-party facilities). Excludes Data Centres dedicated to data processing/storage and cinema network.
Type: Intensity-based
Validation: Aligned with SBTi baseline year (2019)
Progress to date (2024): -62% compared to 2019 baseline

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2. Fleet Electrification

Target metric: Percentage of electrified vehicles in company-owned fleet
Target value: 100%
Target year: 2030
Baseline year: Not specified (target format does not involve defining a baseline year)
Scope: 100% of NOS's own vehicle fleet (passenger and light commercial vehicles)
Type: Absolute
Validation: Aligned with SBTi target year (2030)
Progress to date (2024): 44% of fleet electrified (41% plug-in hybrid, 3% fully electric)

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3. Renewable Electricity Consumption

Target metric: Percentage of electricity from renewable sources (% MWh/MWh)
Target value: 100%
Target year: 2030
Baseline year: Not specified
Scope: Total electricity consumption across all operations
Type: Absolute
Validation: Criteria aligned with RE100 initiative
Progress to date (2024): 50%

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4. Operational Emissions Reduction (Scope 1 + 2)

Target metric: Total Scope 1 and 2 GHG emissions (tCO₂e, market-based)
Target value: -90% reduction (from 50,383 tCO₂e to 5,038 tCO₂e)
Target year: 2030
Intermediate target: -80% by 2025
Baseline year: 2019
Baseline value: 50,383 tCO₂e (market-based)
Scope: 100% of Scope 1 and 2 emissions across all business segments (mobile combustion, stationary combustion, fugitive emissions, purchased electricity and thermal energy)
Type: Absolute
Validation: SBTi-approved Science-Based Target 1.5°C
Progress to date (2024): -21% reduction in Scope 1+2 market-based emissions vs. 2023

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5. Value Chain Emissions Reduction (Scope 3)

Target metric: Total Scope 3 GHG emissions (tCO₂e)
Target value: -30% reduction (from 310,880 tCO₂e to 217,616 tCO₂e)
Target year: 2030
Baseline year: 2019
Baseline value: 310,880 tCO₂e
Scope: 100% of Scope 3 emissions across all applicable categories (upstream and downstream value chain)
Type: Absolute
Validation: SBTi-approved Science-Based Target Well-Below 2°C (Absolute Contraction Approach)
Progress to date (2024): -46% reduction vs. 2019 baseline; -11% vs. 2023

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6. Carbon Neutrality of Own Operations

Target metric: Net Scope 1 and 2 emissions after neutralization of residual emissions
Target value: Net zero
Target year: 2040
Baseline year: 2019 (aligned with reduction target)
Scope: 100% of Scope 1 and 2 emissions
Type: Absolute
Validation: Established under European Green Digital Coalition; complies with SBTi requirements for carbon neutrality targets (neutralization only for residual emissions after achieving 90% reduction by 2030)
Progress to date: Not yet applicable (neutralization to apply post-2030)

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7. Avoided Emissions through Products & Services

Target metric: Ratio of annual avoided customer emissions to NOS's total Scope 1 + 2 emissions
Target value: Ratio > 1 (avoided emissions greater than own operational emissions)
Target year: 2030
Baseline year: Not specified (methodology under development)
Scope: Customer emissions avoided through NOS's portfolio of digital solutions (Communications & Collaboration, Cloud & Data Centre, IoT, Analytics)
Type: Intensity-based (ratio)
Validation: Aligned with European Green Digital Coalition commitments
Progress to date: Methodology under development; 2% of consolidated revenue from eligible products/services in 2024

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8. Circular Economy - Equipment Take-back

Target metric: Equipment take-back rate as percentage of new equipment distributed
Target value: ≥20%
Target year: 2030
Baseline year: Not specified
Scope: Network and customer equipment (reuse, resale, or recycling)
Type: Intensity-based
Progress to date (2024): 53% on fixed equipment

Energy consumption and mix (E1-5)

Total energy consumption

NOS's total energy consumption across all business segments in 2024:

Energy mix breakdown

Renewable electricity detail

In 2024, the renewable fraction of total electricity consumption reached 50%, corresponding to the renewable fraction of electricity suppliers' offers weighted by volumes supplied (21 percentage points increase vs 2023). This reflects the progressive decarbonisation of electricity generation in the Portuguese national electricity market.

Methodology and scope

Scope: Total energy consumption covers all NOS business segments, including:

• Fleet (passenger and light commercial vehicles)
• Buildings (back-office, retail stores)
• Mobile and fixed telecommunications network infrastructure
• Data centres
• Cinema theatres

Fossil fuels: All diesel, gasoline, and natural gas consumed. The renewable fraction from biofuel blending in commercial road fuel (biodiesel, bioethanol) is not disaggregated as it is immaterial and does not result from a NOS management decision.

Renewable electricity: In 2024, corresponds exclusively to the renewable fraction in the energy mix of purchased electricity based on supplier-published information (data from four most recent quarters, weighted by volume and contracted products). All self-generated electricity is renewable (solar photovoltaic and wind at selected network sites).

Thermal energy: All purchased thermal energy is fossil-based (natural gas cogeneration/trigeneration). All self-generated thermal is renewable (solar thermal panels).

Calculation approach: Energy consumption uses metered data where available. For third-party facilities (shared sites, leased locations), estimates based on similar equipment are used.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 Emissions

Scope 1 emissions correspond to total direct emissions that occur in sources owned or controlled by NOS. These include emissions from fixed and mobile combustion of fossil fuels and fugitive emissions from refrigerant gases used in equipment.

Scope 1 breakdown (tCO₂e):

Sub-breakdown: Scope 1 includes mobile combustion (diesel and gasoline in company fleet), stationary combustion (natural gas heating and diesel in emergency generators), and fugitive emissions (fluorinated gases from air conditioning equipment and fire suppression systems).

Scope 2 Emissions

Scope 2 emissions correspond to total indirect emissions associated with the generation of purchased energy consumed at NOS facilities and equipment. These include emissions from purchased electricity, heating, and cooling.

Scope 2 emissions (tCO₂e):

Total Scope 1 + 2 (market-based) (tCO₂e):

Scope 3 Emissions

Scope 3 emissions correspond to total indirect emissions associated with third-party activities in NOS's value chain, both upstream and downstream.

Scope 3 emissions by category (tCO₂e):

Total GHG Emissions

Total emissions all scopes (tCO₂e):

GHG Intensity

Emission intensity is calculated as the ratio between total emissions (Scope 1, 2, and 3) and NOS's consolidated revenue.

GHG intensity (tCO₂e / M€):

Biogenic CO₂ Emissions

There are no biogenic emissions associated with NOS's activities, either in Scope 1 or Scope 2.

Regulated Emissions

NOS does not operate installations subject to EU ETS or other regulated emissions schemes.

Methodology Notes

Methodological framework: NOS's GHG emissions are accounted for in accordance with The GHG Protocol Corporate Accounting and Reporting Standard - Revised Edition (2004), complemented by The GHG Protocol Scope 2 Guidance (2015) for Scope 2 emissions and The GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011) for Scope 3 emissions. The financial control approach is used for consolidation.

GHGs included: Carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), and fluorinated gases (HFCs, PFCs, SF₆, NF₃). Results are converted to CO₂e using GWP values from IPCC AR5 (from 2023 onwards; previously AR4).

Scope 1: Emissions calculated based on fuel consumption and nationally representative emission factors. For fluorinated gases, emissions equal the quantity consumed for leakage replenishment, multiplied by gas-specific GWP values.

Scope 2 - Location-based: Uses the average carbon intensity factor of electricity in the Portuguese grid, based on the latest data published by the European Environment Agency (EEA proxy for year n-1).

Scope 2 - Market-based: Uses supplier-specific emission factors based on the most recent available data (for year n-1). Weighted by the renewable fraction of total electricity consumption from suppliers' offers.

Scope 3: Different approaches are used depending on data availability:

• Categories 1 & 2: Physical approach using LCAs for customer equipment (mobile phones, TV set-top boxes, routers, TVs); hybrid approach using emission intensity ratios for telecom services; financial approach using EEIO sectoral emission intensity ratios for other purchased goods/services and capital goods.
• Category 3: Reference LCA emission factors and national T&D loss data.
• Categories 4 & 9: Based on logistics operation data (weights, distances, vehicle types) and reference emission factors. Categories reported together due to operational data limitations.
• Category 5: Reference Portuguese emission factors, excluding recycling/energy recovery emissions.
• Category 6: Travel distances, passenger numbers, and emission factors. Air travel includes Radiative Forcing Index.
• Category 7: Employee mobility survey data matched with reference transportation emission factors.
• Category 8: Electricity consumption estimates based on similar equipment and location-based emission factor for Portugal.
• Category 11: Representative data on energy consumption, product lifespan, and usage patterns, using location-based emission factor for Portugal. Does not include customer-owned equipment not sold/installed by NOS.
• Category 12: Recovery rates in Portugal for electrical/electronic equipment and packaging, with reference emission factors. Excludes recycling/energy recovery emissions.
• Category 14: Consumption estimates based on average consumption per area of NOS-owned stores, using location-based emission factor.
• Category 15: Emissions calculated based on percentage of capital held in associated companies/joint ventures, using NOS's own emission ratios.

Categories 10 and 13: Not applicable to NOS's activities.

Exclusions: GHG emissions from NOS Madeira and NOS Açores (estimated <1% of total) are estimated based on customer numbers. Municipal solid waste processed through local collection systems is excluded.

Changes: No significant changes to accounting principles in the reporting year. From 2023 onwards, GWP values from IPCC AR5 are used (previously AR4).

Verification: The complete corporate emissions inventory is compiled annually and externally verified.

Baseline year: 2019 was chosen because: (i) it represents a period in which the company's business segments, geographies, asset types, and product/service portfolio are considered representative; (ii) it corresponds to the first reporting year with a complete GHG emissions inventory including all applicable Scope 3 emissions, with independent external verification.

Policies related to resource use and circular economy

NOS has identified two main corporate policies related to resource use and the circular economy:

NOS Sustainability Policy

Key content / principles:

• Within the environmental pillar ("In the Name of the Planet"), the policy identifies reuse, resale, or recycling of network and customer equipment as a key principle to promote circularity in NOS's business and positively influence the entire value chain
• The policy identifies proper waste management as a key principle to promote circularity in NOS's business and positively influence the entire value chain

Coverage:

• Network and customer equipment
• Other material inputs and outputs

Sustainability Requirements for Suppliers and Partners

Key content / principles:

• Requires all suppliers and partners to collaborate to improve the environmental performance of NOS's products and services
• Requires suppliers and partners to provide information on their own environmental goals and performance
• Mandates that suppliers and partners ensure waste generated at NOS's facilities as a result of their services is sent to a licensed and environmentally appropriate final destination
• Requires suppliers and partners to make the Waste Accompanying Form (e-GAR) related to waste transportation/disposal available to NOS upon request when applicable

Coverage:

• Network and customer equipment
• Other material inputs and outputs

Additional information:

• A detailed description of these policies can be found in section "3.1.12. Policies (MDR-P)" of the report

Actions and resources related to circular economy

Overview

NOS's circularity commitment covers the consumption of products and materials and the generation of waste in own operations, as well as the equipment provided to customers, in both the fixed and mobile segments.

In 2024, NOS completed an extensive mapping and evaluation process of initiatives already implemented within the organization, identified new opportunities, and defined intervention priorities, which will be reflected in the new NOS circularity strategy, to be launched in 2025.

Customer Equipment

To minimize the environmental impact of the production and end-of-life of equipment provided to customers, NOS acts on three fronts:

1. Reducing the amount of material used and modifying its profile
2. Implementing take-back, refurbishment, and reuse schemes
3. Contributing to integrated systems that collect and recycle equipment and packaging

Action: Material reduction and sustainability

Scope: Downstream value chain (customer equipment)

Activities:

• Latest models of cable TV set-top box and router manufactured with 100% recycled plastic
• Replacement of virgin plastic with recycled plastic in:
  • One satellite TV box model
  • All remote controls for cable boxes and their packaging
• Progressive increase in the use of digital SIM cards (e-SIMs)

Time horizon: Implemented (ongoing)

Action: Take-back and reuse of fixed equipment

Scope: Downstream value chain (customer equipment)

What it does:

• Equipment used by fixed service customers (TV boxes and routers) is collected through an in-house reverse logistics operation
• Equipment is evaluated and, when technically viable, refurbished and reused
• Targets for reuse rate of collected equipment are set considering technological evolution and market introduction plan

Time horizon:

• Ongoing programme
• 2025: Planned expansion to include new types of customer equipment (alarms and home automation devices)

Resources: In-house reverse logistics operation (non-financial)

Action: Take-back and reuse of mobile equipment

Scope: Downstream value chain (customer equipment)

What it does:

• Complete overhaul of used mobile phone take-back process in 2024
• Trade-in circuits developed in collaboration with a new partner, activated at end of 2024
• All returned devices are refurbished and reused, or when technically unviable, sent for recycling

Time horizon:

• 2024: Process overhauled and new partnership activated
• Ongoing operation

Resources: Partnership with external partner (non-financial)

Targets related to circular economy

Fixed customer equipment

Refurbishment of fixed customer equipment

Target metric: Refurbishment rate of collected fixed customer equipment (TV set-top boxes and routers)

Scope: Own operations - fixed customer equipment collected from customer premises or returned through commercial channels (residential and business segments)

Target type: Intensity-based (ratio of refurbished devices to total devices collected)

Objective: Increase circular material usage rates, minimize primary raw material consumption, and enhance waste management (Level 2 of waste hierarchy - preparation for reuse)

Progress to date (2024): The excerpt notes "The slight reduction in refurbishment rates for returned equipment in 2024 was primarily due to the technology renewal cycle and an increased reliance on new equipment" but does not provide specific quantified values.

Use of refurbished fixed customer equipment

Target metric: Percentage of refurbished devices installed versus total fixed devices (new and refurbished) installed

Scope: Own operations - TV set-top boxes and routers installed in customer premises (residential and business segments)

Target type: Intensity-based (ratio of refurbished devices to total devices installed)

Mobile customer equipment

Mobile customer equipment take-back

Target metric: Take-back rate of mobile devices (smartphones and feature phones)

Target value: 20% take-back rate

Target year: 2025

Scope: Own operations - new mobile devices sold by NOS to customers (business and residential segments)

Target type: Intensity-based (ratio of devices collected through own take-back circuits to total new devices sold)

External validation: Target and monitoring metric defined by GSMA (international mobile telecommunications industry association) and adopted in 2023 by 12 international telecom operators, including NOS

Objective: Increase circular material usage rates, minimize primary raw material consumption, and enhance waste management (Level 2 of waste hierarchy - preparation for reuse)

Progress to date: The excerpt states that current take-back and recovery levels "remain very low" and expects "a significant increase in mobile equipment take-back and recovery levels" in 2025 with full implementation of new trade-in circuits. Specific quantified current values are not provided.

Recovery of mobile customer equipment

Target metric: Recovery rate of collected mobile devices through reuse, repair, or licensed recycling

Scope: Own operations - mobile customer equipment (business and residential segments) collected by NOS through its own take-back circuits

Target type: Intensity-based (ratio of devices reused, repaired, or sent to licensed recycling operators to total devices collected)

Progress to date (2024): "All returned devices were processed for reuse (either with or without prior refurbishment) or recycled by licensed entities, through a dedicated scheme managed by a specialized partner" (implies 100% recovery rate for collected devices)

Waste from operations

The excerpt references a section on "Waste from operations" but does not provide specific targets or quantified metrics in the provided text.

3.2.2.5 Resource Inputs (E5-4)

Material resource input flows

Products

Customer equipment: Electronic devices provided to customers in the mobile and fixed segments (mobile phones, TV set-top boxes, routers, TVs, chargers, power adapters, accessories, PBX systems and other enterprise customer equipment, tablets, smartwatches) and their respective packaging.

These devices are not consumed or transformed between their entry and exit from the company's facilities.

Materials

• Logistics operations: Paper, cardboard, plastic, and other materials used in the logistics process (boxes, packing material, plastic film, documents).
• Technical infrastructure: Cables and batteries.
• Support activities (back-office buildings and stores): Writing and printing paper, cardboard cups, promotional materials, uniforms, food items.
• Cinemas: Paper for ticketing, corn, cardboard food packaging (popcorn buckets and cups).

Products and materials used

Use of secondary (used or recycled) products and materials

Accounting principles

Products

Products classified as incoming resources include telecommunications electronic equipment intended for customer distribution. These products are either purchased new or sourced through NOS's internal take-back and refurbishment operations for reuse. They are not consumed or transformed between their entry into and exit from NOS facilities.

Includes: mobile phones (new and refurbished); TV set-top boxes (new and refurbished); routers (new and refurbished); TVs (new).

Excludes (due to incomplete data availability): product packaging; chargers, adapters, and accessories; telephone exchanges and other enterprise customer equipment; tablets; smartwatches; alarms and related equipment.

The quantification of volumes (t) is based on the unit weight of each brand/model sold or installed, multiplied by the respective number of units in the reporting year. Stock levels are assumed to be negligible, meaning that the number of incoming products equals the number of products delivered to customers within the same period.

Materials

Materials classified as incoming resources include materials and consumables used in NOS operations, excluding products.

Includes: logistics operations: warehouse consumables (internal use), shipping materials (boxes and documents), and production components (boxes and envelopes).

Excludes (due to incomplete data availability): technical infrastructure: cables and batteries; back office and stores: writing and printing paper, paper cups, promotional materials, uniforms, food; cinemas: ticketing paper, corn, and popcorn packaging.

The quantification of volumes (t) is based on operational monitoring data, specifically tracking quantities and weights at NOS logistics center.

Secondary products and materials

The following non-virgin material resource inflows (i.e., secondary resources) are considered:

i) Products:

• Refurbished customer equipment (mobile phones, TV set-top boxes, and routers) sourced for customer distribution in mobile and fixed services. 100% of the equipment's weight is accounted for as a secondary product.
• Excludes: Due to incomplete data, the proportion of reused or recycled materials/components in newly purchased customer equipment is not reported.

ii) Materials:

• Recycled materials used in logistics operations (warehouse consumables, shipping materials, and production components).
• Excludes: Due to incomplete data, materials (both virgin and secondary) used in other NOS operations are not accounted for.

Resource outflows

Durability and repairability of marketed products

Average usage time (durability):

• Mobile phones: Based on manufacturer data and NOS service usage profile monitoring
• TV set-top boxes and routers: Based on manufacturer data and NOS logistics monitoring (refurbishment and dispatch)
• TVs: Based on manufacturer data

Note: The report states that actual lifespan may exceed these estimated values.

Repairability: All equipment sold or provided by NOS is repairable.

Recyclable content of products and packaging

Mobile phones: The average recyclability rate is based on Eco Rating evaluations, which is considered a suitable proxy for mobile phones sold during the year.

TV set-top boxes, routers, and TVs: Specific recyclability rate data is not yet available. NOS is evaluating the implementation of a process to systematize this information, to be provided by manufacturers.

Material sustainability in customer equipment

Recycled materials:

• Latest models of cable TV set-top box and router: manufactured with 100% recycled plastic
• Satellite TV box models: virgin plastic replaced with recycled plastic
• Remote controls for cable boxes and their packaging: recycled plastic

Material reduction:

• Progressive increase in the use of digital SIM cards (e-SIMs)

Reuse and refurbishment rates

Fixed customer equipment (2024):

• 53% of set-top boxes and routers installed were refurbished devices
• This avoids energy consumption and emissions associated with manufacturing new products

Waste

Total waste generated and recovery

In 2024, NOS generated a total of 749 tonnes of waste and achieved a global recovery rate of 99.6%, ensuring minimal landfill disposal and maximum material reuse and recycling.

Used electrical and electronic equipment (network equipment, IT systems, customer devices), batteries, and packaging materials are the primary waste streams generated in NOS operations.

Waste management by type and final destination

Waste management approach

Across all NOS facilities, selective waste collection circuits have been implemented to maximize waste recovery and minimize landfill disposal. Waste is processed through licensed waste management operators, supplemented—where applicable—by municipal waste collection services for small quantities of urban-equivalent waste.

Technical infrastructure: All equipment removed from the telecommunications network is evaluated:

• Portion is reintroduced into operations after refurbishment or internally reused for spare parts
• Legacy equipment with potential for reuse in other networks is sold in secondary markets
• Remaining equipment is sent for recycling

Customer equipment: Equipment used by fixed service customers (TV boxes and routers) is collected through an in-house reverse logistics operation, evaluated, and whenever technically viable, refurbished and reused.

All returned mobile devices are refurbished and reused, or when technically unviable, sent for recycling.

Buildings: Back-office buildings have waste sorting and selective collection circuits. Reusable cups have been provided to employees to progressively phase out disposable coffee cups.

Accounting principles

Includes: Used equipment resold in secondary markets through foreign entities; waste sent to waste management operators in Portugal (including resale of used equipment for reuse).

Excludes: Urban-equivalent waste handled through municipal waste systems.

The report does not provide a breakdown between hazardous and non-hazardous waste categories.

Policies related to own workforce

NOS has established a comprehensive set of policies governing its own workforce, reflecting a commitment to fair working conditions, equal opportunities, and a safe and inclusive environment. All policies are approved by the Board of Directors and/or the Executive Committee and are publicly available on the institutional section of the company's website.

Human Rights Policy

Scope: All employees, partners, suppliers, customers, and the broader community directly or indirectly impacted by NOS operations. Applies to upstream, own operations, and downstream activities across all geographies where NOS operates.

Governance:

• Approved by: Executive Committee (acting under delegated authority from the Board of Directors)
• Implementation responsibility: Investor Relations & Sustainability Department; People & Organisation Department; Legal Department; Internal Audit, Risk, and Compliance Department
• Reporting: The "Investor Relations and Sustainability" area reports directly to the CFO regarding the Human Rights Policy

Key content/principles:

• Reaffirms NOS's commitment to safeguarding human and labour rights
• Respects existing national and international principles, standards, and legislation
• Reinforces commitments, guidelines, and requirements already established in the Code of Ethics and other corporate instruments
• Guarantees freedom of expression and association
• Promotes workplace equality
• Prohibits child labour and forced labour
• Ensures safe working conditions
• Applies to the entire value chain, involving employees, partners, suppliers, customers, and the community

International standards alignment:

• International Bill of Human Rights - Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social, and Cultural Rights
• International Labour Organization (ILO) Declaration
• UN Global Compact Principles
• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights
• WBCSD CEO Guide to Human Rights
• UN Human Rights Council
• Portuguese Charter of Human Rights in the Digital Age

Public availability: Corporate Website and Intranet

Monitoring: The company is taking the first steps in creating its formal Human Rights Due Diligence, having initiated a Screening process of suppliers. Risk assessment is conducted through the Integrated Management System and Double Materiality Assessment. No cases of non-compliance with Human Rights were identified in 2024.

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Gender Equality Plan

Scope: Own operations; all employees across all geographies where NOS operates (mainland Portugal and islands)

Governance:

• Approved by: Executive Committee (CHRO)
• Implementation responsibility: Executive Committee; People & Organisation Department; People Relations & Diversity Department (Diversity & Inclusion area)

Key content/principles:

• Defines NOS's commitment and goal towards equal treatment and opportunities for all employees
• Promotes the elimination of any form of discrimination based on gender
• Reviewed annually with various initiatives throughout the year
• Launched 2025 Gender Equality Plan with strategic measures to ensure gender equity across all areas

International standards alignment:

• United Nations Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), 1979
• Universal Declaration of Human Rights, 1948
• Charter of Fundamental Rights of the European Union
• Treaty on European Union
• Treaty on the Functioning of the European Union, Article 19 (fight against gender discrimination)
• European Pact for Gender Equality (2011-2020), adopted on 7 March 2011
• European Employment Strategy

Public availability: CMVM Website; Institutional Website; Intranet

Monitoring: The plan is reviewed annually and comprises various moments throughout the year, ensuring a continuous and evolving approach to promoting diversity and inclusion.

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Code of Ethics

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to all employees, suppliers and partners, and clients.

Governance:

• Approved by: Board of Directors
• Implementation responsibility: Ethics Committee; Corporate Governance and Sustainability Committee; Audit, Risk & Compliance Department; Legal Department
• Oversight: Ethics Committee monitors compliance with ethical standards, manages the whistleblowing channel, and provides clarifications on company policies

Key content/principles:

• Shares fundamental principles and rules that should govern internal and external relationships between NOS Group companies and their stakeholders
• Establishes values of professionalism, integrity, transparency, and independence
• First published in 2015, revised in 2020, and updated in 2022 to align with legislation on Prevention of Corruption and Related Offences
• Must be adhered to by all members of governing bodies and employees, as well as representatives and service providers to NOS Group
• Covers topics such as harassment, corruption, and fraud
• Clarifies whistleblowing channels

International standards alignment:

• Aligned with the United Nations Global Compact
• Universal Declaration of Human Rights
• International Labour Organization (ILO) Fundamental Principles and Rights at Work

Public availability: Institutional Website and Intranet

Monitoring:

• Ethics Committee manages the whistleblowing channel and provides clarifications
• Promotes "Let's Talk About Ethics" sessions addressing everyday ethical dilemmas
• Mandatory e-learning training on the Code of Ethics for all employees as part of onboarding process
• Annual indicators of activity for reporting and inquiry channels are compiled and disclosed internally
• In 2024, 16 inquiries were received and 23 alleged irregularities were reported, of which 12 were confirmed after investigation, leading to warnings, reprimands, or other sanctions

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Code of Conduct for the Prevention and Combat of Workplace Harassment

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to all employees, suppliers and partners, and clients.

Governance:

• Approved by: Ethics Committee (delegated by the Corporate Governance and Sustainability Committee)
• Implementation responsibility: Corporate Governance and Sustainability Committee; Ethics Committee; People & Organisation Department; Audit, Risk & Compliance Department; Legal Department

Key content/principles:

• Comprises principles and rules aimed at preventing and combating harassment behaviours or any other form of attacks on the dignity of employees or people they interact with
• Must be read alongside other existing policies, particularly the Code of Ethics and the Whistleblowing Regulations
• Reinforces the creation of safe and respectful work environments
• Establishes concrete measures to prevent and address workplace harassment

International standards alignment: Aligned with NOS Code of Ethics

Public availability: Institutional Website and Intranet

Monitoring: Managed through Ethics Committee oversight and confidential reporting mechanisms.

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Code of Conduct for the Prevention of Corruption and Related Offences

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to employees, suppliers and partners, and clients.

Governance:

• Approved by: Executive Committee (acting under delegated powers from the Board of Directors)
• Implementation responsibility: Corporate Governance and Sustainability Committee; RCN – Regulatory Compliance Officer; Audit, Risk & Compliance Department; Legal Department
• Designated person responsible: RCN – Regulatory Compliance Officer or CCO – Chief Compliance Officer, Filipa Santos Carvalho

Key content/principles:

• Establishes principles, values, and rules applicable across all NOS activities regarding corruption, influence peddling, and financial crimes
• Includes regulations on receiving and offering undue advantages
• Covers corruption, influence peddling, money laundering, fraud in obtaining or diverting subsidies, grants, or credit
• Incorporates rules for accepting and offering benefits
• Applies to all corporate body members, executives, and NOS employees, as well as all NOS representatives, Partners, and any entity or individual providing services to NOS
• Created and first published in 2022

International standards alignment: RGPC – General Regime for Corruption Prevention (DL 109-E/2021)

Public availability: Institutional Website and Intranet

Monitoring:

• RCN – Regulatory Compliance Officer is responsible for adoption and implementation
• Must be read alongside other policies, particularly the Code of Ethics and the Whistleblowing Regulations

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Prevention Plan for Risks of Corruption and Related Offenses

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to employees, suppliers and partners, and clients.

Governance:

• Approved by: RCN – Regulatory Compliance Officer (CCO – Chief Compliance Officer)
• Implementation responsibility: RCN – Regulatory Compliance Officer; Audit, Risk & Compliance Department; Legal Department

Key content/principles:

• Results from a legal obligation
• Must be interpreted alongside other policies, particularly the Code of Conduct for the Prevention of Corruption and Related Offences
• Enables NOS to identify potential corruption and related offence risks (RCIC)
• Establishes preventive and corrective measures to reduce their likelihood and impact
• Defines monitoring and evaluation mechanisms for the plan's effectiveness
• Creates a deterrent environment against any corrupt practices within NOS
• Identifies activities and business areas most susceptible to exposure to the risk of corruption
• Overall level of exposure ranges from low to medium, with no high-risk situations identified
• Created and first published in 2022

International standards alignment: RGPC – General Regime for Corruption Prevention (DL 109-E/2021)

Public availability: Institutional Website and Intranet

Monitoring: Risk assessment conducted by the Risk and Compliance area, which is responsible for internal control, including analysis, audit, and investigation of indications of irregularities related to ethics and corruption prevention.

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Whistleblowing Regulation

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to employees, suppliers and partners, and customers.

Governance:

• Approved by: Compliance Officer (CCO - Chief Compliance Officer)
• Implementation responsibility: Corporate Governance and Sustainability Committee; Compliance Officer; Risk and Compliance Audit Department; Legal Department

Key content/principles:

• Establishes a set of internal rules and procedures for receiving, recording, and handling reports of suspected irregularities
• Ensures compliance with applicable legal and regulatory provisions
• Aligns with the rules, principles, and values enshrined in the NOS Code of Ethics
• Guarantees anonymity and trust in the process
• Provides protection against retaliation for those who report in good faith
• Available 24/7 to receive reports and communications
• Published on NOS's website in both Portuguese and English

International standards alignment: General Regime for the Protection of Whistleblowers (Law 93/2021)

Public availability: Website and Intranet

Monitoring:

• All received communications are processed by Internal Audit
• Subsequently forwarded to the Ethics Committee or Supervisory Board, depending on the nature of the issue
• Strict confidentiality and non-retaliation policies in place
• Annual indicators disclosed internally to employees

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Diversity and Inclusion Commitment Statement

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates (mainland Portugal and islands). Applies to employees.

Governance:

• Approved by: Executive Committee (CHRO)
• Implementation responsibility: Executive Committee; People & Organisation Department; People Relations & Diversity Department (Diversity and Inclusion area)

Key content/principles:

• Materialises one of the strategic pillars of NOS's Sustainability Policy
• Enshrines the principle of valuing people
• Contains a set of principles that should guide behaviours, attitudes, and decisions of all governing bodies and employees
• Reinforces NOS's reputation among stakeholders
• Promotes diversity and inclusion
• Reviewed annually with initiatives throughout the year

International standards alignment:

• Compliance with National Legislation on the subject
• Portuguese Charter for Diversity
• EU Charter of Fundamental Rights

Public availability: Institutional Website and Intranet

Monitoring:

• Annual review with continuous initiatives
• In 2024, NOS reinforced its commitment to Diversity & Inclusion, implementing various initiatives
• Recognized with the Diversity Seal and Honorable Mention from APPDI
• Continuous monitoring through internal surveys, audits, and performance indicators

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Sustainability Policy

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to employees, suppliers and partners, and clients.

Governance:

• Approved by: Board of Directors
• Implementation responsibility: Corporate Governance and Sustainability Committee; Sustainability & Investor Relations Department; External Disclosures, Risk & Compliance Department; People & Organisation Department; Legal Department

Key content/principles:

• Includes an Occupational Health and Safety (OHS) Policy
• Provides a safe and healthy work environment
• Prevents risks, injuries, and incidents for all employees, suppliers, and partners
• Aligns with the principles of ISO 45001
• Ensures continuous improvement in working conditions and reduction of occupational risks

Public availability: Institutional Website

Monitoring:

• Certified management system aligned with ISO 45001 since 2015
• Periodic audits of certified management systems
• Risk management embedded in corporate governance based on Business Risk Model

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Risk Management Policy

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to employees, suppliers and partners, and clients.

Governance:

• Approved by: Board of Directors
• Implementation responsibility: Risk & Compliance Audit Department; Board of Directors (Audit and Finance Committee)

Public availability: Institutional Website and Intranet

Monitoring: Risk management embedded in corporate governance through the Business Risk Model, which structures the identification, mitigation, and monitoring of key risks, including those related to employee health and safety.

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Procurement Manual

Scope: Upstream activities across all geographies where NOS operates. Applies to employees and suppliers and partners.

Governance:

• Approved by: Executive Committee
• Implementation responsibility: Executive Committee; Procurement & Supply Chain Department

Key content/principles:

• Comprises the stages and principles applied in the acquisition processes of products and services
• Recognizes that the activity generates environmental and social impacts, including health and safety at work
• Requires suppliers and partners to comply with legislation applicable to their activity
• Requires suppliers and partners to internalise and act in accordance with the principles set out in the Code of Ethics

Public availability: Intranet (internal document exclusively for employees)

Monitoring: Ensures that suppliers maintain appropriate labor relations standards and encourages best practices in communication and problem resolution.

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Tax Policy

Scope: Own operations across all geographies where NOS operates. Applies to employees and shareholders/investors.

Governance:

• Approved by: Board of Directors
• Implementation responsibility: Accounts & Administration Director and team

Key content/principles:

• Establishes a framework of principles, values, and standards that guide the company's tax strategy
• Ensures strict compliance with all tax legislation and rules
• Monitors impacts of new legislative measures
• Protects shareholder interests and company reputation
• Ensures compliance with all tax obligations within stipulated deadlines
• Ensures proper and prudent interpretation of legislation in operations conducted
• Defends legitimate interests through administrative or judicial means when necessary
• Defines and implements frameworks for supervision, review, and control for the tax function

Public availability: Institutional Website and Intranet

Monitoring:

• Topic covered in training and information sharing moments, including tax legislation disclosed, information shared, and training for interns
• Zero cases of non-compliance in terms of Taxation reported in 2024

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Customer Privacy Policy

Scope: Upstream, own operations, and downstream activities across all geographies where NOS operates. Applies to employees, suppliers and partners, and customers.

Governance:

• Approved by: Executive Committee
• Implementation responsibility: Executive Committee; DPO - Data Protection Officer; Legal Department; Risk and Compliance Audit

Key content/principles:

• Enables employees, partners, suppliers, and customers to understand how the organisation collects, processes, and protects personal information
• Explains how personal data is handled for those who use NOS services

International standards alignment: GDPR - General Data Protection Regulation (EU Regulation 2016/679)

Public availability: Institutional Website and Intranet

Monitoring: DPO monitors compliance with data protection standards, cooperates with the National Data Protection Commission (CNPD), and acts as a point of contact for consumers and end users.

Taking action on material impacts on own workforce

NOS has implemented a structured approach to workforce management, promoting attraction, retention, and development of employees. The measures aim to mitigate material risks (dissatisfaction, lack of competitiveness, inequalities) while leveraging opportunities related to professional development and organizational well-being.

1. Salary Review

Description: Annual salary reviews ensuring fair and competitive compensation.

What it does: Maintains wage adequacy by considering inflation adjustments, market benchmarking, minimum wage updates, and internal promotions.

Scope: All NOS operations - all employees in mainland Portugal and the islands (own operations).

Time horizon: Annual reviews (ongoing)

Objective: Enhance fairness and NOS's attractiveness as an employer, mitigating risks of dissatisfaction and talent loss while promoting motivation, retention, and recognition.

2. Skills Development

Description: Continuous learning through NOS CAMPUS (corporate university).

What it does: Training delivered across four strategic areas: Leadership & Management, Technical & Digital, Technological, and Transversal skills.

Scope: Own operations

Time horizon: Ongoing (2024 programmes listed)

Key programmes in 2024:

• Leadership development
• Enhancement of performance and development models (continuous feedback culture)
• FAAST - Advanced Analytics Program (advanced data analysis and Generative AI concepts)
• Cloud Training (cloud computing technologies)
• Training for values alignment and risk management (ethical and compliance practices)

Resources allocated (non-financial):

• 32,120 total training hours provided to employees (2024)

Expected outcomes:

• Employee training: 32,120 total training hours
• Work-life balance index: 76% (improved from 70% in 2023)
• NOS recommendation index: 85% (up from 83% in 2023)

3. Talent Management Programmes

NOS Alfa Programme

Description: Trainee programme for young talent.

What it does: 12-month immersive experience through rotations across two business areas, complemented by structured mentoring.

Scope: Own operations

Time horizon: 12-month programmes (ongoing)

Resources (non-financial):

• 48 new trainees in 2024 (highest number since inception)
• 94 curricular and summer internships integrated

Expected outcomes: Onboarding week rating of 4.9 out of 5

Internal Mobility Programme

Description: Programme allowing employees to explore new roles within the organization.

What it does: Facilitates horizontal career moves, promotes broader business understanding, enhances progression opportunities.

Scope: Own operations

Time horizon: Ongoing (since 2020)

Expected outcomes: 793 mobility actions since 2020

4. Health and Well-being

NOS VITA Programme

Description: Holistic well-being programme across three dimensions: physical health, emotional health, and social health.

What it does: Personalized, holistic approach with various initiatives to inspire choices, empower change, and facilitate access to well-being activities.

Scope: Own operations (expanded reach in 2024)

Time horizon: Ongoing

Specific initiatives:

• Informative content on stress management, emotional intelligence, financial education
• Health and Well-being Days
• Health Month
• Mental health initiatives and support networks
• Psychosocial risk surveys

Expected outcomes: Work-life balance index 76% (2024), up from 70% (2023)

5. Diversity and Inclusion Initiatives

Description: Multiple programmes promoting equity, diversity, and inclusion.

What it does: Eliminates discrimination, promotes representation, creates inclusive workplace.

Scope: Own operations

Time horizon: Ongoing programmes, target by 2030

Key initiatives implemented:

• Membership in iGen Forum for Equal Organisations
• Diversity Seal & Honourable Mention by APPDI
• Partnership with PWN (Portugal Women Network)
• Partnership with APPDI
• Inclui conNOSco Podcast
• Inspiring Talks
• Extraordinary Women in Tech Conference
• Diversity Month
• Post-parental leave reintegration support
• 12th Grand Conference on Female Leadership
• Awareness and sensitisation sessions
• Neurodiversity Programme (partnership with two external companies to train, hire, and integrate autistic individuals)
• Cinemas & Valor T Project (recruiting individuals with disabilities across four locations)
• Strong HER - Self-esteem Club
• Women in Tech KIDS workshops
• STEM Labs – Engineers for a Day

Resources (non-financial):

• Partnerships with external organizations
• 3 employees recruited and trained under Neurodiversity Programme in 2024

Expected outcomes / KPIs:

• Current: 34% women in management positions (Directors and Managers)
• Target: 40% women in leadership positions by 2030

Link to policy: Gender Equality Plan (annual), Commitment to Diversity and Inclusion Statement

6. AI-Driven Operational Improvements

SCAILE Programme

Description: Strategic AI programme to scale impact across all areas of NOS.

What it does: Develops AI capabilities across customer service, network optimization, technical operations.

Scope: Own operations (company-wide)

Time horizon: 2024 onwards

Linked training:

• FAAST training programme (empowering people for AI goals)

Expected outcomes:

• Over 30 AI projects in production (2024)
• Spanning more than 10 operational domains
• First fully generative virtual assistant in Portuguese telecommunications market
• Enhanced customer experience
• Network energy consumption optimization

7. Employee Engagement and Feedback Systems

Description: Active listening mechanisms and feedback channels.

What it does: Ensures open dialogue, collects employee concerns and suggestions.

Scope: Own operations

Time horizon: Ongoing

Mechanisms:

• People Business Partner assigned to each department
• Exit interviews (offboarding)
• Regular psychosocial risk surveys
• Climate surveys
• Ethics Committee sessions (e.g., "Let's Talk About Ethics" - 4 meetings in 2024)

Resources (non-financial):

• Dedicated People Business Partner function
• Ethics Committee (100% attendance in 2024)

8. Ethical Culture and Compliance

Description: Training and awareness programmes on ethics and conduct.

What it does: Reinforces ethical standards, prevents harassment and discrimination.

Scope: Own operations and value chain (includes partners/suppliers)

Time horizon: Ongoing (part of onboarding for new employees)

Resources (non-financial):

• Mandatory e-learning training on Code of Ethics (harassment, corruption, fraud)
• Code of Conduct for Prevention and Combat of Workplace Harassment
• Ethics Committee oversight
• Confidential whistleblowing channels (24/7)

Link to policy: Code of Ethics, Code of Conduct for Prevention and Combat of Workplace Harassment

9. Talent Development and Retention Programme

Description: Consolidated programme based on aspirational, inclusive leadership and continuous feedback (2024).

What it does: Recognizes talent, promotes internal growth, focuses on future-oriented skills.

Scope: Own operations

Time horizon: Consolidated in 2024, ongoing

Link to policy: Human Rights Policy (published 2024), extends commitment across entire value chain

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Summary of Key Performance Indicators (2024)

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Monitoring and Effectiveness: All actions are monitored through specific indicators ensuring positive and sustainable impact. Progress is tracked annually and disclosed in public reports.

Targets related to own workforce

NOS has established a set of scheduled, results-oriented targets aligned with its 2025-2030 Sustainability Strategy, aiming to reduce negative impacts, enhance positive contributions, and mitigate material risks and opportunities related to its employees.

The targets were defined based on NOS's business strategy and internal consultation with employees and stakeholders. Monitoring is conducted annually using both quantitative and qualitative indicators.

Target 1: Female representation in leadership positions

Commitment: Ensuring equal opportunities, recognition, and transparent, merit-based evaluation for our people

This target applies to managers and directors, ensuring that female representation extends across all levels of management. To achieve this, NOS implements female talent development programs, inclusive recruitment policies, and mentorship initiatives that support women's progression into leadership roles.

Target 2: Ethics training coverage

Commitment: Acting ethically and responsibly with our employees, suppliers, and business partners, ensuring the highest standards of governance across our operations and supply chain

This initiative ensures that all employees understand and apply the ethical and regulatory principles that guide the company's operations, reinforcing an organizational culture rooted in integrity, transparency, and accountability.

Employee Characteristics

Total Employees: 1,827 employees (scope: all employees except cinema operators, interns, and governing bodies)

Gender Distribution:

• Men: 59%
• Women: 41%

Average Age: 42.9 years

Geographical Distribution:

• Lisboa: 66.6%
• Porto: 26.8%
• Others: 6.6%

Women in Management: 33.8% of women in Management and Top Management Positions

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

Scope of own workforce

NOS defines "own workforce" to include:

• Salaried employees: Workers with a direct contractual employment relationship with the company
• Independent workers: Individual contractors providing services directly to the company or workers supplied by entities engaged in temporary employment activities (NACE code N78)

Quantitative disclosures

No quantitative data on the number, breakdown by type, or characteristics of non-employee workers in NOS's own workforce is disclosed in the provided excerpts.

Contractual obligations for non-employees

NOS requires partner employees (subcontractors) to:

• Protect personal data and maintain confidentiality regarding NOS information
• Sign a "Responsibility Agreement on the Use of IT/IS, Confidentiality, and Personal Data Protection"
• Comply with "Supplier and Partner Sustainability Requirements" including obligations related to Information Security, Personal Data Privacy, and Business Continuity
• Access and process personal data only to the extent necessary, based on need-to-know principles

Partner companies acting as subcontractors sign Data Processing Agreements with NOS and are responsible for communicating and enforcing data protection rules with all employees providing services to NOS.

Collective bargaining coverage and social dialogue

Social dialogue structures

NOS maintains a structured and constructive relationship with trade unions and other labor representatives, promoting social dialogue and ensuring respect for freedom of association and collective bargaining.

Collective bargaining agreements

In the case of the NOS Cinemas business, a collective labor agreement is in place, regulating the relationship between the company and employee representatives, safeguarding workers' rights and interests.

Works councils and employee representation

The company ensures that employees have an active voice within the organization, through the existence of works councils and collective bargaining mechanisms.

Employee engagement channels

NOS employs a multichannel approach to internal communication, including in-person interactions, digital internal channels such as the corporate portal, newsletters, and internal events, as well as specialized tools for organizational climate studies and internal discussion forums.

Operational responsibility for ensuring dialogue is assigned to:

• Chief Resources & Human Officer (CRHO)
• People & Organization Director

Diversity Metrics

Gender Diversity:

• Overall workforce: 41% women, 59% men
• Women in Management and Top Management Positions: 33.8%

Public Commitment: NOS has committed to achieving 40% of women in leadership positions by 2030. Aware of the challenge given the sector in which we operate, we continue to build a pipeline of female talent.

Diversity and Inclusion Initiatives:

• Neurodiversity Programme: Partnership with Specialisterne Talent Programme to recruit and integrate people on the autism spectrum. Successfully recruited and trained three employees under this programme in 2024.
• Cinema Inclusion: Recruited and integrated individuals with disabilities or impairments across four cinema locations nationwide.
• Diversity Month: Celebrated in May 2024, reaffirming commitment to inclusion and equity, raising employee awareness of the importance of diversity.

Age Distribution: Average employee age of 42.9 years

Adequate wages

NOS's remuneration policy is guided by principles aligned with national and international best practices. The company regularly participates in benchmark studies on compensation and benefits trends to assess and enhance the competitiveness of its model.

Principles of NOS's Remuneration Policy

• Equity: Ensuring internal equity principles that support integration into a unified corporate culture
• Balance: Maintaining a balance between fixed and variable components within the remuneration structure
• Simplicity: Implementing a simplified remuneration structure that ensures clarity in communication
• Flexibility: Providing flexibility within defined rules to address differentiated situations
• Performance: Linking compensation to both individual and company performance
• Competitiveness: Ensuring competitive remuneration levels necessary to attract and retain talent

Benchmark and Coverage

NOS ensures that all its employees receive an adequate salary in accordance with applicable reference criteria. The only mandatory reference for the company's workforce is the National Minimum Wage, and 0% of salaried employees earn below this benchmark salary.

NOS invests in benefits with experiential and emotional impact beyond formal remuneration, providing a comprehensive compensation package.

Salary Review Process

NOS conducts annual salary reviews covering all operations and employees in mainland Portugal and the islands. The review considers:

• Inflation adjustments
• Market benchmarking
• Minimum wage updates
• Internal promotions

Persons with Disabilities

Neurodiversity Programme: NOS joined the Specialisterne Talent Programme, which aims to recruit and integrate people on the autism spectrum into our organisation. Our goal is to raise awareness among employees and society, facilitating the integration of neurodiverse individuals. We want these individuals to be valued for their potential and capabilities rather than being defined by their limitations, providing them with opportunities for professional development and growth. Successfully recruited and trained three employees under this programme in 2024.

Cinema Inclusion: Within our Cinemas division, we have recruited and integrated individuals with disabilities or impairments across four locations nationwide, furthering our commitment to an inclusive and diverse workplace.

Partnership with Valor T: NOS joined forces with Valor T to promote workplace inclusion by hiring and integrating individuals with diverse cognitive and motor abilities into NOS cinemas. As part of this initiative, teams have received inclusive recruitment training, reinforcing NOS's commitment to a more diverse, accessible, and equitable work environment.

Training and Skills Development

NOS CAMPUS: A dedicated learning space structured around four strategic areas: Leadership & Management, Technical & Digital, Technological, and Cross-functional. This platform offers a personalised learning journey tailored to each employee, ensuring a flexible and individualised approach aligned with their interests and professional development needs.

Leadership Development:

• Leadershift: A leadership programme that drives the development and empowerment of NOS leaders, reinforcing the strategic role of leaders as cultural transformation agents within the organisation, promoting a more agile, digital, and innovative approach.

Technical Training:

• FAAST Training Programme: Designed to elevate the organisation's analytical and technological knowledge in areas such as Machine Learning and Optimisation.
• FAAST Gen AI Edition: Launched in 2025, focusing on generative AI applications, ensuring widespread knowledge dissemination across NOS about the capabilities and potential of Generative AI.

Technology Certifications: Extensive certification programme for technology teams in customer experience, with major industry recognitions including:

• Cisco: Best Managed Services Provider in EMEA South
• Google Cloud Portugal: Best New Partner in 2023 and Demand Creation in 2024
• Microsoft: Achievement of all Azure designations
• Fortinet: Data centre specialisation

Performance and Development Model: Strengthened to ensure a culture of continuous feedback, essential for both individual and collective development.

Health and safety metrics

Coverage of health and safety management system

NOS operates a certified Occupational Health and Safety Management System (OHSMS) in accordance with ISO 45001. While the certification primarily covers Products and Services in the Corporate market segment, health and safety management processes and procedures are applied across the entire Group, impacting all employees as well as partner employees who work at NOS facilities or infrastructures occupied and/or managed by the company.

Fatalities

Recordable work-related accidents

Scope note: For reporting purposes, all work-related accidents resulting in lost days that occurred during the reporting period and were reported to the People and Organisation Department are considered.

Rate of recordable work-related accidents (per 1,000,000 hours)

Calculation: Frequency rate = (number of work-related accidents occurring during the reporting period / number of hours worked) × 1,000,000

Work-related illnesses

Lost days

Scope note: The number of lost days includes all absences resulting from work-related injuries and fatalities, covering work-related accidents, occupational health issues, and fatalities due to illness among salaried workers. In the calculation of lost days, all calendar days are considered, including weekends and public holidays, regardless of whether the employee was scheduled to work on those days.

Severity rate (lost days index)

Calculation: Severity rate = (number of lost days due to work-related accidents or occupational diseases during the reporting period / number of hours worked) × 1,000,000

Work-life balance metrics

Family-related leave and flexible work arrangements

NOS promotes a flexible model for work-life balance, providing flexible entry and exit hours along with a set of leave entitlements and benefits, including:

• Leave on the employee's birthday
• Morning leave on the first day of the new school cycle for employees with children up to 15 years old
• Full-day leave on December 24 and half-day leave on the afternoon of December 31

Post-parental leave support

NOS provides post-parental leave reintegration support as part of its diversity and inclusion initiatives.

Additionally, NOS introduced special leave for parents to accompany their children on the first day of school in 2023, reinforcing its commitment to work-life balance.

Well-being index

Work-life balance index: 76% (2024), improved from 70% in 2023

NOS recommendation index as a great place to work: 85% (2024), up from 83% in 2023

Coverage and methodology

All reported metrics apply to NOS's own workforce. The company conducts annual Climate Studies to assess employee satisfaction across various dimensions, including well-being and work-life balance. These results serve as strategic input for the People & Organization Department.

Compensation metrics (ESRS S1-16)

Pay gap

NOS regularly tracks gender pay equity indicators, ensuring an accurate assessment of gender equality within the company. By the end of 2024, the average salary ratio between women and men in both technology and non-technology areas stood at 99%.

Remuneration ratio

The following tables show the annual percentage change in directors' remuneration, the Company's performance and the average remuneration of employees from 2020 to 2024:

Annual Variation in Directors' Remuneration (%)

Average remuneration of full-time employees (%)

No explicit CEO-to-median remuneration ratio is disclosed.

Methodology

The average employee remuneration is calculated on the basis of the objective average remuneration of full-time employees in the company on 31 December of each year, excluding directors, trainees and workers in the cinema area, of all companies with more than 50% control by the Company.

The gender pay gap metric (99% ratio between women and men) reflects equality where a 100% ratio would indicate complete parity. This appears to indicate women earn approximately 99% of what men earn on average across both technology and non-technology areas.

Policies related to value chain workers

NOS acknowledges that responsible supply chain management is essential to ensuring fair working conditions, respect for human rights, and a safe and inclusive environment for all workers involved in its operations, whether directly or indirectly. The company's commitment extends beyond its own workforce, covering workers employed by suppliers, partners, and service providers.

NOS's policies for value chain workers have been developed to prevent and mitigate labor risks, fostering ethical and responsible business relationships. These guidelines include the protection of human rights, the guarantee of freedom of association and collective bargaining, the prohibition of child and forced labor, and the fight against any form of discrimination or labor exploitation.

Human Rights Policy

• Scope: Applies to employees, suppliers, and all company stakeholders
• Key content: Establishes fundamental principles of labor rights protection within the supply chain, including the prohibition of child and forced labor, the guarantee of safe working conditions, and the commitment to freedom of association
• International standards alignment: Aligned with the United Nations Guiding Principles on Business and Human Rights (UNGPs), the International Labour Organization (ILO) Declaration, and the Organisation for Economic Co-operation and Development (OECD) Guidelines
• Governance: As described in sections S1-1 and S2-1, NOS establishes responsibility for implementation of internal policies in the Executive Committee. The "Investor Relations and Sustainability" area is responsible for implementing these policies, reporting directly to the CFO regarding the Human Rights Policy

Sustainability Policy

• Key content: Defines NOS's approach to integrating environmental, social, and governance (ESG) criteria into its operations and commercial relationships, promoting responsible practices throughout the value chain

Code of Ethics

• Scope: Applies to the company and its partners
• Key content: Sets out the fundamental principles and values guiding the company and its partners, ensuring a joint commitment to ethics and social responsibility
• Availability: Summary version available for partners and suppliers

Code of Conduct for the Prevention and Combating of Workplace Harassment

• Key content: Reinforces the creation of safe and respectful work environments, applying both internally and in relationships with suppliers. Promotes diversity and prevents practices that violate the dignity of employees and partners

Code of Conduct for the Prevention of Corruption and Related Offenses

• Key content: Establishes clear rules to prevent corruption risks and unethical practices in procurement and supply processes
• Approval: Approved in 2022
• Availability: Publicly available on the NOS website
• Scope: Applies to all companies in the group

Procurement Manual

• Key content: Sets out criteria and requirements for supplier selection and management, ensuring compliance with NOS's sustainability and human rights policies. Regulates the processes of selection, adjudication, and evaluation of suppliers. Defines criteria for ethical and sustainable procurement

Sustainability Requirements for Suppliers and Partners

• Key content: Formalize NOS's expectations regarding its business partners' adoption of best environmental, social, and labor practices, ensuring that all workers in the value chain operate under dignified conditions

Whistleblowing Regulation for Reporting Irregularities

• Key content: Provides mechanism for reporting irregularities

Implementation and monitoring

NOS implements a supplier engagement program, evaluating compliance with human rights standards. The company conducts ESG surveys of suppliers, starting with the highest risk suppliers. This evaluation includes topics related to Human Rights, where suppliers are asked about:

• Internal policies that respect the UN Guiding Principles on Business and Human Rights (UNGPs)
• Human Rights Due Diligence Systems
• Prevention measures to avoid Human Rights violations
• Measures to ensure that slavery or human trafficking do not occur in their organisations

For suppliers whose performance falls below expectations, action plans and improvement modules are defined.

Within the scope of the 2021-2025 sustainability strategy, NOS has set a strategic goal to conduct environmental and social assessments of 100% of high-risk suppliers by 2025.

NOS has an Integrated Management System whose review cycle took place in 2024, as well as the assessment of Double Materiality, which allows the identification and mapping of risks and impacts concerning Human Rights.

NOS also provides training and awareness sessions to its employees, suppliers, and partners, addressing ethics issues, including those related to Human Rights.

Non-compliance

In 2024, no cases of non-compliance with Human Rights were identified, both in NOS's activities and in its value chain. To date, no non-compliance cases have been reported regarding the United Nations Guiding Principles, the ILO Declaration, or the OECD Guidelines.

Taking action on material impacts on value chain workers

NOS implements specific measures to promote better working conditions, ensure transparency across its value chain, and mitigate material risks for workers of its suppliers and partners. The company has established policies applying to its entire value chain with minimum standards for working conditions, labour rights, and ethical practices.

Infrastructure and Access Initiatives

Garage Access

• Action: Digital platform for booking parking spaces in NOS buildings
• Scope: Value chain workers (employees, service providers, and visitors)
• Resources: Free parking spots subject to availability
• Outcome: Greater equity in infrastructure access for all workers regardless of employment status

Workspace Infrastructure

• Action: Inclusive workspace design accommodating in-house staff and service providers
• Scope: Value chain workers operating in corporate spaces
• Resources: Meeting rooms, ergonomic workstations, reception areas, collaborative and rest areas
• Outcome: Optimal conditions for all professionals to perform their roles effectively

Capacity Building

Training Academies

• Action: Development of training academies for partner ecosystem
• Scope: Suppliers and partners across value chain
• Purpose: Ensure deep understanding of NOS's commercial offering and technical expertise for installation and provisioning
• Outcome: Alignment with NOS standards, professional development, and process standardisation across value chain

Monitoring and Remediation Mechanisms

Whistleblowing Channel

• Action: Confidential reporting channel for irregularities or human rights violations
• Scope: Any worker within the value chain
• Process: All reports thoroughly analysed with full whistleblower protection
• Link to policy: Cross-reference to section 1.3.4.1.1 Policies (G1-1)

Monitoring and Audits

• Action: Regular assessments with suppliers ensuring compliance with sustainability and social responsibility guidelines
• Scope: Supplier value chain
• Resources: Internal and external audits
• Outcome: Verification of NOS commitments fulfilment in supply chain

Corrective Action Plans

• Action: Implementation of improvement plans when non-conformities identified in supplier practices
• Scope: Suppliers failing to meet standards

ESG Assessment Programme

ESG Supplier Assessment Model

• Action: Distribution of ESG questionnaire and evaluation framework to suppliers
• Scope: Critical suppliers selected based on environmental, business, and geographic risk criteria
• Timeline: Started 2023; ongoing expansion toward 2030
• Initial coverage: 174 critical suppliers (2023)
• Target: 100% assessment by 2030 (referenced in context of broader ESG commitments)
• Outcome: Strengthened supplier engagement, promotion of responsible practices, and ESG transformation across value chain

Policy Framework

NOS applies the following policies throughout its value chain:

• Code of Conduct for the Prevention of Corruption and Related Offenses
• Whistleblowing Regulation for Reporting Irregularities
• Supplier engagement program evaluating human rights compliance

Effectiveness Monitoring

Ethical Performance Target

• Target: Annual improvement in employees' evaluation of company's ethical performance (extends to value chain context)
• 2024 result: Ethical operation index of 91% (organisational climate survey)
• Actions planned: Training initiatives, awareness-raising actions, reinforcement of ethical reporting and monitoring mechanisms
• Timeline: Annual monitoring

Non-Compliance

No non-compliance cases reported regarding United Nations Guiding Principles, ILO Declaration, or OECD Guidelines to date.

Targets related to value chain workers

NOS states that it has established "a set of time-bound and results-oriented targets, aligned with its 2025-2030 Sustainability Strategy, aimed at reducing negative impacts, enhancing positive impacts, and mitigating material risks and opportunities related to the workers in its value chain."

The document references that these targets reflect the company's commitment to fostering responsible practices in its supply chain, ensuring fair working conditions, transparency, and compliance with human rights and business ethics principles.

The excerpt states that "the definition of these targets is based on NOS's business strategy, engagement with suppliers and stakeholders, and international best practices" and that "the monitoring of these targets is conducted annually through quantitative and qualitative indicators."

However, no specific quantified targets are disclosed in the provided excerpts. The section "Strategic targets, commitments, and metrics" is mentioned but the actual targets, target values, baseline years, target years, or metrics are not included in the excerpts provided.

The document confirms targets exist and references the S2.MDR-T_01-13 disclosure requirement, but the specific details are not reproduced in these excerpts.

Policies related to affected communities

NOS acknowledges that its activities have a significant impact on the communities in which it operates and adopts a responsible approach to managing its relationship with affected communities. The company's commitment extends beyond direct operations, also covering communities impacted by suppliers, partners, and service providers, ensuring that principles of equity, transparency, and respect for human rights are promoted across its entire sphere of influence.

No significant changes were made to the policies during 2024.

In the specific context of managing impacts on communities, the following policies are particularly relevant:

Human Rights Policy

• Key content/principles: Ensures NOS's commitment to protecting and promoting the fundamental rights of communities impacted by its activities, safeguarding well-being, diversity, and international human rights principles
• Links to international standards: Aligned with the International Bill of Human Rights, the ILO Declaration, the United Nations Global Compact Principles, the OECD Guidelines for Multinational Enterprises, and the United Nations Guiding Principles on Business and Human Rights. At national and European levels, adheres to the Portuguese Charter of Human Rights in the Digital Age and the Charter of Fundamental Rights of the European Union
• Note: NOS is a signatory of the CEO Guide to Human Rights. In 2022, the company conducted an assessment of actual and potential human rights impacts of its activities

Code of Ethics

• Key content/principles: Establishes the values and principles that guide the company's actions and its relationship with communities, promoting transparency, social responsibility, and active engagement with local stakeholders

Code of Conduct for the Prevention of Corruption and Related Offences

• Key content/principles: Sets out guidelines to ensure that all interactions between the company, communities, and local stakeholders are conducted with integrity and in full compliance with applicable legislation

Sustainability Policy

• Key content/principles: Integrates the community perspective into NOS's strategy, promoting initiatives that contribute to the socio-economic development and environmental preservation of the regions where the company operates

Risk Management Policy

• Key content/principles: Includes the assessment and mitigation of potential socio-economic and environmental impacts on communities, ensuring that the company's actions generate shared value while minimising negative externalities

Implementation and monitoring

NOS actively implements measures to prevent negative human rights impacts and, should they occur, acts swiftly and effectively to mitigate their effects. The company promotes cooperation and encourages stakeholders to uphold fundamental values, and reserves the right to terminate relationships with any parties that are proven or suspected to violate these values, while respecting the principles of proportionality and recurrence.

Detailed information on each policy can be found in section 1.3.1.12. Policies (MDR-P), with additional information on Human Rights commitments available in sections 1.3.3.1.2. Policies (S1-1) and 1.3.3.2.2. Policies (S2-1).

Taking action on material impacts on affected communities

Approach to sustainable innovation

Innovation is one of NOS's key assets, positioning it as one of Portugal's leading innovators. Guided by its sustainability strategy, a significant portion of NOS's innovation efforts is channelled into projects that generate environmental and/or social value, allowing the company to combine competitiveness with contributions to the United Nations Sustainable Development Goals (SDGs).

Technological pillars:

• 5G Technology
• IoT (Internet of Things), particularly NB IoT
• Smart city solutions

Named initiatives mentioned:

• Test Bed 5G & Digital Transformation: Further groundbreaking advancements in healthcare and implementation of smart services in Portuguese cities and towns
• Smart Cities Programme: Transforms urban areas into more efficient and sustainable environments
• Voice Leadership Programme: Run in partnership with Nova Business School, equipping business leaders with better understanding of community dynamics
• Technology events providing SMEs with opportunities to share feedback

Social and educational support

Community impact:

• In 2024, through multiple contributions to associations and social integration projects focused on capacity-building, NOS positively impacted over 22,000 people, strengthening social and educational initiatives

Partner organizations:

• Scholarships to students in financial need
• Bagos d'Ouro Association: Funding increased in 2024, allowing 30 additional young people from Mesão Frio, Douro, to receive educational support

Employee volunteering initiatives

Goods collection campaign (World Day of Social Justice):

• Two-week goods collection for Vida Norte
• Donations included hygiene products, food, clothing, and childcare essentials
• Target: Pregnant women and babies in vulnerable situations

Community dinners:

• Partnership with Serve The City
• Locations: Lisbon and Porto
• Over 200 meals served to individuals in vulnerable situations

Food bank campaigns:

• Participation in food collection drives in Lisbon and Porto
• Hundreds of employees joined

Solidarity Cellar:

• Annual holiday initiative converting partner gifts into donations
• All proceeds donated to NOS's partner organisations

Monitoring and evaluation systems

ESG Scorecard:

• Implemented following approval of NOS's 2025-2030 sustainability strategy
• Structured around key strategic pillars
• Results systematically presented to Executive Committee and Board of Directors
• Strategic KPIs monitor implementation, performance, and objective achievement

Integrated Management System:

• ISO 9001: Quality Management System
• ISO 14001: Environmental Management System
• ISO 45001: Occupational Health and Safety Management System
• ISO 27001: Information Security Management System
• ISO 20000: IT Service Management System

Evaluation approach:

• For institutional and regulatory engagements: Directorate's Action and Resource Plan (annual targets, executive board oversight)
• For social impact projects: Progress meetings with partner institutions to assess results and adjust actions
• Post-implementation joint reviews to ensure positive impacts align with community expectations

Accessibility and digital inclusion

Specific focus on rural and isolated areas, with community consultations carried out at varying frequencies depending on needs and strategic objectives.

Targets related to affected communities

NOS has established measurable targets associated with its commitments to community management. These targets directly contribute to the identified material impacts, risks and opportunities (IROs) and will be monitored systematically to ensure effective implementation.

Target 1: €500K investment in 5G social initiatives by 2030

Commitment: Leveraging NOS's strategic assets and competencies to create impact in local communities through support for institutions and social responsibility initiatives.

• Target metric: Investment in social initiatives powered by 5G technology
• Target value: €500,000
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed (builds upon investment in 5G for Good initiatives up to 2024)
• Scope: Social initiatives using 5G technology to support socially vulnerable individuals or communities; includes projects promoting education, healthcare, digital accessibility, and connectivity in underserved regions
• Type: Absolute (total investment amount)
• Validation: Internal (identified through NOS 5G Task Force in collaboration with partner institutions)
• Progress to date: No results reported yet as commitment was established within the 2025-2030 strategic cycle

Implementation details:

• Projects must use 5G as an enabler for supporting socially vulnerable individuals or communities
• Total investment is budgeted and reported annually
• Impact may vary based on solution scalability and customization needs
• Solutions have mass adoption potential for replication and broader application

Target 2: 200 institutions supported by 2030

Commitment: Leveraging NOS's strategic assets and competencies to create impact in local communities through support for institutions and social responsibility initiatives.

• Target metric: Number of institutions supported
• Target value: 200 institutions
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Institutions within local communities
• Type: Absolute (total number of institutions)
• Validation: Internal
• Progress to date: Not disclosed

Policies related to consumers and end-users

NOS acknowledges that its operations have a significant impact on consumers and end users of its services. The company adopts a responsible approach to customer relationship management, ensuring that quality, security, accessibility, and the protection of consumer rights are upheld in all interactions.

NOS's commitment extends beyond the provision of products and services, encompassing the promotion of an inclusive, transparent, and secure digital experience. Through policies and practices, the company strives to mitigate risks that may affect consumers and end users, ensuring that privacy and data protection remain core principles of operations.

In the specific context of impact management for consumers and end users, the following key policies stand out:

Information Security Policy

• Key content/principles: Sets out the principles and measures to ensure the confidentiality, integrity, and availability of customer data, providing protection against digital threats and cyberattacks
• Public availability: Detailed information can be found in section 1.3.1.12. Policies (MDR-P)

Customer Privacy Policy

• Key content/principles: Defines NOS's commitments regarding the collection, use, and protection of consumers' personal data, ensuring transparency and compliance with data protection regulations
• Public availability: Detailed information can be found in section 1.3.1.12. Policies (MDR-P)

Privacy and Personal Data Protection Commitment Statement

• Key content/principles: Reinforces the company's priority to safeguard user privacy and data security, fully aligning with the principles of the General Data Protection Regulation (GDPR)
• Public availability: Detailed information can be found in section 1.3.1.12. Policies (MDR-P)

Human Rights Policy

• Key content/principles: Guarantees the protection of consumers' fundamental rights, ensuring fair and non-discriminatory practices in accessing NOS's services. The company rejects discrimination based on race, nationality, culture, religion, sex, gender, sexual orientation, age, socio-economic status, educational background, ethnicity, or any physical or mental disability
• Links to international standards: Aligned with the United Nations Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises, the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Civil, Political, Economic, Social, and Cultural Rights), the Portuguese Charter of Human Rights in the Digital Age, and the Charter of Fundamental Rights of the European Union. NOS is a signatory of the CEO Guide on Human Rights by the World Business Council for Sustainable Development (WBCSD)
• Public availability: Detailed information can be found in section 1.3.1.12. Policies (MDR-P)
• Monitoring: Commitment operationalised through continuous assessment processes, which identify current and potential human rights impacts

Sustainability Policy

• Key content/principles: Incorporates consumer perspectives into the company's strategy, promoting innovative and sustainable solutions that enhance accessibility and digital inclusion
• Public availability: Detailed information can be found in section 1.3.1.12. Policies (MDR-P)

Diversity and Inclusion Commitment Statement

• Key content/principles: Ensures that NOS products and services are designed to be accessible and inclusive, guaranteeing equal opportunities for all consumers, regardless of their background, gender, or social status
• Public availability: Detailed information can be found in section 1.3.1.12. Policies (MDR-P)

Additional commitments

NOS ensures strict compliance with the General Data Protection Regulation (GDPR) and other relevant security and privacy regulations to safeguard the fundamental right to privacy and freedom of expression. The company promotes responsible use of its products and services, offering specific solutions for vulnerable groups, including people with disabilities, children, and adolescents. These initiatives feature functions that prevent exposure to abusive content, illegal activities, and excessive technology use.

Digital inclusion and technological literacy are strategic priorities, with programmes aimed at empowering segments of the population with limited access to technology, supported by awareness campaigns on security and privacy.

NOS follows the precautionary principle concerning potential adverse health effects of telecommunications infrastructure and equipment, providing clear information to enable informed consumer decisions.

Taking action on material impacts on consumers

NOS recognises the importance of ensuring a safe, inclusive, and transparent experience for its consumers and end users. The company implements various measures to manage and mitigate material impacts on consumers and end users, ensuring that its product and service offerings are developed in line with high standards of quality, data protection, privacy, and digital inclusion.

Security and Privacy

Governance approach

The NOS Security and Privacy (S&P) governance model is based on the Three Lines of Defence model to ensure an effective and segregated distribution of responsibilities within the organisation. The Executive Committee holds ultimate responsibility for this matter within the organisation.

The Information Security Policy (ISP) serves as the guiding framework that defines the organisation's overall S&P stance. It includes the General Information Security Policy and all other S&P regulations and documents, structured within a hierarchical framework.

Key actions in 2024:

E-learnings on "Security & Privacy" for employees

• Description: Continued implementation of the training plan for all employees and partners, which includes the completion of e-learnings on "Security & Privacy"
• Scope: Own operations and partners
• Outcome: The completion rate for the e-learnings was 83%, both for NOS employees and for partner employees

S&P by design in transformational, structuring projects

• Description: Continued integration of S&P by Design requirements in transformational, structuring projects
• Application areas: Advanced Analytics, Go to Cloud, and Digital Marketing
• Scope: Own operations

Strengthening cybersecurity capabilities

• Description: Continued enhancement of the Cybersecurity team across its various specialties, with the goal of consolidating the model for identifying and mitigating risks and promoting the development of cross-functional capabilities
• Key elements:
  • Ongoing reinforcement of the set of technological tools used for prevention, detection, and response to cybersecurity incidents (e.g., Endpoint Detection and Response, Threat Intelligence, Vulnerability Management)
  • Continued proactive actions to identify security vulnerabilities as quickly as possible
  • Strengthening the Vulnerability Management process
• Resources: Non-financial - team enhancement across various specialties; technological tools investment (not quantified)

ISO27001 recertification - Information security

• Description: NOS secured recertification under the "ISO27001 - Information Security Management System" standard
• Coverage: Business processes related to installation, activation, account management, service requests, billing, and customer collections in the B2C (Residential) and B2B (Enterprise) market segments; and security processes related to NOS Data Center services (Housing Services)
• Scope: Own operations

Actions supporting the sustainability of the Portuguese business sector

NOS positions itself as a partner for the digital transformation of its enterprise clients, working alongside the Portuguese technology ecosystem on multiple projects aimed at capitalising on the gains digitalisation can bring to the competitiveness and sustainability of businesses across various sectors.

NOS Smart Home solution

• Description: Solution particularly for the real estate development sector
• Scope: Downstream value chain (enterprise clients)

Targets related to consumers

Overview

NOS has set measurable goals associated with its commitments to managing its consumers and end users. These goals directly contribute to the identified material IROs and will be monitored in a structured way to ensure their effective execution.

Target 1: 5G Coverage in All Municipalities

Commitment: Benefit local communities with the extension of our Next-Generation Networks FttH and 5G

Additional context:

• Strategic plan to achieve over 90% coverage in the least populated municipalities by end of 2025, in compliance with regulatory requirements of ANACOM
• Goal set with involvement of NOS employees
• Implementation will be continuously monitored

Target 2: Investment in 5G Infrastructure

Commitment: Benefit local communities with the extension of our Next-Generation FttH and 5G networks

Additional context:

• Investment will enable continuous expansion of 5G network nationally
• Aims to ensure greater coverage, performance, and service quality

Business conduct policies and corporate culture

NOS's approach to business conduct and corporate culture is structured around multiple policies and codes that guide ethical behavior, human rights, anti-corruption measures, and supplier relationships. The policies are approved by the Board of Directors and/or Executive Committee and are publicly available on the company's institutional website.

Code of Ethics

• Scope: Applies to all members of governing bodies and employees of NOS Group companies, as well as all those representing or providing services to NOS Group on a permanent or temporary basis
• Governance: Managed by the Ethics Committee (delegated by the Corporate Governance and Sustainability Committee); implementation involves People & Organisation Department, Audit, Risk & Compliance Department, and Legal Department
• Key content: Covers meritocracy, team spirit, legal and regulatory compliance, proper use of resources and information, prevention of corruption and related offenses, conflicts of interest, fair competition, respect for human and labour rights, diversity and equal opportunities, non-discrimination, prevention of moral and sexual harassment, transparency in accountability, privacy, civic conduct, and environmentally and socially sustainable conduct
• Public availability: Corporate Website and Intranet
• International alignment: Aligned with Portuguese Institute of Corporate Governance (IPCG) Corporate Governance Code
• Monitoring: Annual ethics action plans including mandatory e-learning training (97% completion rate by end of 2024); "Let's Talk About Ethics" sessions; ethics inquiry channel (duvidas.etica@nos.pt) and irregularities reporting channel (comunicar.irregularidades@nos.pt)
• First published: 2015, revised in 2020 and 2022

Code of Ethics – Summary Version for Partners and Suppliers

• Scope: Applies to suppliers and partners
• Governance: Ethics Committee (delegated by the Corporate Governance and Sustainability Committee); People & Organisation Department; Audit, Risk & Compliance Department; Legal Department
• Key content: Summary version promoting understanding and adoption of the principles and rules described in the Code of Ethics by suppliers and partners
• Public availability: Institutional Website and Intranet
• International alignment: Aligned with NOS Code of Ethics
• Monitoring: Since 2016, NOS provides this summary version to suppliers and partners, who must ensure strict compliance

Code of Conduct for the Prevention and Combat of Workplace Harassment

• Scope: All geographies where NOS operates; applies to employees, suppliers and partners, and clients
• Governance: Ethics Committee (delegated by the Corporate Governance and Sustainability Committee); People & Organisation Department; Audit, Risk & Compliance Department; Legal Department
• Key content: Comprises principles and rules aimed at preventing and, where necessary, combating harassment behaviours or any other form of attacks on the dignity of employees or the people they interact with
• Public availability: Institutional Website and Intranet
• International alignment: Aligned with NOS Code of Ethics

Code of Conduct for the Prevention of Corruption and Related Offences

• Scope: All geographies where NOS operates; applies to all corporate body members, executives, and NOS employees, as well as NOS representatives, Partners, and any entity or individual providing services to NOS on a permanent or temporary basis
• Governance: Executive Committee (acting under delegated powers from the Board of Directors); Regulatory Compliance Officer (RCN) / Chief Compliance Officer (CCO) - Filipa Santos Carvalho designated as responsible; Audit, Risk & Compliance Department; Legal Department
• Key content: Establishes principles, values, and rules applicable across all NOS activities regarding regulations on receiving and offering undue advantages, corruption, influence peddling, financial crimes including money laundering or fraud. Incorporates rules for accepting and offering benefits
• Public availability: Institutional Website and Intranet
• International alignment: RGPC – General Regime for Corruption Prevention (DL 109-E/2021)
• Monitoring: Designated RCN/CCO responsible for adoption and implementation; to be read alongside Code of Ethics and Whistleblowing Regulations
• First published: 2022

Prevention Plan for Risks of Corruption and Related Offenses

• Scope: All geographies where NOS operates; applies to employees, suppliers and partners, and clients
• Governance: RCN – Regulatory Compliance Officer (CCO – Chief Compliance Officer); Audit, Risk & Compliance Department; Legal Department
• Key content: Enables NOS to identify potential corruption and related offence risks (RCIC), establish preventive and corrective measures to reduce their likelihood and impact, define monitoring and evaluation mechanisms for the plan's effectiveness, and create a deterrent environment against any corrupt practices within NOS. Risk assessment identifies activities and business areas most susceptible to exposure (overall exposure ranges from low to medium, with no high-risk situations identified)
• Public availability: Institutional Website and Intranet
• International alignment: RGPC – General Regime for Corruption Prevention (DL 109-E/2021)
• First published: 2022

Whistleblowing Regulation

• Scope: All geographies where NOS operates; available to employees, suppliers and partners, and customers
• Governance: Compliance Officer (CCO - Chief Compliance Officer); Corporate Governance and Sustainability Committee; Risk and Compliance Audit Department; Legal Department
• Key content: Establishes internal rules and procedures for receiving, recording, and handling reports of suspected irregularities received by the company, in compliance with applicable legal and regulatory provisions and the rules, principles, and values enshrined in the NOS Code of Ethics
• Public availability: Website and Intranet
• International alignment: General Regime for the Protection of Whistleblowers (Law 93/2021)
• Monitoring: Channels available 24/7; all communications processed by Internal Audit and forwarded to Ethics Committee or Supervisory Board depending on nature; confidentiality and protection against retaliation guaranteed; 16 inquiries and 23 alleged irregularities reported in 2024 (12 confirmed after investigation)

Diversity and Inclusion Commitment Statement

• Scope: Own operations; all geographies where NOS operates; applies to employees, suppliers and partners
• Governance: Executive Committee (CHRO); People & Organisation Department; People Relations & Diversity Department (Diversity and Inclusion area)
• Key content: Materialises one of the strategic pillars of NOS's Sustainability Policy, enshrining the principle of valuing people. Contains principles that should guide behaviours, attitudes, and decisions of all governing bodies and employees of NOS Group companies, reinforcing NOS's reputation among stakeholders
• Public availability: Institutional Website and Intranet
• International alignment: Compliance with National Legislation; Portuguese Charter for Diversity; EU Charter of Fundamental Rights

Procurement Manual

• Scope: Upstream; all geographies where NOS operates; applies to employees, suppliers and partners
• Governance: Executive Committee; Procurement & Supply Chain Department
• Key content: Comprises the stages and principles applied in the acquisition processes of products and services. Recognises that activity generates environmental and social impacts including health and safety at work, requiring suppliers and partners to comply with applicable legislation and act in accordance with NOS Code of Ethics principles
• Public availability: Intranet

Customer Privacy Policy

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, and customers
• Governance: Executive Committee; DPO - Data Protection Officer; Legal Department; Risk and Compliance Audit Department
• Key content: Enables employees, partners, suppliers, and customers to understand how NOS collects, processes, and protects personal information provided by all those who use NOS services
• Public availability: Institutional Website and Intranet
• International alignment: GDPR - General Data Protection Regulation (EU Regulation 2016/679)

Privacy and Personal Data Protection Commitment Statement

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, and customers
• Governance: Executive Committee; DPO - Data Protection Officer; Legal Department; Risk and Compliance Audit Department
• Key content: Details NOS's commitment to privacy, security, and data protection, ensuring that all individuals who process personal data in their relationship with NOS subscribe to and act in accordance with the principles underlying this commitment
• Public availability: Institutional Website and Intranet
• International alignment: GDPR - General Data Protection Regulation (EU Regulation 2016/679)

Responsible Online Presence Guide

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, and customers
• Governance: Ethics Committee (by delegation of the Corporate Governance and Sustainability Committee); People & Organisation Department; Corporate Communication Department; Brand & Communication Department
• Key content: Supports and guides expected conduct when acting in a professional context or representing NOS. Clarifies what employees can and cannot publish on social media involving the NOS brand, respecting freedom of expression and individual privacy. As an integral part of the NOS Code of Ethics, complements the principles and rules established therein
• Public availability: Intranet
• International alignment: Aligned with the NOS Code of Ethics

Responsible Online Presence Guide – Version for Partners and Suppliers

• Scope: Upstream; all geographies where NOS operates; applies to suppliers and partners
• Governance: Ethics Committee (by delegation of the Corporate Governance and Sustainability Committee); People & Organisation Department; Corporate Communication Department; Brand & Communication Department
• Key content: Developed to help partners and suppliers understand how they should act and what their employees can and cannot post involving the NOS brand when using social media to talk about NOS, as they influence how others perceive the company
• Public availability: Intranet
• International alignment: Aligned with the NOS Code of Ethics

Human Rights Policy

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, and customers
• Governance: Executive Committee (acting under delegated authority from the Board of Directors); Investor Relations & Sustainability Department; People & Organisation Department; Legal Department; Internal Audit, Risk, and Compliance Department
• Key content: Reaffirms NOS's commitment to safeguarding human and labour rights, respecting existing national and international principles, standards, and legislation. Reinforces commitments, guidelines, and requirements already established in NOS's Code of Ethics and other corporate codes, policies, and instruments
• Public availability: Corporate Website and Intranet
• International alignment: International Bill of Human Rights - Universal Declaration of Human Rights; International Covenant on Civil and Political Rights; International Covenant on Economic, Social, and Cultural Rights; International Labour Organization (ILO) Declaration; UN Global Compact Principles; OECD Guidelines for Multinational Enterprises; UN Guiding Principles on Business and Human Rights; WBCSD CEO Guide to Human Rights; UN Human Rights Council; Portuguese Charter of Human Rights in the Digital Age
• Monitoring: Screening process of suppliers initiated in 2023; ESG survey includes Human Rights topics; commitment to conduct environmental and social assessments of 100% of high-risk suppliers by 2025; Integrated Management System review cycle; zero cases of non-compliance identified in 2024

Gender Equality Plan

• Scope: Own operations; all geographies where NOS operates; applies to employees, suppliers and partners
• Governance: Executive Committee (CHRO); People & Organisation Department; People Relations & Diversity Department (Diversity & Inclusion area)
• Key content: Defines NOS' commitment and goal towards equal treatment and opportunities for all its people, promoting the elimination of any form of discrimination based on gender. Developed annually
• Public availability: CMVM Website; Institutional Website; Intranet
• International alignment: United Nations Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), 1979; Universal Declaration of Human Rights, 1948; Charter of Fundamental Rights of the European Union; Treaty on European Union; Treaty on the Functioning of the European Union, Article 19; European Pact for Gender Equality (2011-2020); European Employment Strategy; Europe 2020 Growth Strategy; Women's Charter; Fundamental Rights and various EU directives and national legislation

Risk Management Policy

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, and customers
• Governance: Executive Committee (under the delegated authority of the Board of Directors); Audit, Risk & Compliance Department
• Key content: Part of NOS's Corporate Governance instruments. Aims to define the risk management system, including methodologies, key processes related to risk management and monitoring, involved entities, and their responsibilities
• Public availability: Corporate Website and Intranet
• International alignment: Portuguese Institute of Corporate Governance (IPCG) Corporate Governance Code

General Information Security Policy

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners
• Governance: Executive Committee; Chief Information Security Officer (CISO); Audit, Risk & Compliance Department
• Key content: Establishes the Information Security Principles to be followed by Employees and Suppliers & Partners, as well as the levels and security domains, including their control objectives
• Public availability: Corporate Website and Intranet
• International alignment: ISO 27001:2013 Information Security Management System; Regulation on the Security and Integrity of Electronic Communications Networks and Services (ANACOM Regulation No. 303/2019)

Tax Policy

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, customers, shareholders and investors, governmental entities and regulators
• Governance: Executive Committee (under the delegated authority of the Board of Directors); Financial & Assurance Services Department
• Key content: Consolidates NOS Group's tax strategy and commitment to tax regulations and the application of best tax practices, fostering collaboration and cooperation with Tax Authorities. Aims to ensure compliance with applicable tax legislation and standards, adequately coordinate tax practices across Group entities, considering corporate interest and ensuring achievement of long-term objectives, avoiding tax risks and inefficiencies in decision-making, thereby maximising value creation for shareholders
• Public availability: Corporate Website and Intranet
• International alignment: Applicable tax legislation and standards
• Monitoring: Zero cases of non-compliance in 2024; training and information sharing including tax legislation disclosure

Sustainability Policy

• Scope: Upstream, own operations, downstream; all geographies where NOS operates; applies to employees, suppliers and partners, customers
• Governance: Executive Committee (CFO); Investor Relations & Sustainability Department; Sustainability area
• Key content: Establishes NOS's approach to integrating environmental, social, and governance (ESG) criteria into operations and commercial relationships, promoting responsible practices throughout the value chain
• Public availability: Corporate Website and Intranet
• International alignment: United Nations Global Compact; Sustainable Development Goals; Paris Agreement

Sustainability Requirements for Suppliers and Partners

• Scope: Upstream; all geographies where NOS operates; applies to suppliers and partners
• Governance: Executive Committee; Procurement & Supply Chain Department; Investor Relations & Sustainability Department
• Key content: Document created to complement and detail the commitments in the Sustainability Policy and applicable to NOS Suppliers and Partners. Includes guidelines related to Environment, Social, and Governance areas (including topics such as Emissions, Energy, Circularity, Waste, Water Resources, Health & Safety, Security, Quality, Service Management, etc.), encouraging adoption of measures to reduce environmental impacts, promote fair working conditions, and ensure ethical and compliance-driven practices. All NOS Suppliers and Partners required to comply with applicable legal requirements, adopt best sustainability practices, act in accordance with NOS's Code of Ethics, collaborate in improving environmental and social performance of NOS products and services, participate in NOS supplier evaluation processes, and provide information on their environmental and social objectives and performance. Environmental pillar identifies energy and emissions, as well as waste, as key focus areas
• Public availability: Corporate Website and Intranet
• International alignment: United Nations Global Compact; Sustainable Development Goals; Paris Agreement

Corporate Culture Assessment and Monitoring

NOS conducts annual evaluations of organizational culture, analyzing learning, employee satisfaction, and ethical conduct. The Board of Directors and internal committees conduct annual self-assessments on diversity, skills, and representativeness. The company has been externally recognized through awards and certifications including Bloomberg Gender-Equality Index, CDP Climate Change, ISS Quality Score, Moody's ESG Solutions, and MSCI ESG Ratings.

Reporting Channels

NOS provides dedicated channels available 24/7:

• Ethics inquiry channel: duvidas.etica@nos.pt
• Irregularities reporting: comunicar.irregularidades@nos.pt or Apartado 4035, Loja CTT Senhora da Hora, 4461-901 Senhora da Hora
• Available in Portuguese and English on NOS website and intranet
• Confidentiality and protection against retaliation guaranteed
• Anonymous reporting permitted
• In 2024: 16 inquiries received; 23 alleged irregularities reported (12 confirmed after investigation, leading to warnings, reprimands, or other sanctions)

Training and Awareness

NOS implements annual ethics action plans including:

• Mandatory e-learning on Code of Ethics: Completed by 97% of employees by end of 2024; part of onboarding process; includes individual commitment declaration
• "Let's Talk About Ethics" sessions: Open discussions on business ethics with Ethics Committee participation; 2024 edition had approximately 250 employees, focusing on Psychological Safety
• Training for suppliers and partners: More than 6,200 employees from partner organizations completed ethics training in 2023

Alignment with International Standards

NOS's business conduct policies are aligned with:

• UN Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises
• International Labour Organization (ILO) Declaration and Conventions
• UN Global Compact Principles
• International Bill of Human Rights
• WBCSD CEO Guide to Human Rights
• General Data Protection Regulation (GDPR)
• Portuguese legislation on corruption prevention, whistleblower protection, and corporate governance

2025-2030 Strategic Commitments

NOS has established time-bound targets including:

• Achieve 100% awareness on business conduct and ethics among employees by 2030
• Maintain comprehensive ethics training and communication programs
• Continue annual monitoring and reporting of ethics indicators

Prevention and detection of corruption and bribery

NOS does not disclose any named policies specifically dedicated to the prevention and detection of corruption and bribery in the provided excerpts.

The excerpts indicate that:

• The company's risk management and internal control system encompasses "Ethics and Corruption Prevention" as one of various types of risks monitored
• The supplier/partner questionnaire includes "Anti-Corruption policies and measures" as an area of analysis
• Training programmes for partners cover "Ethics" among other topics
• An "Ethics channel" exists (though no details are provided)

However, no specific anti-corruption or anti-bribery policy is named, and no details are provided regarding policy scope, governance, content, public availability, alignment with international standards, or monitoring mechanisms for corruption and bribery prevention.

Incidents of corruption or bribery

Confirmed incidents

In 2024, no cases of non-compliance in terms of Corruption and Bribery were identified, both in NOS's operations and in its value chain.

Convictions and fines

Not disclosed.

Disciplinary actions

NOS has disciplinary procedures in place to sanction irregularities related to compliance with the Code of Ethics and/or Code of Conduct for the Prevention of Corruption and Related Offences. After investigation, sanctions may result in a warning, reprimand, or other type of sanction. However, no specific incidents requiring disciplinary action were reported in 2024.

Contracts terminated

Not disclosed.

Investigation procedures and speak-up mechanisms

NOS maintains a Whistleblowing Regulation that establishes clear rules for receiving, recording, and processing reports. The company provides dedicated channels for reporting:

• Email: comunicar.irregularidades@nos.pt
• Postal address: Apartado 4035, Loja CTT Senhora da Hora, 4461-901 Senhora da Hora
• Clarification requests: duvidas.etica@nos.pt

These channels are available 24/7 in both Portuguese and English. All communications are treated as confidential, and whistleblowers can report anonymously. NOS guarantees protection against retaliation for anyone who reports in good faith.

Communications are received by Internal Audit and forwarded to either the Statutory Independent Audit Board (for corruption matters) or the Ethics Committee (for other ethics violations), depending on the nature of the issue. There is a record of all irregularities related to the Code of Ethics and/or Code of Conduct for the Prevention of Corruption and Related Offences.

The handling process includes: (i) receipt; (ii) confirmation of receipt; (iii) notification to responsible body; (iv) investigation; (v) reporting conclusions; and (vi) communication to the author. Reference deadlines are: 7 days for receipt notification, 3 months for follow-up measures, and 15 days for conclusion notification.

Policies and framework

NOS has implemented:

• Code of Conduct for the Prevention of Corruption and Related Offences (approved 2022)
• Prevention Plan for Risks of Corruption and Related Offenses (approved 2022)
• Mandatory e-learning training on ethics covering harassment, corruption, and fraud

As of 2024, 97% of employees (excluding cinema operations staff) had completed the mandatory ethics e-learning course. The Code applies to all governing body members, employees, partners, and service providers.

Payment practices

Policy and standard payment terms

NOS adopts a structured and responsible approach to managing supplier relationships, promoting good commercial practices, ethical alignment, and sustainability throughout its supply chain. This commitment is reflected both in its payment policy and in its broader approach to supplier relations, with a strong focus on risk mitigation and the promotion of positive sustainability impacts.

NOS's policy applies to all suppliers, including small and medium-sized enterprises (SMEs), ensuring fair and transparent payment terms. The standard payment term is 90 days. Any changes to these conditions require formalisation through a contract signed by a member of the Executive Committee or approval via email, ensuring alignment between the procurement and finance records.

Payment processes follow a weekly routine, with approved and unlocked documents included in proposals due within 13 days. For suppliers with outstanding debts to NOS as customers, payments may be suspended for review or reconciliation. Additionally, in the final month of each quarter, invoices overdue for the past eight days are not processed. These procedures ensure punctuality and fairness in payments, fostering equitable business relationships with all companies, including SMEs.

Standard payment terms by supplier category

NOS's standard payment terms are established to ensure consistency and alignment with applicable commercial and regulatory practices. In general, suppliers are set up with a 90-day payment term. However, there are exceptions to the general 90-day payment term, grouped into the following main categories:

• Regulatory and Institutional Suppliers: Entities such as regulators, banks, municipalities, associations, and institutions that require prompt payment due to their institutional and contractual nature

• Critical Operational Suppliers: Suppliers providing essential services such as energy, water, freight transport, telecommunications, and security are subject to shorter payment terms, generally between 0 and 30 days, due to the criticality of these services for NOS's operational continuity

• Partnership and Strategic Project Suppliers: This category includes suppliers involved in programming, advertising, and events, with payment terms varying between 30 and 60 days, adjusted to the nature of the projects and partnership commitments

• Business Support Service Suppliers: Suppliers offering consultancy, outsourcing, training, and customer support services have a 90-day payment term, aligned with market practices for these categories

Payment-related performance indicators

Average payment time

NOS's average payment time is 3 days before the due date. This figure represents the difference between the due date and the actual payment date, based on the weighted average of values across the NOS Group.

Percentage of payments in line with standard terms

In 2023, 61% of payments made by NOS were processed within the standard contractual payment term.

Number of legal proceedings for late payments

Currently, there are no ongoing legal proceedings related to late payments. NOS remains committed to the responsible and prompt resolution of any disputes, ensuring clear and cooperative communication with suppliers to prevent similar situations in the future.

Supplier financing agreements

NOS has agreed supplier financing agreements with four banks. In these agreements, NOS delivers to the banks the credits to be paid to its suppliers, instructing the banks to pay on the respective due date. Suppliers, on their own initiative, can bring forward the receipt of these credits. The participation of suppliers in these financing agreements has no impact on NOS's payment terms and conditions, nor are any guarantees provided by NOS.

Current payment terms with most suppliers vary between 30 and 90 days.

As at 31 December 2023 and 2024, the amount of outstanding obligations that the Company has delivered to the banks:

Note: Values in thousands of euros