The role of the administrative, management and supervisory bodies

Composition of the Board of Directors

As of December 31, 2024, the Board of Directors of OPmobility SE comprised:

• Total members: 14 directors
  • 12 directors elected by the General Shareholders' Meeting
  • 2 directors representing employees
• Gender composition: 7 women out of 14 directors (50%)
  • When excluding employee representatives (as per legal requirements): 6 women out of 12 directors (50%)
• Independent directors: 5 out of 12 directors (excluding employee representatives) = 42%
• Average age: 58 years
• Term of office: 3 years, renewable

Executive Leadership Structure:

• Chairman of the Board of Directors: Laurent Burelle (separate from CEO role since January 1, 2020)
• Chief Executive Officer: Laurent Favre
• Managing Director: Félicie Burelle

Independent Directors (as of December 31, 2024):

1. Gonzalve Bich
2. Virginie Fauvel
3. Lucie Maurel Aubert
4. Alexandre Mérieux
5. Élisabeth Ourliac

Panel of Censors:

• Jean Burelle (Honorary Chairman)
• Prof. Dr. Bernd Gottschalk

Board Committees with Sustainability Oversight

Three specialized committees support the Board:

1. Audit Committee

• Chairwoman: Élisabeth Ourliac (independent director, since December 2024)
• Members: Lucie Maurel Aubert (independent), Vincent Labruyère
• Meetings in 2024: 3 meetings with 100% attendance rate
• Responsibilities: CSR topics and monitoring of non-financial data; risk issues; carbon neutrality strategy

2. Appointments and CSR Committee

• Chairwoman: Lucie Maurel Aubert (independent director, since December 2024)
• Members: Anne-Marie Couderc, Virginie Fauvel (independent)
• Meetings in 2024: 3 meetings with 100% attendance rate
• Responsibilities: CSR issues; board diversity policy; skills matrix; independence assessment; director selection

3. Compensation Committee

• Chairman: Alexandre Mérieux (independent director)
• Members: Anne-Marie Couderc, Amandine Chaffois (employee representative), Gonzalve Bich (independent)
• Meetings in 2024: 3 meetings with 100% attendance rate
• Responsibilities: Alignment of compensation with strategic objectives including quantifiable criteria related to climate objectives and carbon neutrality strategy

Diversity Policy and Board Skills

Diversity Criteria and Implementation:

Skills Matrix (as of December 31, 2024):

Key skills represented across the Board:

• Senior Executives experience: 67%
• Digital/Innovation/New technologies: 33%
• Industry sector knowledge: 73%
• International profile: 60%
• CSR expertise: 40%
• Finance/Audit: 53%
• Automotive sector: 47%
• Human Resources: 40%
• Knowledge of the Group: 47%

Board Functioning and Meeting Frequency

2024 Board Activity:

• Board meetings: 4 meetings
• Overall attendance rate: 94%
• Committee meetings: 8 meetings total (3 Audit, 3 Appointments and CSR, 3 Compensation)
• Committee attendance rates: 100% for all committees

Meeting Organization:

• Minimum 4 meetings per year (per Internal Rules)
• Directors receive information via secure digital platform
• Videoconferencing/telecommunication allowed per Internal Rules
• Executive sessions held without executive officers (held October 25, 2024, chaired by Appointments and CSR Committee Chair)

Roles and Responsibilities

Chairman of the Board of Directors (Laurent Burelle)

Key responsibilities:

• Organizes and directs Board work
• Chairs Board meetings and General Shareholders' Meetings
• Ensures compliance with Internal Rules
• Develops relationship of trust between Board and Senior Executives
• Ensures directors receive clear and appropriate information
• Works in close collaboration with CEO

Specific approval authority:

• Annual budget and five-year strategic plan
• Disposals/acquisitions >€50 million or revenue >€100 million
• Executive Committee movements
• Raising/cancellation of loans and banking agreements
• Strategic CSR policy changes

Chief Executive Officer and Managing Director

• CEO (Laurent Favre) and Managing Director (Félicie Burelle) responsible for operational management
• Transparent communication with directors
• Regular reporting on Group events and performance
• Work in coordination with Chairman

Sustainability Expertise and Training

Director Training:

• Training offered to directors, particularly on CSR
• Personalized support available
• New directors receive comprehensive onboarding including bylaws, Internal Rules, Stock Market Ethics Charter
• ACT FOR ALL Climate School training: 900 employees completed in 2024

CSR Integration in Board Work:

• CSR topics widely addressed in Appointments and CSR Committee
• Climate strategy supported by experts in climate science
• Board assessment confirms CSR issues well addressed with good level of information on strategic CSR challenges
• Compensation Committee monitors alignment with climate objectives and carbon neutrality strategy

Internal Control and Risk Management

Internal Control and Compliance Committee:

• Chaired by Corporate Secretary
• Members include: People and Sustainability Director, Chief Operating Officer, CFO, Internal Control Director, Internal Audit and Risk Management Director, Corporate Compliance Director, CEOs and CFOs of business groups
• Reports to CEO
• Ensures quality and effectiveness of internal control system

Oversight Structure:

• Board of Directors reviews major strategies and internal control/risk management system outlines
• Audit Committee oversees internal control procedures
• Three levels of control: Operational Departments, Corporate Functions, Internal Audit
• Internal Audit conducted 37 assignments planned for 2025

Board Evaluation Process

2024 Formal Assessment:

• Conducted with external consultant assistance
• Led by Chairwoman of Appointments and CSR Committee
• All directors completed detailed questionnaire

Assessment areas:

• Board composition, organization and functioning
• Quality and relevance of information provided
• Board commitment to defining Group strategy
• Committee activity
• Main governance issues

Key findings:

• Composition satisfactory and balanced
• Diversity in profiles, age, gender, expertise enables active strategic discussion
• Number of independent directors appropriate
• CSR topics widely addressed
• Climate strategy well supported
• Compensation aligned with climate objectives and carbon neutrality strategy

Independence and Effectiveness Arrangements

Independence Criteria (AFEP-MEDEF Code): All directors assessed annually against 8 independence criteria:

1. Not employee/director in past 5 years
2. No cross-directorships
3. No significant business relations
4. No family ties with directors
5. Not Statutory Auditor in past 5 years
6. Term of office not over 12 years
7. Non-executive corporate officer status
8. Not major shareholder >10%

Conflict of Interest Management:

• Annual examination of potential conflicts
• Directors must inform Board of any conflict
• Must abstain from voting or withdraw from meetings when in conflict
• No business relationships identified that could lead to conflicts
• Stock Market Ethics Charter enforced

Director Obligations:

• Minimum shareholding: 900 shares (not applicable to employee representatives)
• Professional secrecy and loyalty obligations
• Compliance with insider trading rules
• Closed trading periods defined and communicated
• All transactions reported to French Financial Markets Authority (AMF)

Gender Balance on Committees

Committee Leadership:

• 2 out of 3 Committees chaired by women (Audit Committee and Appointments and CSR Committee)
• Gender balance respected across all committees

Integration of sustainability-related performance in incentive schemes

Roles covered

The integration of sustainability performance into incentive schemes applies to:

• Executive corporate officers of OPmobility SE
• Managing Director of the Company

Note: The Board of Directors decided to limit the beneficiaries of the performance share plan to executive corporate officers and the Managing Director of the Company with the aim of mobilizing the Group's key players around its successful development.

Sustainability KPIs tied to remuneration

Short-term incentive (STI) - Annual variable compensation

For 15% of the annual variable compensation, ESG criteria (social and environmental governance) are applied, two-thirds of which can be quantified.

Detailed ESG criteria:

Long-term incentive (LTI) - Performance shares

The allocation of performance shares is subject to quantifiable performance conditions. The vesting of shares is subject to performance conditions that are recognized at the end of a vesting period of 3 years from the grant date.

Weighting

• Annual variable compensation (STI): 15% tied to ESG criteria
• Performance shares (LTI): The value of these shares, estimated at the grant date in accordance with IFRS, represents between 35% and 40% of the executive corporate officer's overall compensation, and may not exceed 100% of the fixed compensation

Performance period and target structure

Free share award plan of February 19, 2025

Additional conditions

• The executive corporate officers formally undertake not to hedging the risk associated with performance shares until the end of the holding period set by the Board of Directors
• They retain at least 10% of the shares granted until the end of their corporate office
• In the event of the departure of an executive corporate officer during the first quarter, the Board of Directors may set the amount of the annual variable compensation for the current fiscal year pro rata temporis to the amount of the annual variable portion granted to the executive corporate officer concerned in respect of the previous fiscal year

Governance

The transition plan was presented in October 2024 by the ACT FOR ALL Committee, and the Executive Committee is informed monthly of its progress. These elements are also reported to the Appointments and CSR Committee and the Audit Committee.

Strategy, business model and value chain

Description of products/services and key markets

OPmobility is a world leader in sustainable mobility solutions. The Group operates through four Business Groups and a dedicated software activity:

1. Exterior solutions

• The Exterior business group is dedicated to lightweight and intelligent bodywork
• Complex body part assemblies made of injected polypropylene or composite materials: bumpers, energy absorption systems, tailgate modules, spoilers, fender supports and rocker panels
• These systems enhance passenger safety and help reduce greenhouse gas emissions through aerodynamics improvement and weight reduction

2. Lighting

• The Lighting business group specializes in interior and exterior lighting components, projection systems and complete headlights
• Present across the entire lighting value chain since the acquisitions of 2022
• Offers a differentiating range of connected solutions to meet growing demand from manufacturers for integrated exterior systems

3. Modules

• The Modules business group specializes in the development, assembly and logistics of front-end modules
• Extends product offering to other parts of the vehicle, such as the cockpit and the center console
• Part of the Group's strategy to increase the added value per vehicle by developing new modules and systems while taking advantage of growing demand for electric vehicles

4. Powertrain technology solutions (C-Power and H2-Power)

• C-Power business group: on-board energy storage and emissions reduction systems, contributing to the emergence of the clean car. Offers solutions adapted to all powertrains: internal combustion, hybrid or plug-in hybrid, and electric (with e-Power)
• H2-Power business group: pioneer in hydrogen technologies, innovates in the design of hydrogen solutions for zero-emission electric mobility. Develops cutting-edge technologies such as high-pressure storage in carbon fiber-reinforced vessels, fuel cell stacks and energy management and control solutions

Software activity

• OP'nSoft, software activity: 150 employees
• International technological partnerships: MIT, NICE (National Innovation Center for Excellence) in China

Significant groups of products/services and revenue share

In 2024, the Group generated €11.6 billion in revenue.

Breakdown by customer (2024):

• VW Group: 28%
• Stellantis: 13%
• Others: 12%
• BMW: 8%
• General Motors Group: 9%
• Mercedes-Benz: 7%
• Ford: 6%
• Renault Nissan Group: 6%
• JLR-Tata Group: 5%
• HMC: 4%
• Toyota: 2%

Opportunities pursued in 2024 generated €1,565 million in revenue.

Powertrain operational segment (mainly C-Power): €2,660 million in 2024 (down 1.6% compared to €2,703 million in 2023).

Significant markets / geographies

Global footprint:

• 150 plants and 40 R&D centers in 28 countries (all entities and joint ventures)
• Operations spread across Europe, North America, Asia, Africa, and South America

Revenue by geography:

• Nearly 50% of revenue generated in Europe
• Europe represents less than 20% of worldwide automotive production
• Accelerating development in North America and Asia

Market positioning:

• The Group is the leader in its three historical activities (Exterior, C-Power and Modules)
• Serves the majority of global carmakers
• Customer portfolio diversifying with new players in heavy and industrial (off-road) mobility
• Expanding into rail sector

Number of employees by geography

Total workforce: 38,900 employees (as of 2024)

Geographic distribution:

• Europe: 50%
• North America: 20%
• Asia: 24%
• Africa: 3%
• South America: 3%

Total revenue by significant ESRS sustainability matter

Not explicitly disclosed by sustainability matter.

Revenue from opportunities related to climate change mitigation (hydrogen, fuel cells, electrification systems, BEV/FCEV systems): €1,565 million in 2024.

Sustainability-related goals embedded in the business model

OPmobility's purpose: "Driving a New Generation of Mobility"

The Group has structured its commitments within the ACT FOR ALL™ program, based on three major areas:

1. Act for People

• Health and safety at work
• Skills and career management
• Diversity and inclusion
• Local sponsorship initiatives

2. Act Responsibly

• Business ethics
• Sustainable purchasing
• Cybersecurity

3. Act for Planet

• Waste management
• Eco-design and recyclability
• Value chain carbon footprint (Top Planet and renewable energies)
• Biodiversity

Climate commitments (SBTi certified in 2021):

• Carbon neutrality on scopes 1 and 2 by 2025 (80% reduction and offsetting of residual emissions)
• 30% reduction in scope 3 by 2030 compared to 2019 levels
• Net Zero 2050 commitment with SBTi
• In 2027 for Lighting (carbon neutrality scopes 1 & 2)

2025 Targets (from ACT FOR ALL™):

• Safety FR2 (accidents with/without lost time): < 0.5
• Ergonomics: 100 workstations ergonomically improved
• Health: 100% of sites supporting health initiatives
• Diversity - Women Managers & Engineers: 27%
• Diversity - Women Senior Executives: 28%
• Youth employment: 1,300 trainees, apprentices, Graduate Program and VIE
• Local sponsorship: 100% of sites engaged in actions to support local communities
• Business ethics: 100% of employees trained
• Responsible purchasing: < 60% of medium and high risk suppliers enrolled in self-assessment (based on 75% of purchasing base)
• Top Planet score: 65%
• Renewable energy: 7.7% share of renewable sources in total energy consumption (2024 result)
• Sustainable mobility initiatives: 100% of sites

Description of upstream and downstream value chain

Value chain overview:

Upstream:

1. Extraction and distribution of raw materials

   • Oil, minerals, natural materials

2. Production and distribution of materials

   • Electronics & Technologies
   • Equipment & Tools
   • Materials, Chemicals, Plastic
   • Other components

Own operations:

• Mobility solutions
• Fuel tank & emission reduction system
• Batteries
• Electronics & Software
• Lighting
• Bumpers, Tailgate, Spoiler, Body Panel
• Indoor module
• H2: high-pressure vessel and fuel cell stack

Downstream:

1. Customers

   • Car, truck, bus and train manufacturers

2. Users

   • Vehicle use

3. End of life

   • Dismantling
   • Recycling

Supplier categories:

• Raw material suppliers (oil, minerals, natural materials)
• Electronics and technology suppliers
• Equipment and tool suppliers
• Materials, chemicals, and plastic suppliers
• Component suppliers

The Group has a network of suppliers across 28 countries. Responsible purchasing policy includes EcoVadis assessments, supplier visits and audits, and integration of CSR clauses in contracts.

Customer types:

• Historical carmakers (VW Group, Stellantis, BMW, General Motors, Mercedes-Benz, Ford, Renault Nissan, Toyota, etc.)
• New players in electric mobility
• Heavy and collective mobility players (rail sector - CRRC, Stadler)

Key inputs and outputs

INPUTS:

Human Capital:

• 38,900 employees
• Network of HSE (Health, Safety, Environment) experts

Environmental Capital:

• 35 sites with solar panels or wind turbines
• Network of HSE experts

Industrial Capital:

• 150 plants and 40 R&D centers in 28 countries
• Almost 5% of revenue invested in R&D

Financial Capital:

• Equity capital: €2,058 million
• Leverage of 1.7x EBITDA

Intellectual Capital:

• OP'nSoft software activity: 150 employees
• International technological partnerships: MIT, NICE in China

Shareholder Capital:

• A family-run company for 4 generations
• 60.6% of capital held by Burelle SA

Materials:

• Plastics (polypropylene, composite materials)
• Metals and alloys
• Electronics components
• Carbon fiber (for hydrogen storage)
• Chemicals

Energy:

• 7.7% share of renewable sources in total energy consumption (2024)
• 22.8 GWh self-generated non-fuel renewable energy

OUTPUTS:

Products:

• Exterior systems (bumpers, tailgates, spoilers, body panels)
• Lighting systems (headlights, interior/exterior lighting)
• Modules (front-end modules, cockpits, center consoles)
• Fuel tanks and emission reduction systems
• Battery systems
• Hydrogen storage vessels (350 bar high-pressure systems)
• Fuel cell systems (150 kW systems, NM12 Twin fuel cell stacks)
• Electronics and software solutions

Environmental outputs:

• Scope 1 & 2 CO2 emissions: 1% of total (31.5 MtCO2eq)
• Scope 3 CO2 emissions: 99% of total
  • Processing and use of sold products: 85%
  • Purchase of goods and services: 10%
  • Other scope 3 emissions: 4%
• Waste generation (hazardous and non-hazardous)
• VOCs, SOx, NOx emissions (controlled and compliant)

Social outputs:

• Employment: 38,900 employees globally
• Training and development programs
• Health and safety programs (148 sites reported zero accidents in 2024)
• Local community support initiatives (97.5% of sites in 2024)

Innovation outputs:

• 159 new programs launched in 2024
• Development of hydrogen solutions for trains (15 hydrogen-powered trains for Stadler in Italy)
• 76 type 4 high-pressure storage systems for CRRC smart tramways in Malaysia

Interests and views of stakeholders

Overview

The main objective of dialogue with OPmobility's stakeholders is to ensure that its actions are aligned with their expectations and contribute positively to its ecosystem. This dialogue makes it possible to anticipate regulatory changes, meet customer needs, strengthen ESG practices within the supply chain and improve transparency towards investors.

OPmobility integrates stakeholder engagement at the heart of its sustainability and performance strategy, focusing on several key areas:

• Employees: OPmobility's employees are key players in its development. The Group invests in their training, well-being and safety while promoting a culture of inclusion and diversity. Employee engagement is strengthened through career development initiatives and opportunities.

• Carmakers: OPmobility works closely with its customers, mainly carmakers and mobility operators, to develop innovative and sustainable solutions adapted to the specific needs of each market. This proximity makes it possible to anticipate regulatory and technological changes while meeting the expectations of end users. These exchanges promote the construction of a relationship of trust and maintain a long-term strategic alignment.

• Competitors: OPmobility pays attention to strategic changes and the practices of its competitors on ESG challenges. This helps to better understand market trends and identify the implicit expectations of the various stakeholders, while helping to strengthen industry standards.

• Regulators and political decision-makers: They define the climate and tax policies that impact the Group's activities (such as emissions standards, carbon taxation, ban on internal combustion engines).

• Other stakeholders: OPmobility actively contributes to the energy transition by developing solutions that reduce emissions and promote the use of recycled materials. In addition, its global network supports local economic development and encourages collaboration and relationships with communities and industrial players.

• The environment: This is an essential stakeholder for OPmobility. The Group incorporates carbon neutrality, waste reduction and natural resource preservation objectives into all its activities and innovation processes. These stakeholders will be detailed in this chapter 4.

This global commitment is structured and monitored within the framework of rigorous governance, ensuring that all actions undertaken contribute to the Group's sustainability objectives.

Stakeholder engagement activities

The relationships and commitments with the various categories of stakeholders identified are detailed in the table below:

Integration of stakeholder views into strategy

For OPmobility's own workforce (S1), stakeholder interests and views are explicitly taken into account through:

• Internal surveys and discussions with employee representatives and employees to identify priority risks
• Consultation with managers, employees and trade unions to assess training needs
• Employee satisfaction and feedback surveys conducted at least once a year through the Pulse Survey
• Regular data collection and analysis of key performance indicators (KPIs)
• Consultations with trade unions, watch and benchmark on candidate expectations

For workers in the value chain (S2), the Group incorporates stakeholder views through:

• Surveys and discussions with employee representatives to identify priority risks
• Collaboration with the AFCDP (French Association of Correspondents for the Protection of Personal Data)
• Collaboration with cybersecurity experts, commercial partners and specialized associations: CLUSIF, CESIN
• Surveys of Managers, HRBPs and new employees

For consumers and end-users (S4), the Group considers stakeholder interests through:

• Carmakers: collaboration to ensure equipment compatibility and safety
• Consumers: safety and compliance testing to ensure risk-free use

All these processes are documented in the Group's policies and made available to potentially affected stakeholders through various channels including the website, intranet, training sessions, and direct communications.

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

List of Material IROs

OPmobility identified 17 material impacts, risks and opportunities (IROs) through its double materiality analysis in 2024:

Detailed Description of Material IROs

Climate change (scopes 1, 2 and 3): contribution to climate change via the emission of greenhouse gases by the direct and indirect activities of the Group.

• Reason: OPmobility is a leader in the production of automotive parts.
• Consequence: OPmobility's industrial activities result in CO2 emissions from the purchase, transportation, production and use of equipped vehicles that consume fossil fuels.
• IRO Management: Group Environmental Policy; "Carbon neutrality" targets and roadmap aligned with the Paris Agreement and approved by the SBTi in 2021; Sites' energy decarbonization policy (decarbonized energy, facilities to produce renewable energy, and PPA); ISO 50001 certification; Scope 3 reduction policy by working on the value chain
• Possibility: Real
• Criticality: +++
• Horizon: Short term

Development of clean mobility (growth of low‑carbon mobility (BEV, PHEV, hydrogen)):

• Reason: mobility market dynamics strongly oriented towards decarbonization, driven by three major factors: growing customer expectations, regulatory incentives and the fiscal pressure related to carbon taxes.
• Consequence: need to offer solutions that reduce CO2 emissions over the entire life cycle of the vehicle.
• IRO Management: Group Environmental Policy; R&D on materials, bio‑sourcing and research into replacing materials with low‑impact products; Life Cycle Assessments for OPmobility's projects and products and those of suppliers; Innovative partnerships; Development of hydrogen energy for clean mobility
• Possibility: Real
• Criticality: +++
• Horizon: Medium term

Growth of the historical business and capture of new businesses:

• Reason: 75% of OPmobility's business is not exposed to the change of powertrain technology (bumpers, for example), proven technological expertise and balanced geographical coverage. Market recognition.
• Consequence: OPmobility is developing new business lines and implementing a "Last Man Standing" strategy in this segment, taking market share from its competitors.
• IRO Management: Group Environmental Policy; R&D on materials, bio‑sourcing and research into replacing materials with low‑impact products; Life Cycle Assessments for OPmobility's projects and products and those of suppliers; Innovative partnerships; Development of hydrogen energy for clean mobility
• Possibility: Real
• Criticality: +++
• Horizon: Medium term

Innovation for the development of low‑carbon solutions (eco‑design, recycled materials, new alternative and bio‑sourced materials):

• Reason: OPmobility wants to improve its impact on the environment by offering alternative solutions.
• Consequence: Research and Development to use eco‑designed solutions and recycled and bio‑sourced materials.
• IRO Management: Group Environmental Policy; R&D on materials, bio‑sourcing and research into replacing materials with low‑impact products; Life Cycle Assessments for OPmobility's projects and products and those of suppliers; Innovative partnerships; Development of hydrogen energy for clean mobility
• Possibility: Real
• Criticality: +
• Horizon: Medium term

Non‑transition of the business model in a sluggish market:

• Consequence: loss of market share, leadership and customer confidence. The combustion engine business is exposed to various regulations in many regions.
• IRO Management: Group Environmental Policy; R&D on materials, bio‑sourcing and research into replacing materials with low‑impact products; Life Cycle Assessments for OPmobility's projects and products and those of suppliers; Innovative partnerships; Development of hydrogen energy for clean mobility
• Possibility: Potential
• Criticality: +++
• Horizon: Medium term

Material IROs by ESRS Topic

The complete list of material IROs identified covers:

ESRS E1 Climate change:

• Climate change - Mitigation
• Climate change - Adaptation

ESRS E2 Pollution:

• Pollution of air
• Hazardous and very hazardous substances
• Microplastics

ESRS E5 Circular economy:

• Use of raw materials
• Waste generation and management

ESRS S1 Own workforce:

• Talent attraction and skills development
• Working conditions
• Health and safety
• Diversity and inclusion
• Other human rights

ESRS S2 Workers in the value chain:

• Respect for working conditions in the value chain

ESRS S4 Consumers and end‑users:

• Product quality and safety

ESRS G1 Business conduct:

• Supplier relations
• Relationship with stakeholders
• Business ethics

Interaction with Strategy and Business Model

Transition Plan: As part of its transition plan, the Group is taking advantage of development opportunities in the areas of:

• Hydrogen and fuel cell storage, through its H2-Power business group (BG)
• Electrification systems, with the e‑Power activity
• Energy management solutions, combining new technologies (batteries, fuel cells) with the thermal engine segment, in a virtuous approach to reducing emissions

The Group is implementing a differentiated regional commercial strategy and seeking growth vectors in each of the regions in which the Group operates, in order to strengthen its market share. The Group does not anticipate any significant adjustment to its assets and liabilities in 2025, given the provisions for restructuring and/or asset impairment recorded in the financial statements as of December 31, 2024.

Business Model Resilience: The resilience of OPmobility's business model is based on its proven ability to adapt to market transformations. The double materiality analysis, carried out in accordance with the requirements of the CSRD, confirmed the relevance of OPmobility's business model. No major adjustments were necessary, but the Group strengthened certain targeted actions to better respond to the challenges identified. It is thus continuing its commitment to sustainable innovation while adapting its initiatives to the transformations in the sector.

Strategic Integration: OPmobility's business model incorporates significant impacts, risks and opportunities (IROs) by aligning them closely with its strategy and operations. While relying on a solid model focused on innovation in sustainable mobility, the Group continuously monitors changes in the market, regulations and societal expectations. These elements are integrated into an ongoing strategic reflection, thus guaranteeing the resilience and sustainability of its activities.

Time Horizons

The time horizons used by OPmobility are aligned with those of the ESRS 1 standard:

• Short‑term horizon: corresponds to the current year
• Medium‑term horizon: extends up to five years
• Long‑term horizon: beyond five years

Climate Commitments

Regarding OPmobility's climate commitments, the Group's trajectory was SBTi certified in 2021 on the historical scope, excluding the Lighting acquisition, in line with the Paris Agreement:

• Carbon neutrality on scopes 1 and 2 in 2025 (80% reduction and offsetting of residual emissions)
• 30% reduction in scope 3 by 2030 compared to 2019 levels
• Net Zero 2050 with SBTI

Non-Material Topics

The following sustainability matters were not considered material:

ESRS E3 - Water and Marine Resources: OPmobility has undertaken an assessment to identify actual and potential material impacts related to water and marine resources in its direct activities, and its upstream and downstream value chain. The impact of freshwater abstraction and consumption by industrial sites is limited, as a large part of the plants operate in a water use closed circuit. There is no impact related to water discharges into the ocean at the level of the Group's industrial sites. OPmobility's direct and indirect activities are not associated with the exploitation of marine resources.

ESRS E4 - Biodiversity: In 2022, the Group carried out an analysis of its biodiversity footprint covering scopes 1, 2 and 3, using the Corporate Biodiversity Footprint (CBF) method. The mapping of priority sites showed that only three OPmobility sites are located in key biodiversity areas (KBA), in South Africa, Mexico and the Czech Republic. OPmobility has not identified and assessed actual and potential material impacts on biodiversity and ecosystems, as the identified direct impacts of climate change and air pollution are already covered by the ESRS E1 and ESRS E2 standards.

ESRS S3 - Local Communities: OPmobility has not identified and assessed actual and potential material impacts, risks or opportunities related to local communities.

Transition plan for climate change mitigation

Overview and objectives

OPmobility has set itself ambitious targets to help limit global warming. The decarbonization roadmap, established in 2021, consists of three stages:

• 2025: carbon neutrality for scopes 1 and 2 for the scope excluding Lighting (80% reduction and offsetting of residual emissions, in line with a 1.5° trajectory for the sector)
• 2030: 30% reduction in scope 3 emissions compared with 2019
• 2050: carbon neutrality commitment for all sites

The reference value chosen is the year 2019. This year was selected because it represents a period without significant exogenous influences such as the Covid-19 pandemic or the war in Ukraine, thus ensuring a representative base of the activities covered. The emissions for the 2019 reference year were reassessed by 10.3% to take into account the emissions of companies acquired by the Group in 2022.

Carbon neutrality, on a global scale, aims to offset any greenhouse gas (GHG) emissions from human activity by sequestering equivalent quantities of CO2, i.e. their long‑term maintenance outside the atmosphere. At the Group level, OPmobility considers that it is first and foremost a question of reducing the CO2 emissions emitted by its activities as much as possible through a strategy of reducing carbon emissions, replacing fossil fuels and then offsetting residual emissions through certified external CO2 avoidance and sequestration projects.

Scope of the plan

The transition plan was presented in October 2024 by the ACT FOR ALL Committee, and the Executive Committee is informed monthly of its progress. These elements are also reported to the Appointments and CSR Committee and the Audit Committee.

The plan covers the entire Group, its subsidiaries and its activities, including direct and indirect impacts, as well as those generated by its business relationships. It was conducted at the global value chain scale, from raw material suppliers to end‑users, integrating the specific characteristics of the regions and markets where OPmobility operates.

Alignment with Paris Agreement and SBTi validation:

The Group's trajectory was SBTi‑certified in 2021 on the historical scope excluding the Lighting acquisition, in line with the Paris Agreement:

• Carbon neutrality on scopes 1 and 2 in 2025 (with an 80% reduction and offsetting of residual emissions, in line with a 1.5°C trajectory for the sector)
• 30% reduction in scope 3 in 2030 compared to 2019 levels

The SBTi also recognizes that the Group is committed to Net Zero 2050, which certifies it as a member of the "Business Ambition for 1.5°C.". As this certification predates the acquisition of AMLS, Varroc Lighting Systems and Actia Power in 2022, a new submission is underway for the entire Group.

GHG emission reduction targets and milestones

Objectives approved by SBTi and in line with Paris Agreement:

*for 2022 acquisitions, neutral in 2027

Detailed targets table:

Sub-objective:

Decarbonization levers and key actions

OPmobility's decarbonization roadmap is based on 8 levers: Raise awareness, Measure, Reduce, Replace, Offset, Collaborate, Eco‑design and Innovate.

1) Raising awareness of climate challenges

Raising awareness of climate challenges is an essential lever for decarbonization, accelerating the transition to a low‑carbon economy by influencing individual and collective behavior.

2) Measure

The measurement of greenhouse gas (GHG) emissions is a fundamental lever for initiating an effective and structured decarbonization approach. Without an accurate assessment of emissions, it is impossible to identify the main emission items, set relevant targets and monitor progress.

3) Reduce: reduce the carbon footprint of operations

OPmobility is committed to reducing the carbon footprint of its activities by optimizing the energy consumption of its industrial sites. To achieve this, the Group is:

• Digitizing its measurement tools for responsive monitoring of consumption in real time
• Modernizing its infrastructure and gradually replacing its equipment with more efficient and less energy‑consuming solutions
• Conducting regular energy audits on its sites
• Setting up a library of best practices
• Raising employee awareness and implementing intelligent energy monitoring and management systems

4) Replace: promote the supply of renewable energy

In order to limit its use of fossil fuels, OPmobility is accelerating the deployment of alternative solutions by integrating more renewable energy into its operations. This transition involves:

• Installation of photovoltaic panels and wind turbines on the Group's sites
• Mechanisms such as PPAs (Power Purchase Agreements), VPPAs (Virtual Power Purchase Agreements) and renewable energy certificates

5) Offset: neutralizing residual emissions

As some CO2 emissions are difficult to eliminate completely, OPmobility sets up offsetting mechanisms by financing carefully selected and certified CO2 emission avoidance and sequestration projects. These initiatives are chosen in line with the Group's activities, guaranteeing a tangible environmental impact and aligned with its sustainability commitments. These projects include:

• Support for reforestation and ecosystem conservation initiatives
• Financing of energy efficiency and renewable energy projects

6) Collaborate: a collective approach for greater impact

OPmobility adopts a collaborative approach with all its stakeholders to accelerate the ecological transition across its entire value chain:

• With suppliers: The Group supports its partners in their sustainable transformation by favoring those who commit to managing their own carbon footprint
• With customers: OPmobility works in close collaboration from the design phase of the products, integrating sustainability criteria upstream of the projects. Eco‑design is thus an essential lever for reducing the environmental impact of the solutions developed, in particular by making vehicles lighter and improving their aerodynamics

7) Eco‑design: developing low‑carbon solutions from the circular economy

In order to reduce the environmental impact of its products, OPmobility incorporates new low‑carbon materials and materials from the circular economy into its production processes. This approach is based on several areas:

• Research and development of recycled and biosourced materials
• Development of new lightweight composites to reduce vehicle energy consumption
• Optimization of supply chains to limit the carbon footprint related to transportation

8) Innovate: accelerate the transformation towards sustainable mobility

Innovation is at the heart of OPmobility's strategy. The Group invests in research and development to design technologies and offer solutions to reduce the environmental impact of its products and services. As a specialist in exterior systems and energy storage, OPmobility offers its portfolio of technologies to all mobility players, from carmakers to new transportation operators.

CapEx and investment commitments

Under the transition plan, the Group allocated in 2024:

• Approximately €232 million in financial resources for its H2-Power activity
• Approximately €52 million in financial resources for its e‑Power activity
• €10 million for improving the efficiency of industrial equipment and renewable energy production
• €3 million in CapEx for circular economy projects

Summary of resource allocation for 2022-2025:

In addition, in 2024, the Group allocated €70 million in CapEx for exterior systems and modules for 100% electric vehicles and included in activities 3.18 and 8.2 of the capital expenditure reported under the European Taxonomy.

CapEx invested in coal, oil and gas: The Group did not make any significant CapEx in fossil fuels during the reporting period.

Locked-in emissions and stranded assets

"Stranded assets" refer to OPmobility's key assets already in use or firmly planned (i.e. those that the Group intends to deploy most likely over the next five years) that generate significant GHG emissions throughout their operational lifetime.

At OPmobility, the C‑Power business group designs, manufactures and sells fuel tanks initially intended for internal combustion vehicles. As the C‑Power business group's contribution to scope 3 "Use of the group's products sold" is less than 10% of that of the Group overall, maintaining this activity and its plants would not risk compromising the Group's achievement of its objectives.

In addition, as the mobility market is moving towards low‑carbon solutions, the business group may have to equip hybrid vehicles or vehicles powered by e‑fuels and thus reduce its scope 3 emissions.

The "Powertrain" operational segment of which the C‑Power business group is now the main component, recorded a slight drop in revenue, down 1.6% compared to 2023 (€2,660 million compared to €2,703 million in 2023), and down 0.6% at constant exchange rates. The C‑Power business group also incurred approximately €9 million in restructuring expenses in Europe, the Americas and Asia.

For the year 2025, the Group plans to continue developing its new energy activities (electricity and hydrogen), and, as part of the "Last Man Standing" strategy of its tank production activity, will continue to manage its investments in line with market changes in each of the regions in which the Group operates, in order to strengthen its market share. The Group does not anticipate any significant adjustment to its assets and liabilities in 2025, given the provisions for restructuring and/or asset impairment recorded in the financial statements as of December 31, 2024.

Use of carbon credits and removals

OPmobility considers that it is first and foremost a question of reducing the CO2 emissions emitted by its activities as much as possible through a strategy of reducing carbon emissions, replacing fossil fuels and then offsetting residual emissions through certified external CO2 avoidance and sequestration projects.

Progress in 2024:

• Signature of the contract with the partner and selection of CO2 avoidance and sequestration projects. This commitment will enable the Group to offset its residual emissions in 2025
• OPmobility reduced its scopes 1 and 2 CO2 emissions by 83kt between 2019 and 2024 (including acquisitions), thus continuing its transition to more sustainable mobility

Progress in implementation of the plan (2024)

GHG EMISSIONS REPORTING: 2024 CARBON ASSESSMENT

In metric tons of CO2eq (including Lighting):

PROGRESS IN 2024:

1. Raising awareness of climate issues:

   • Campaign of the 6 Environmental Basics deployed
   • AFA (Act For All) Climate School: 900 employees completed awareness‑raising modules
   • Levers and achievements to reduce the carbon footprint of scope 3

2. Measure:

   • Digitalization of measurement systems: 36 sites equipped with the new system

3. Reduce: reduce the carbon footprint of operations:

   • ISO 50001 certification
   • Energy efficiency was improved by 22% (vs. 2019)
   • Energy efficiency actions have made it possible to reduce CO2 emissions on scopes 1 and 2 by 15.6% compared to 2019 (including acquisitions) and by 6.2% compared to 2023

4. Replace: promote the supply of renewable energy:

   • On‑site production: 35 sites equipped
   • Start of the production of a VPPA located in Spain
   • Signing of EDF and India supply contracts
   • The Group produced 2.4% of its electricity directly on its sites in 2024. Starting from non‑existent energy production on‑site in 2019. At least 6 more sites will be equipped by the end of 2025
   • New means of renewable energy production have been installed at the Banbury sites in England, Ramos and Leon in Spain, and Pitesti in Romania
   • Implementation of PPA and virtual PPA contracts: Two major contracts signed - The first contract signed with EDF Renouvelables for 45 GWh/year of solar energy will be able to cover nearly half of the Group's French electricity needs by 2026. The second of 63 GWh/year was signed at the end of 2024 with a Spanish developer

5. Offset: neutralizing residual emissions:

   • Signature of the contract with the partner and selection of CO2 avoidance and sequestration projects. This commitment will enable the Group to offset its residual emissions in 2025
   • OPmobility reduced its scopes 1 and 2 CO2 emissions by 83kt between 2019 and 2024 (including acquisitions)

6. Collaborate: a collective approach for greater impact:

   • Maintaining an engine technology‑agnostic strategy and the strategic move towards low‑carbon mobility enable the Group to satisfy its historical customers and collaborate with new players, thus increasing its rate of equipping vehicles with electric propulsion. As a result, the use of marketed products now generates fewer carbon emissions
   • The Group is strengthening its commitment to a more responsible supply chain by prioritizing the purchase of sustainable raw materials and developing eco‑designs to optimize its scope 3
   • 270 initiatives in the area of purchasing
   • Improvement of the EcoVadis score of the supplier panel

Integration into overall strategy and governance

The transition plan, the main principles of which were established in 2021, is fully in line with OPmobility's overall strategy, aimed at making the Group a leader in sustainable mobility. This plan was presented and approved by the Board of Directors, which provides strategic oversight.

Strong integration into the Group's strategy and communication:

This plan is fully integrated into OPmobility's strategy and is a central focus of its integrated report, thus reinforcing its transparency and commitment to a successful transition to low‑carbon mobility. It is also highlighted during public speeches by executive corporate officers, reaffirming the Group's desire to actively steer its transformation and mobilize all stakeholders around its commitments.

Rigorous monitoring and enhanced transparency:

OPmobility's commitment is based on rigorous monitoring and solid transparency mechanisms. Each year, at the General Meeting of Shareholders, the progress made and the resources allocated to the deployment of the transition plan are presented to shareholders and stakeholders. This process guarantees:

• Continuous assessment of the actions implemented
• Efficient allocation of resources
• Adaptability to regulatory and technological developments
• Accountability of executive corporate officers and operational teams in the execution of commitments

The Group diligently monitors the evolution of its non‑financial performance, paying particular attention to its carbon neutrality roadmap and the key factors that guarantee its success. This proactive approach makes it possible to ensure precise management, anticipate challenges and adjust actions according to regulatory, technological and environmental changes and market trends.

Opportunities pursued

As part of its transition plan, the Group is taking advantage of development opportunities in the areas of:

• Hydrogen and fuel cell storage, through its H2-Power business group (BG)
• Electrification systems, with the e‑Power activity
• Exterior systems and modules for electric vehicles (BEV) and hydrogen (FCEV)

In 2024, the opportunities pursued by the Group generated €1,565 million in revenue, contributing to the Group's growth in an automotive market that was down -1.2%.

Policies related to climate change mitigation and adaptation

Op Mobility has not disclosed specific named policies dedicated to climate change mitigation and adaptation in the excerpts provided.

However, the company has established a decarbonization roadmap announced on December 9, 2021, by Mr. Laurent Favre (Group CEO) and Mr. David Meneses (EVP People and Sustainability). This roadmap integrates climate challenges into the Group's strategy and sets out the following commitments:

• 2025: Carbon neutrality for scopes 1 and 2 (80% reduction and offsetting of residual emissions, in line with a 1.5°C trajectory for the sector)
• 2030: 30% reduction in scope 3 emissions compared to 2019 levels
• 2050: Carbon neutrality commitment for all sites

Integration and Oversight

• The transition plan was presented in October 2024 by the ACT FOR ALL Committee
• The Executive Committee is informed monthly of progress
• Elements are reported to the Appointments and CSR Committee and the Audit Committee
• The transition plan was presented and approved by the Board of Directors, which provides strategic oversight
• Progress and resources are presented annually at the General Meeting of Shareholders

Alignment with Standards

• The Group's trajectory was SBTi-certified in 2021 on the historical scope (excluding the Lighting acquisition), in line with the Paris Agreement
• The SBTi recognizes the Group's commitment to Net Zero 2050, certifying it as a member of the "Business Ambition for 1.5°C"
• A new SBTi submission is underway for the entire Group following acquisitions
• The transition plan aligns with European Taxonomy requirements as defined in Delegated Regulation 2021/2139

Implementation Mechanisms

While not presented as a standalone policy document, the company's approach includes:

• Raising awareness of climate issues (6 Environmental Basics campaign, AFA Climate School)
• Measurement through digitalization of measurement systems
• Reduction of carbon footprint through ISO 50001 certification and energy efficiency improvements
• Implementation of PPA and virtual PPA contracts for renewable energy
• Offsetting of residual emissions through certified CO2 avoidance and sequestration projects

The company has not disclosed a specific public URL or document for a climate policy, nor has it described detailed monitoring mechanisms beyond the governance reporting structure mentioned above.

Actions and resources in relation to climate change policies

Decarbonization roadmap based on 8 levers

OPmobility's decarbonization roadmap is structured around 8 strategic levers: Raise awareness, Measure, Reduce, Replace, Offset, Collaborate, Eco-design and Innovate.

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1) Raising awareness of climate challenges

Description: Strategic and methodological areas aimed at informing, mobilizing and encouraging action on climate challenges to accelerate the transition to a low-carbon economy by influencing individual and collective behavior.

Scope: Own operations

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2) Measure

Description: Measurement of greenhouse gas (GHG) emissions through a methodical approach combining data collection, analysis and management of reduction actions. Enables identification of main emission items, setting relevant targets and monitoring progress.

Scope: Own operations and value chain

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3) Reduce: reduce the carbon footprint of operations

Description: Committed to reducing the carbon footprint of activities by optimizing energy consumption of industrial sites through:

• Digitizing measurement tools for real-time consumption monitoring
• Modernizing infrastructure
• Replacing equipment with more efficient, less energy-consuming solutions
• Conducting regular energy audits
• Setting up a library of best practices
• Raising employee awareness
• Implementing intelligent energy monitoring and management systems

Scope: Own operations

Time horizon: Since 2015

Resources allocated: All business groups committed to this reduction program

Expected outcomes / KPIs:

• ISO 50001 certification
• Energy efficiency improved by 22% (vs. 2019)
• Energy efficiency actions reduced CO2 emissions on scopes 1 and 2 by 15.6% compared to 2019 (including acquisitions) and by 6.2% compared to 2023
• Reduced scopes 1 and 2 CO2 emissions by 83kt between 2019 and 2024 (including acquisitions)

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4) Replace: promote the supply of renewable energy

Description: Accelerating deployment of alternative solutions by integrating more renewable energy into operations through:

• Installation of photovoltaic panels and wind turbines on Group sites
• PPAs (Power Purchase Agreements)
• VPPAs (Virtual Power Purchase Agreements)
• Renewable energy certificates

Scope: Own operations

Time horizon: Ongoing; at least 6 more sites to be equipped by end of 2025

Expected outcomes / KPIs:

• On-site production: 35 sites equipped (as of 2024)
• Group produced 2.4% of its electricity directly on sites in 2024 (vs. non-existent in 2019)
• Start of production of a VPPA located in Spain
• Signing of EDF and India supply contracts
• New renewable energy production installed at Banbury (England), Ramos and Leon (Spain), and Pitesti (Romania)

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5) Offset

Description: CO2 avoidance and sequestration projects chosen in line with the Group's activities, guaranteeing tangible environmental impact. Includes:

• Support for reforestation and ecosystem conservation initiatives
• Financing of energy efficiency and renewable energy projects

Scope: External projects

Expected outcomes / KPIs:

• Commitment will enable the Group to offset its residual emissions in 2025

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6) Collaborate: a collective approach for greater impact

Description: Collaborative approach with all stakeholders to accelerate ecological transition across entire value chain:

• With suppliers: Supporting partners in their sustainable transformation by favoring those who commit to managing their own carbon footprint
• With customers: Working in close collaboration from the design phase of products, integrating sustainability criteria upstream of projects

Scope: Upstream and downstream value chain

Timeline:

• 2022: Supplier assessment; Webcast with CEO and Purchasing Department
• 2023: Supplier awareness; Training sessions for employees and suppliers
• 2024: Supplier roadmap and initiatives

Expected outcomes / KPIs:

• 270 initiatives in the area of purchasing
• Improvement of the EcoVadis score of the supplier panel
• Maintaining engine technology-agnostic strategy enables collaboration with new players, increasing rate of equipping vehicles with electric propulsion
• Use of marketed products now generates fewer carbon emissions

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7) Eco-design: developing low-carbon solutions from the circular economy

Description: Incorporating new low-carbon materials and materials from circular economy into production processes through:

• Research and development of recycled and biosourced materials
• Development of new lightweight composites to reduce vehicle energy consumption
• Optimization of supply chains to limit carbon footprint related to transportation

Scope: Own operations and downstream value chain

Projects by Business Group:

Exterior:

• Demonstrator containing 50% recycled plastics in body panels (including visible parts)
• Development of a bumper with 30% recycled plastics
• Study on the reuse of end-of-life bumpers: work on separation and recycling of components
• Integration of carbon footprint in assessment and analysis of life cycle of projects and products

C-Power:

• HDPE purchasing policy favoring suppliers reducing carbon content of their material (reduction target of more than 40% compared to European average by 2027)
• Research on chemical recycling of fuel tanks to produce HDPE with same characteristics as virgin HDPE from fossil sources
• Study on mechanical recycling of HDPE, including solvent-based desorption solutions and drying processes

Expected outcomes: Reduction of CO2 emissions over entire life cycle of products, while improving performance and sustainability

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8) Innovate: accelerate the transformation towards sustainable mobility

Description: Investments in research and development to design technologies and offer solutions to reduce environmental impact of products and services. As specialist in exterior systems and energy storage, offers portfolio of technologies to all mobility players, from carmakers to new transportation operators.

Scope: Downstream value chain

Time horizon: Since 2015

Focus areas: e-Power, H2-Power activities

Resources allocated: Budget of €500 million

Links to targets: Supports 30% reduction in GHG emissions in scope 3 by 2030 compared to 2019

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Overall resources for climate action plan

Funding sources:

• Positive operating cash flow
• Financial liabilities
• Subsidies acquired for development of activities related to hydrogen and electrification

Strategic investments allocated to:

• Achieving carbon neutrality in operational activities by 2025 through:

  • Strategic investments to improve energy performance
  • Signing of Power Purchase Agreements (PPA)
  • Acquisition of renewable energy certificates
  • Use of carbon offsetting mechanisms

• 30% reduction in GHG emissions in scope 3 by 2030 (vs. 2019) by:

  • Accelerating development and financing of low-carbon solutions
  • Investments in hydrogen and electric batteries
  • Budget of €500 million for emissions reduction from Group's purchases and products sold

Budget process:

• Begins annually in September with initial preparation by each subsidiary
• Consolidated at Group level
• Presented to Senior Executives for approval in November
• Submitted to Board of Directors for approval
• Budget includes CapEx and OpEx, income statement, cash flow statement, capital employed flows, analyzed by subsidiary and by activity for year N+1

Note: All quantified resources associated with environmental topics are described in ESRS 2, section 4.1.4 and in ESRS E1, section 4.2.1.2.2.

Targets related to climate change mitigation and adaptation

Overview

OPmobility has set carbon neutrality targets aligned with the Paris Agreement and approved by the Science Based Targets initiative (SBTi) in 2021. The Group is committed to Net Zero 2050 with SBTi.

GHG Emission Reduction Targets

Supporting Sub-Targets

Scope and Geography

• Scopes 1 & 2: Own operations (all OPmobility business groups: Exterior, Lighting, Modules, C-Power, H2-Power)
• Scope 3: Entire value chain, including upstream and downstream emissions
• Geography: Worldwide operations

Decarbonization Strategy

The Group's roadmap is based on 8 levers:

1. Raise awareness: Climate School training (19 modules), 6 Environmental Basics
2. Measure: Digitization of measurement with sensors and software
3. Reduce: Energy efficiency improvements, Top Planet program
4. Replace: Renewable energy (PPA, on-site generation, green certificates)
5. Offset: Carbon credits for residual emissions
6. Collaborate: Engagement with suppliers (270 actions in 2024)
7. Eco-design: Life Cycle Assessments, recycled materials
8. Innovate: Hydrogen mobility (H2-Power), battery technology (e-Power)

Financial Resources

Notes

• The 2019 reference year has been recalculated to enable relevant comparisons
• Lighting acquisition (2022) targets differ: carbon neutrality by 2027 instead of 2025
• SBTi certification predates the acquisition of AMLS, Varroc Lighting Systems and Actia Power; new submission underway for entire Group
• Total emissions in 2024: 31.5 MtCO2eq (down 5.5% vs 2023), with scope 3 representing 86.7% of total
• No CapEx in fossil fuels during reporting period

Energy consumption and mix

Scope and methodology: Energy consumption data covers all OPmobility sites (including the Lighting acquisition). Data collected over 11 months via energy bills and extrapolated over 12 months. Location‑based and market‑based emission factors from IEA. Conversion to emissions uses ADEME emission factors.

Energy production (MWh):

• Non‑renewable energy production (internalized co‑generation): 20,027 MWh
• Renewable energy production (on‑site PPA): 22,853 MWh

Contractual agreements: Network electricity consumption: 906,884 MWh; Electricity consumption covered by green certificates: 78,717 MWh (8.7% of scope 2 GHG emissions). No contractual agreements used for the sale and purchase of non‑bundled energy certificates in 2024; all certificates come from electricity suppliers.

Energy intensity: OPmobility is classified under high climate impact sectors (Annex I, Regulation EC No. 1893/2006). All turnover is covered.

• Total energy consumption of high climate impact sector activities: 1,312,082 MWh
• Net revenue from high climate impact sector activities: €10,484 million
• Energy intensity: 125 MWh/€ million

Multi-year comparison (energy efficiency vs. 2019): In 2024, energy efficiency improved by 22% vs. 2019 (excluding Lighting). Energy consumption of historical sites (electricity and gas) was 1,339,261 MWh in 2019, with a -12% target by 2025; in 2024, -13.1% vs. 2019 was achieved (excluding Lighting).

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 and 2 GHG emissions

OPmobility reports consolidated Scope 1 and Scope 2 emissions for the reporting year 2024 and comparatives. The Group committed to carbon neutrality for scopes 1 & 2 by 2025 (excluding the Lighting acquisition), with a 2027 target for Lighting.

Scopes 1 & 2 emissions roadmap 2019–2025 (ktCO2e):

2024 results:

• Scopes 1 & 2 emissions: –15.6% vs 2019 (including Lighting)
• The Group applies linear extrapolation for the final month (December 2024) based on the first 11 months of data, consistent with prior-year methodology.

Baseline: The 2019 baseline for Lighting is estimated by applying a revenue-based ratio (10.3% of Group revenue in 2019) to calculate Lighting's notional 2019 emissions. This is used to ensure comparability.

Methodology notes:

• Scope 1: direct emissions from combustion (stationary and mobile), process emissions, and fugitive emissions.
• Scope 2: indirect emissions from purchased energy. The Group reports market-based figures and applies green energy certificates and PPAs/VPPAs to reduce market-based emissions.
• Residual emissions (after reduction and renewable energy procurement) are offset via certified carbon credits to achieve carbon neutrality.
• The calculation uses the GHG Protocol methodology.

Scope 3 GHG emissions

OPmobility reports Scope 3 emissions covering upstream and downstream categories. The Group committed to a –30% reduction in Scope 3 by 2030 vs 2019 and Net Zero across all scopes by 2050.

Scope 3 emissions roadmap 2019–2030 (MtCO2e):

2024 results:

• Scope 3 emissions: –33.4% vs 2019 (including Lighting)

Scope 3 breakdown by activity segment (indicative):

• Upstream activities (suppliers, logistics, fuel and energy-related activities): ~12% of total CO2 emissions
• Downstream activities (product use, end-of-life): ~87% of total CO2 emissions

The report notes partial data availability and estimation for value chain categories. Specific GHG Protocol categories are referenced:

• Category 1 (Purchased goods and services): Material, involving assumptions and supplier data extrapolation.
• Category 11 (Use of sold products): The largest contributor (~87% of total). Assumptions: 10 years vehicle use, 15,000 km/year travel distance. This assumption has been maintained since 2019 for comparability.
• Category 12 (End-of-life treatment of sold products): Included.
• Other categories (2 Capital goods, 3 Fuel- and energy-related, 4 Upstream transport, 5 Waste, 6 Business travel, 7 Employee commuting, 9 Downstream transport) are referenced in the Group's carbon accounting but not individually quantified in the excerpts.

Methodology notes:

• The Group follows the GHG Protocol for Scope 3 calculation.
• Data quality: Partial availability of value chain data, reliance on industry databases, supplier reports, and third-party tools (e.g. environmental databases, benchmarking). Estimates are used where primary data is unavailable.
• The report acknowledges measurement uncertainty in Scopes 3.1 and 3.11 due to assumptions.
• Carbon footprint calculations incorporate the most recent industry emission factors and are updated annually.

Total GHG emissions and intensity

Total GHG emissions (Scope 1 + 2 + 3) are not explicitly summed in the excerpts, but can be inferred:

• 2024: Approximately 31.1 MtCO2e (Scope 3) + 0.447 MtCO2e (Scopes 1 & 2) ≈ 31.5 MtCO2e total
• 2019 baseline: Approximately 46.7 MtCO2e (Scope 3) + 0.531 MtCO2e (Scopes 1 & 2) ≈ 47.2 MtCO2e total

GHG intensity:

• Not disclosed in the excerpts.

Regulated emissions and biogenic CO2

• EU ETS or other regulated emissions: Not disclosed separately in the excerpts.
• Biogenic CO2: Not disclosed separately in the excerpts.

Scope notes

• The Group consolidates all entities and joint ventures in its reporting scope.
• The Lighting acquisition (2022) is integrated into 2024 figures. For historical comparability, the 2019 baseline includes a revenue-based estimate for Lighting emissions.
• The Group's carbon neutrality roadmap excludes Lighting until 2027, when Lighting is expected to achieve carbon neutrality for scopes 1 & 2.
• Scope 1 & 2 calculation: linear extrapolation for December 2024 based on 11-month data (consistent with prior years).
• Scope 3: estimates used for upstream suppliers and downstream use phase due to partial data availability. Assumptions disclosed for vehicle use (category 11).

Policies related to pollution

Op Mobility addresses pollution through its environmental policy framework, specifically through the pollution component of its Group Environmental Policy.

Group Environmental Policy - Pollution Component

Policy name: Group environmental policy - Pollution component

Scope:

• Involves all OPmobility business groups (Exterior, Lighting, Modules, C-Power, H2-Power)
• Extends to subcontractors working for OPmobility

Key content and principles: The policy encompasses major challenges and commitments:

• Comply with and anticipate legal requirements and other legislation
• Adopt eco-responsible practices during product design phases
• Ensure compliance with environmental regulations
• Manage traceability of product composition
• Implement rigorous prevention, monitoring and control measures to prevent incidents
• Reduce noise emissions and implement necessary measures to achieve this
• Gradual reduction and substitution of substances of very high concern (SVHC) in accordance with European REACH regulation
• Prohibit CMR substances (categories 1A and 1B) and SVHCs, subject to exceptions under specific exemptions
• Only authorized products with updated safety data sheets may be used
• Safe storage and handling of substances of concern
• Systematic preference for less hazardous alternative substances

Priority areas:

• Mitigate global warming
• Prevent the risk of pollution
• Reduce impact on water
• Protect and preserve biodiversity
• Promote the circular economy

Governance and oversight:

• Established at the level of the Executive Committee (CODIR)
• Promoted by all business groups
• Supported by action plans and investment projects
• Managed by dedicated Committees in the presence of the Executive Committee (CODIR)
• Monitoring several times a year by the Compensation Committee to monitor objectives and their implementation

Public availability:

• Policy published on the website
• Distribution to employees through internal communication
• Displayed at OPmobility sites

Links to international standards:

• ISO 14001 standard
• ISO 50001 standard
• CDP climate
• EcoVadis questionnaire
• TFCD, CSRD and EU taxonomy
• SBTi Net Zero emission standards
• GHG protocol
• European REACH regulation (for chemical substances)

Implementation monitoring:

• ISO 14001 certification for industrial sites (87.2% of sites certified in 2024)
• Monthly reports to Senior Executives on safety performance, certifications, energy performance and associated CO2 emissions
• Annual reporting to Senior Executives of any environmental damage
• Support from external expert for questions relating to chemical products
• Phase I and phase II environmental analyses during purchase or construction of sites
• Substance traceability tools adapted to Taxonomy requirements
• Specific monitoring of parts containing substances of concern
• Regular audits analyzing energy consumption and pollutants released into air
• Corporate Safety Procedure for serious accidents and incidents with immediate notification, incident analysis, and corrective action plans

Key monitoring indicators:

• Total quantity of substances of concern generated or used during production or purchased: 13,261 tons
• Total quantity of substances of very high concern generated or used during production or purchased: 134 metric tons

Supporting Policies and Tools

While not separate policies, the following support the pollution prevention framework:

Supplier Charter:

• Requires suppliers to limit environmental impact
• Manage resources and waste responsibly
• Maintain required environmental approvals
• Avoid toxic products or limit use while guaranteeing safety
• Ensure traceability of raw materials and components
• Encourages ISO 14001 certification

Sustainable Purchasing Guide: Sets specific principles on:

• Reduction of carbon emissions
• Environmental conservation with pollution prevention
• Responsible management of resources, waste minimization, promotion of recycling and reuse
• Suppliers must have environmental management system complying with ISO 14001
• Sustainable resource management including energy consumption, use of chemicals, water management
• Responsible management of conflict minerals (in accordance with US SEC rule 13P-1)

Incident Management Procedures:

• Corporate Safety Procedure for serious accidents, fatal accidents or natural disasters
• Immediate notification within the hour to plant managers, business group and HSE department
• Detailed incident reports and communication to stakeholders
• Implementation of corrective action plans to prevent recurrence
• Site-specific protocols to reduce environmental impact and protect safety

Actions and resources related to pollution

OPmobility has disclosed two key actions related to pollution management, focused primarily on environmental due diligence and air emissions reduction. The company integrates environmental considerations into its value chain through its Duty of Vigilance Plan and Supplier Charter, which requires suppliers to limit environmental impact, manage resources and waste responsibly, and avoid or limit toxic products.

The company notes that financial resources related to the air pollution action plan are detailed in section 4.2.1.2.2 of ESRS E1 "Climate change."

Product-level pollution reduction

OPmobility designs products that contribute to pollution reduction:

• SCR systems: Technologies that effectively reduce NOx emissions from diesel vehicles
• Lightweight components: Plastic bumpers and fuel tank systems that reduce vehicle fuel consumption, indirectly reducing SOx, NOx and fine particles emissions

Key actions and resources

Upstream value chain requirements

The Supplier Charter formalizes requirements for suppliers including:

• Limit environmental impact
• Manage resources and waste responsibly
• Maintain required environmental approvals
• Avoid toxic products or limit their use while guaranteeing safety
• Ensure traceability of raw materials and components
• Use of environmentally friendly technologies
• Obtaining ISO 14001 certification encouraged

Pollution of air, water and soil

Air Emissions

Op Mobility discloses the following pollutant emissions for 2024:

Microplastics

Methodology

Emissions of carbon monoxide, ammonia, nitrogen oxides and sulfur oxides are calculated using two methodologies:

• Once a year, each site reports its VOC emissions using a "solvent assessment" carried out beforehand
• A module is used to calculate air pollutants by assessing the number of metric tons of VOCs discharged. The calculation takes into account the concentration at the inlet and outlet, as well as the throughput of the incinerator, divided by the number of hours of operation per day

Water and Soil Discharges

No specific quantitative data disclosed for emissions/discharges to water or soil in the excerpts provided.

Controls and Objectives

The company has set an objective to control all plastic granule discharges to avoid any water and soil contamination, with 100% target by 2028 and 100% progress reported for 2024.

Substances of concern and substances of very high concern

Policy and Management Approach

OPmobility implements rigorous controls on substances of concern (SoC) and substances of very high concern (SVHC) throughout its value chain. The Group's environmental policy commits to:

• REACH Compliance: Prohibiting the use of SVHC as defined by REACH regulation, unless otherwise exempted
• CMR Substances: Prohibiting the use of CMR substances (Carcinogenic, Mutagenic and toxic to Reproduction) classified 1A and 1B, unless an exemption is granted according to the procedure relating to the management of chemical products
• Authorized Products Only: Exclusively using authorized products accompanied by safety data sheets (SDS) in accordance with regulations in force

Monitoring and Traceability

OPmobility uses the IMDS (International Material Data System), a sector-based database developed for the automotive industry, to report the detailed composition of components and materials delivered. All materials used to manufacture vehicles are archived and tracked in this system.

The Group works with a third-party partner (Ecomundo) to:

• Identify substances considered as CMR or SVHC in development or production
• Conduct quarterly monitoring to map substances used and implement corrective actions
• Complete updates and projected views taking into account changes in regulations, guaranteeing regulatory compliance

Substance approval and control measures are integrated into each key step of the value chain, including manufacturing, use, and marketing processes.

Objective

The Group has set a target of no CMR 1A and 1B in production by 2030, as long as possible alternatives approved by customers exist.

Quantitative Disclosure

Substances of Concern

Substances of Very High Concern (SVHC)

Methodology

The lists of substances come from:

• Appendix VI of the CLP Regulation (table 3) for substances of concern classified in hazard categories
• The "Candidate List of Substances of Very High Concern for Authorization" of ECHA (criterion in articles 57 and 59 of REACH) for SVHC

The IMDS database defines substances contained by type of parts and their quantity. Third-party reports identify substances in chemicals. The Group's ERP provides quantities used. A reconciliation of these tools provides an overview of SoC and SVHC sourced and marketed.

Important note: In the absence of a specific classification standard recommendation, and given the multiplicity of categories for the same substance proposed by REACH, the data are not distinguished by hazard class. The Group has chosen to wait for a specific standard to be proposed under the CSRD.

In all of the Group's processes, the quantities of SVHC and SoC leaving sites equal the quantity entering, as processes do not generate any SoC or SVHC. However, SoC and SVHC can be found in various outgoing flows, such as products sold, emissions, or waste.

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

No expenditure related to a major incident or a pollution deposit occurred in 2024.

Methodologies

Description of measurement methods (air pollution)

The sites are confronted with two cases to calculate the quantities of pollutant emitted into the air.

Information is available locally

The site can obtain the information locally thanks to an annual measurement campaign carried out during the normal operation of equipment such as incinerators, furnaces, the presence of refrigerant gas leaks, etc., in particular for carbon monoxide, ammonia, nitrogen oxides and sulfur oxide emissions.

Emissions are estimated based on several parameters related to the Group's activity. It is extrapolated from production, taking into account elements such as opening hours and the quantities of plastic and composites processed.

Information is not available locally

If the information is not available locally, then it will be extrapolated based on information from the scientific literature.

This indicator is only validated by a sustainability auditor.

Description of measurement methods for microplastics

Data is retrieved from some of the sites concerned by microplastics. They come from waste service providers and are therefore external to OPmobility.

The raw material used (HDPE, adhesive, EVOH) consists of granules between 1 and 5 mm in diameter that the Group has considered by default as microplastics.

To determine the quantity of microplastics used, the sites measure the quantities released before and after the processes. Most of this comes from waste dust generated by regrinding, as well as microplastics recovered from the cleaning of areas near granule storage.

Finally, the final value is extrapolated to all sites using microplastics.

Regarding the limits of this approach, it should be noted that approximately half of the sites measured microplastic waste. In addition, no environmental accident with a leak of microplastics was reported in C‑Power's information system.

Substances of concern and substances of very high concern

The lists of substances used come from:

• appendix VI of the CLP Regulation (table 3) for substances of concern classified in the hazard categories;
• from the paragraph "Candidate List of Substances of Very High Concern for Authorization" of the ECHA (criterion in articles 57 and 59 of REACH) for substances of very high concern.

OPmobility's logistics practices do not take inventory into account, as they do not have a material impact. The IMDS database, an international reference in the automotive sector, is used to define the substances contained by type of parts and their quantity. Third party reports can identify the substances contained in the chemicals, given that the substances for maintenance products are only considered for C‑Power and Modules. The Group's ERP (integrated management software) provide the quantities used. A reconciliation of these tools and data provides an overview of the substances of concern and substances of very high concern that the Group sources and markets.

In all of the Group's processes, the quantities of SVHC and SOC leaving the sites are equal to the quantity entering, as the processes do not generate any SOC or SVHC. However, SOC and SVHC can be found in various outgoing flows, such as products sold, emissions or waste.

In the absence of a specific classification standard recommendation, and in view of the multiplicity of categories for the same substance proposed by REACH, the data are not distinguished by hazard class. The Group has chosen to wait for a specific standard to be proposed under the CSRD.

The methodology varies according to each business group because the nature of their products, their customers, their technologies, their data and their traceability history are different.

For example, in the context of H2-Power, the elements are extrapolated from an automotive project for which it has declarations in the IMDS tool. As this business group does not work exclusively for the automotive industry, the IMDS declaration is not regulatory and systematic.

Water consumption

Materiality assessment

OPmobility has undertaken an assessment to identify actual and potential material impacts related to water and marine resources in its direct activities, and its upstream and downstream value chain. To study the impacts related to the use of freshwater, the Group used water stress and water depletion indicators from the World Resources Institute (WRI). A mapping of water challenges was carried out to better understand the potential impacts on water resources using SBTN Water maps.

The impact of freshwater abstraction and consumption by industrial sites is limited, as a large part of the plants operate in a water use closed circuit.

There is no impact related to water discharges into the ocean at the level of the Group's industrial sites. OPmobility's direct and indirect activities are not associated with the exploitation of marine resources.

OPmobility has not, therefore, identified and assessed the actual and potential material impacts related to water and marine resources in its own activities and in its upstream and downstream value chain, and has not carried out consultations, including with affected communities.

Policies and commitments

The 6 Environmental Basics include water and soil protection commitments:

• Limit water consumption and report any leaks
• Report and control any oil or chemical spill
• Avoid any contamination of water and soil by plastic granules

Metrics disclosure status

All quantitative water consumption metrics under ESRS E3-4 are marked as non-material in the cross-reference table:

• ESRS E3-4 Water consumption (general): non-material
• ESRS E3-4 Total percentage of water recycled and reused paragraph 28 c): non-material
• ESRS E3-4 Total water consumption in m³ compared to the revenue generated paragraph 29: non-material

No numerical water consumption, withdrawal, discharge, or intensity data is disclosed.

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

This disclosure requirement has been assessed as non-material by OPmobility.

According to the company's cross-reference table, E3-5 "Anticipated financial effects from water and marine resources-related risks and opportunities" is marked as non-material.

Actions and resources related to circular economy

Overall circular economy resources allocation

Financial resources committed:

• €3 million in CapEx allocated in 2024 for circular economy projects
• Total planned resources 2022-2025: €10 million
• Resources committed at end of 2024: €3 million

Business group-specific circular economy initiatives

C-Power business group actions

Scope: Own operations and upstream value chain

Actions implemented:

• Helium recovery systems: Deployment at several sites, with planned rollout in all regions
• "Project One" partnership: Collaboration with main HDPE supplier to reduce carbon emissions related to HDPE production by 50%
• End-of-life tank material reuse: Study underway on reusing materials from end-of-life tanks

H2-Power business group actions

Scope: Own operations and downstream (product end-of-life)

Actions implemented:

• Carbon fiber recovery from pressurized composite tanks: Exploring recovery via solvolysis and thermopyrolysis
• Achievement in 2024: First 100% recycled carbon fiber parts produced

Exterior business group actions

Scope: Own operations

Actions implemented:

• Reuse of rinsing solvents at industrial sites

e-Power business group actions (Battery Regulation compliance)

Scope: Own operations and downstream value chain

Time horizon: Implementation ongoing, rollout in 2025

Actions implemented to anticipate Battery Regulation Directive:

1. Carbon footprint calculation:

   • Implementation of CO2 data collection tool
   • Carbon footprint calculation model developed
   • CO2 calculator for eco-design of battery packs (rolled out in 2025)

2. Battery pack recyclability:

   • Partnership with company specializing in recycling
   • System for tracing materials in supply chain
   • Battery passport accessible via QR code

3. Monitoring and traceability of battery packs: Strengthened to comply with EU regulation requirements

Cross-functional circular economy initiatives

Waste management promotion

Scope: Own operations (all sites)

Resources (non-financial):

• ISO 14001 certification: 87.2% of OPmobility's sites certified
• Top Planet Score: 60%

Eco-design approach

Scope: Product design phase (own operations and downstream)

Actions implemented:

• Application of eco-design principles focusing on:
  • Reduction of raw material consumption
  • Energy consumption reduction
  • End-of-life product impact mitigation (recyclability and energy recovery)
  • Ease of dismantling parts for better recycling channel management
  • Material compatibility to ensure high recyclability rates

Regulatory compliance:

• Targeting European Commission proposed threshold of 25% recycled plastic (PCR) in new vehicles, of which a quarter must come from end-of-life vehicles (ELVs)

Material innovation:

• Suppliers developing biosourced plastics technologies to replace oil with biomass (food materials or wood)
• Proposals made to manufacturers for recycled plastic parts production

Targets and KPIs

Link to overall strategy

Circular economy actions are integrated into OPmobility's transition plan, which was presented and approved by the Board of Directors. Progress and resources allocated are presented annually at the General Meeting of Shareholders.

ESRS E5-4: Resource Inflows

OPmobility is committed to transparent and responsible management of its incoming material resources. For 2024, the following inflow information is disclosed:

Types of Material Resources

OPmobility uses a wide variety of material resources in its operations, including:

• Raw materials: metals, plastics, etc.
• Electronic components and chemicals
• Rare earth elements: cerium, lanthanum, neodymium and praseodymium (used to manufacture metal parts, electrical components and seals)
• Critical materials: copper, gold, lead, manganese, nickel, silicon, tin and zinc in various parts, including printed circuits, electrical cables and headlights

These resources are essential to manufacture mobility products and solutions.

Quantitative Data

Total Products, Technical and Biological Materials

Secondary Materials (Recycled/Reused)

Biological Materials

Concerning the percentages of biological materials (including biofuels used for energy purposes) used to produce the Group's products and services (including packaging) that come from sustainable sources, as well as information on certification systems, OPmobility considers a value of 0%. Indeed, the biological materials processed by the Group are very negligible, with the exception of rubber seals and wooden pallets, and do not come from sustainable sources.

Sourcing and Supplier Information

• Sources of resources: They come from different regions of the world, from suppliers selected for their high standards in terms of sustainability and social responsibility
• Quantities and volumes: OPmobility publishes data on the quantities and volumes of the main material resources used. This information is presented in aggregate form to provide an overview of the Group's resource requirements
• Supplier selection criteria: Suppliers are selected according to strict criteria including quality of materials, compliance with environmental and social standards, and the ability to supply the required volumes reliably
• Inventory management: OPmobility implements advanced inventory management systems to optimize the use of material resources, minimize waste and ensure continuous availability of materials needed for production
• Sustainability initiatives: The Group engages in initiatives to reduce the environmental impact of its material resources, such as the use of recycled materials, reducing packaging and improving the efficiency of production processes

Methodology

The metrics are calculated on the IFRS scope. These metrics are consolidated from January 1 to November 30, 2024 and extrapolated to December 31.

To determine the total weight of its products and materials, OPmobility uses different methods:

• For the products of the Exterior, C-Power, Modules and Lighting business groups, the Group uses an extract from SAP which provides, by item code, the weights and quantities received in 2024. The methodology is identical for the raw materials of the C-Power and Lighting business groups.
• Concerning the products of the H2-Power business group, the Group does not have sufficiently precise data to make an estimate, and since the volumes were low, they were not included in the calculation. OPmobility will continue to improve the quality of this data in 2025.
• For the raw materials of the Exterior, H2-Power and Modules business groups, the material monitoring file is managed by the Materials Purchasing department of each business group.
• The biological materials used by OPmobility were considered as zero.
• For recycled materials and recycled products, monitoring tools are being implemented in each of its business groups. In 2024, only the Exterior and Modules business groups have a monitoring system to report data, in particular the percentage of recycled material in their plastics (RESIN).

Resource outflows

Recyclability and recycled content

Recycled materials in products:

• Development of a bumper with 30% recycled plastics (Exterior business group)
• Demonstrator containing 50% recycled plastics in body panels, including visible parts (Exterior business group)
• Construction of first demonstrators in 2023 with 100% recycled carbon fiber by filament winding (H2-Power business group)
• 132 recycled material references tested as of 2024

Product recyclability: The recyclability of OPmobility products was estimated for the Exterior and C-Power activities using different methods. The Group notes methodological limitations in calculating the weight of intermediate and secondary products. The typology of automotive parts and their diversity within OPmobility make it difficult to report the percentage of parts recycled for the Group, particularly for Modules parts, some of which are recycled and others, even within the same module, are not.

End-of-life considerations:

• Study on the reuse of end-of-life bumpers: work on the separation and recycling of components (Exterior)
• Research on chemical recycling of fuel tanks to produce HDPE with same characteristics as virgin HDPE from fossil sources (C-Power)
• Study on mechanical recycling of HDPE, including solvent-based desorption solutions and drying processes (C-Power)
• Exploring recycling processes (solvolysis, thermopyrolysis) for recovering long and continuous carbon fibers from pressurized composite tanks (H2-Power)
• Study on recycling and recovery of carbon composite waste (H2-Power)

Product lifetime

For scope 3.11 emissions calculations, the Group applies assumptions of:

• 10 years of use
• 15,000 kilometers traveled per year
• 10% of spare parts

This assumption has been maintained since 2019 to ensure comparability of data.

Eco-design commitments

OPmobility integrates environmental considerations from the design phase:

• Integration of carbon footprint assessment and life cycle analysis into project evaluation (Exterior)
• Development of lighter, more aerodynamic components
• Research and development of recycled and biosourced materials
• Optimization of manufacturing processes to limit energy consumption
• Implementation of responsible supply chains for traceability

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

Page reference: 182

Note: The cross-reference table indicates that E5-6 disclosure is located on page 182 of the Universal Registration Document 2024. However, the provided excerpts do not contain the actual content from page 182.

Waste

Total waste generated (2024)

Waste treatment and diversion (2024)

Recycled or recovered waste: 87.9% (2024 objective: 100%)

Waste management approach

OPmobility implements the waste management hierarchy outlined in EU Directive 2008/98/EC, prioritizing:

1. Prevention
2. Preparation for reuse
3. Recycling
4. Other recovery (including energy recovery)
5. Disposal

Key policies and practices:

• Waste prevention: Reintegration of internal production residues into the manufacturing process (reuse of waste and reduction in virgin material use)
• ISO 14001 certification: 87.2% of sites certified in 2024, targeting 100% by 2030
• Reporting methodology: Until now, OPmobility published waste generated according to type of waste and treatment type. To align with CSRD requirements, the Group now completes reporting with ranking of waste (hazardous and non-hazardous) and types of recovery and disposal aligned with Directive categorization
• Monitoring: Each site checks waste sorting and collection processes and uses certified service providers
• Supplier engagement: Supplier Charter requires responsible waste management

Methodological note: The 2024 reporting exercise concerning incoming resource flows has certain methodological limitations, particularly on the calculation of the weight of intermediate and secondary products.

Progress vs targets:

• 2023: 86% recycled or recovered waste
• 2024: 87.9% recycled or recovered waste
• 2024 target: 100%
• Strategic objective (ACT FOR PLANET pillar): Maximize waste recovery and minimize landfill

Policies related to own workforce

Op Mobility discloses several policies relevant to its own workforce under ESRS S1-1:

Code of Conduct

Policy name: Code of Conduct

Scope: Applicable to all entities and partners. All OPmobility employees must respect the Code of Conduct and contribute to its dissemination.

Governance:

• Established at the level of the Executive Committee
• Promoted by all business groups
• Managed by dedicated Committees in the presence of the Executive Committee
• Monitored several times a year by the Compensation Committee to monitor objectives and their implementation

Key content:

• Establishes the nature of relationships that OPmobility wishes to maintain within the Group to ensure good relationships, both internally and with all stakeholders: customers, suppliers, other partners, administrations, shareholders and the financial community
• Sets out values governing individual and collective behavior
• Determines fundamental principles underpinning internal control rules and procedures
• Includes an anti-corruption policy
• Covers respect for human rights and fundamental freedoms, health and safety, diversity, environment, and preventing discrimination, fraud, corruption and influence peddling
• Reminds employees of obligations: protecting the Group's assets and image, guaranteeing product quality and safety, and complying with ethics rules and regulations

International standards alignment:

• United Nations Global Compact
• UN Guiding Principles
• GEEIS Label (Gender Equality European & International Standard)

Public availability: Accessible on the Group's website and shared during onboarding sessions. Available on the Group's intranet and websites. Translated into 22 languages (in some references stated as 20 languages).

Monitoring: Each new employee is made aware of this Code. All employees complete e-learning about the Code of Conduct upon arrival (10,700 trained in 2024). The Group has first, second and third level controls to ensure compliance. A network of compliance correspondents helps raise awareness among all employees.

Human Rights Policy

Policy name: Human Rights Policy

Scope: Applicable to all entities. Applies to the entire value chain.

Governance: Last update was carried out in 2024. From Q1 2025, a Group-wide observatory will be set up under the responsibility of the Risk Management Director, the Compliance Director and the Global HR Labor Relations Director.

Key content:

• OPmobility's commitments in the area of human rights
• Description of human rights risks
• List of policies and procedures put in place to eliminate these risks
• Description of responsibilities
• Guarantees safe and healthy working conditions
• Respect for fundamental freedoms

International standards alignment:

• United Nations Global Compact
• UN Universal Declaration of Human Rights and its two complementary covenants
• ILO Fundamental Conventions
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines
• United Nations Sustainable Development Goals (SDGs)

Public availability: Available on the Group's website in the Sustainability section.

Monitoring: The Group has a whistleblowing mechanism available 24/7 via email (opmobility@ethicspoint.com) or mail. In 2024, 48 alerts were received. An ad hoc Committee composed of Legal, Compliance, Human Resources and Internal Audit Departments manages alerts. Any proven impact on human rights is subject to measures adapted to the degree of severity: training, instructions, corrective actions, or sanctions up to dismissal.

Diversity & Equity Impact (D&EI) Policy

Policy name: Diversity & Equity Impact (D&EI) Policy / Diversity program

Scope: Applicable to all employees. Some initiatives may exclude contractual partners.

Governance: Group People and Sustainability Department has operational responsibility.

Key content: Based on 5 commitments:

• Base employment decisions on qualifications, experience and performance with mandatory diversity and non-discrimination requirements
• Train partners and raise awareness at all levels
• Adapt policies and processes to ensure fairness in opportunities
• Develop employees with equal opportunities
• Communicate internally and externally about diversity commitment

Four priority dimensions:

• Gender: achieve gender balance, encourage higher representation of women in leadership roles
• Cross-cultural: diverse teams representing cultural diversity of countries where Group operates
• Intergenerational: value teams of all ages
• Disability: provide accessible tools and workplace

International standards alignment:

• ISO 10015 lifelong learning standards
• OECD recommendations on education and training
• United Nations Global Compact (membership since 2003)

Public availability: Accessible via internal training platforms, mentioned in individual employee development plans and annual report.

Monitoring:

• Recruitment guidelines on job offers, interviewer panels and shortlisted candidates
• Training for hiring managers and HRBPs
• Succession plans with attention to gender and culture dimensions
• "Unconscious bias" training for all managers
• 24 training modules available on U Learn platform
• Minimum 30% female participation in qualifying training programs
• Whistleblowing procedure for discrimination reports
• Compensation of executives includes ACT FOR ALL™ diversity target
• 4 dedicated global events annually (Equity Week, Cultural Diversity Week, Intergenerational Week, Disability Week)
• Key metric: 25% of Managers and Engineers are women; 23.1% of Senior Executives are women

Skills Development Policy

Policy name: Skills development policy (currently being drafted)

Scope: Applicable to all employees. Some initiatives may exclude contractual partners.

Governance: Group People and Sustainability Department.

Key content: Committed to promoting continuous learning and professional development of employees.

International standards alignment:

• ISO 10015 lifelong learning standards
• OECD recommendations on education and training

Public availability: Accessible via internal training platforms, mentioned in individual employee development plans.

Monitoring: Consultation with managers, employees and trade unions to assess training needs. In 2024, launched STARTER Program, CHARGER Program, and BOOSTER Program for career development.

Information Technology Security Policy

Policy name: Information Technology Security Policy

Scope: Applicable to all entities, partners and users.

Governance: Information Systems Department.

Key content: Committed to protecting data, applications, systems and networks against cyber threats and breaches.

International standards alignment:

• ISO/IEC 27001 standard
• NIST (National Institute of Standards and Technology) framework
• GDPR (General Data Protection Regulation)
• TISAX (Trusted Information Security Assessment Exchange) for the automotive industry

Public availability: Shared via the intranet, accessible to all employees. Communicated during training and onboarding.

Monitoring: Collaboration with cybersecurity experts, commercial partners and specialized associations: CLUSIF, CESIN.

Personal Data Protection Policy

Policy name: Personal Data Protection Policy

Scope: Applicable to all Group entities operating in the European Union, whether or not the processing of personal data is covered.

Governance: Information Systems Department.

Key content: Committed to protecting the personal data of employees, customers and partners.

International standards alignment: GDPR.

Public availability: Shared via the intranet, accessible to all employees. Communicated during training and onboarding.

Monitoring: Collaboration with the AFCDP (French Association of Correspondents for the Protection of Personal Data).

Health and Safety Policy

Policy name: Group health and safety policy

Scope: All Group entities and own workforce.

Governance: Not explicitly stated, but managed through HSE Network.

Key content:

• Zero accident strategy
• "6 Non Negotiables" safety measures covering: pedestrian traffic, wearing of PPE, handling of loads at height, use of forklifts, lockout and maintenance operations, work at height
• Promotes risk analysis and reporting of hazardous situations
• Daily monitoring of accidents
• Safety training and awareness campaigns

International standards alignment: Not explicitly stated for this policy.

Public availability: Communicated through internal campaigns (e.g., "I act" campaign). Updated visuals of "6 Non Negotiables" launched in 2024.

Monitoring:

• Daily monitoring and analysis of accidents (workplace accidents with and without lost time, first aid)
• Key metric: Accident frequency rate (FR2) reached its lowest level in 20 years in 2024
• 97.5% of sites proposed actions in favor of local communities
• Regular internal audits at all sites

Universal Parental Leave Model

Policy name: Universal parental leave model (introduced 2024)

Scope: All employees regardless of region.

Key content:

• 24 days of paid parental leave out of 12 months
• 16 weeks of paid maternity leave
• Guarantees equal rights and benefits for all employees

Monitoring: Ensures equal opportunities regardless of local regulations.

Anti-Corruption Policy

Policy name: Anti-Corruption Code of Conduct

Scope: All OPmobility employees. Updated following review of risk mapping in May 2024.

Governance:

• Board of Directors reviews anti-corruption system updates periodically
• Internal Control and Compliance Committee oversees compliance
• Regional Compliance Officers implement policies
• Compliance Department manages deployment

Key content:

• Details risky situations and prohibited behaviors
• Covers: gifts and hospitality, relations with intermediaries, sponsorship and philanthropy, donations, lobbying, conflicts of interest
• Associated policies on gifts and hospitality, conflicts of interest, and intermediaries
• Policies on sponsorship/philanthropy and lobbying being drafted (to be finalized Q1 2025)

International standards alignment:

• French law no. 2016-1691 of December 9, 2016 (Sapin 2 law) on transparency, fight against corruption and modernization of economic life

Public availability: Included in Code of Conduct, available on website and intranet.

Monitoring:

• E-learning on anti-corruption available in 23 languages for all Group managers and non-managers in exposed functions (91% coverage in 2024)
• E-learning on relations with intermediaries available in 22 languages
• Face-to-face training for over 800 employees most exposed in 10 highest-risk countries in 2024
• Corruption risk mapping updated May 2024
• Whistleblowing mechanism via NAVEX EthicsPoint platform
• Investigation Committee reviews all alerts
• Monthly reporting on alert status to CEO
• Key metrics: 0 convictions for violations; €0 in fines

Fair and Equitable Compensation Policy

Policy name: Fair and equitable compensation policy (referenced but not detailed as standalone)

Key content: Ensures compliance with legal minimum wage according to geographical location of sites. Analysis of wage gaps led to implementation of actions to gradually reduce gaps, with part of budget reserved for salary adjustments.

Social Dialogue and Collective Bargaining

While not a single named policy, the company describes extensive social dialogue practices:

• European Works Council established since 1996 (35 members from 10 countries)
• Local social dialogue at country and site level
• Numerous agreements signed annually (competitiveness agreements, profit-sharing, flexibility, disability employment)
• Compliance with ILO Conventions C87, C98, and C135
• All employees sign commitment to respect ILO standards in employment contracts

International standards alignment:

• ILO fundamental labor standards (C87, C98, C135)
• ILO Convention no. 111
• UN Global Compact principles on workers' rights

Characteristics of the undertaking's employees

Total headcount and FTE

No explicit total headcount or FTE figure for 2024 or 2023 was disclosed in the excerpts provided. References to "1 in 3 vehicles produced globally is equipped by OPmobility" and employee-related context appear, but absolute headcount numbers are not stated.

Headcount by gender

The excerpts reference "31% women" in the context of employee metrics (page 47), but do not provide absolute headcount by gender (male/female/other/not disclosed) or a total headcount denominator.

Headcount by country or region

No breakdown of headcount by country or region was disclosed in the excerpts.

Headcount by employment contract type

No breakdown by permanent/temporary/non-guaranteed hours contract type was disclosed.

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

No breakdown by full-time or part-time employment was disclosed.

Employee turnover

Senior manager turnover rate: 7.4% (page 47)

No overall employee turnover rate or absolute number of employees who left was disclosed.

New hires

Interns and apprentices: +1,200 in 2024 (page 47)

No total new hires number or hiring rate was disclosed.

Additional employment characteristics

Internal mobility: 35% (page 47)

Training: An average of 20 hours of training per year per employee (page 47)

Young people under the age of 30: 18% (page 47)

Methodology notes

The document states that training hours for OPmobility employees are monitored and "their distribution by gender was projected on the basis of the breakdown observed in the internal My Learning Place tool" (section 4.1.1.2, page 147). No further methodology for headcount data collection was provided in the excerpts.

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

Number of non-employee workers

Note: The document confirms that temporary employees exist and are tracked, with a recorded workplace accident rate for temporary employees of 0.57 in 2024.

Breakdown by type

The document defines non-employees as:

• Temporary employees (made available by a service company)
• Self-employment contracts

No specific numerical breakdown by these categories is provided.

Methodology

Scope: Non-employees are defined as individuals who do not have an employment contract with the Group, including temporary and self-employment contracts of the parent company and subsidiaries. The scope excludes joint ventures.

Calculation basis: The Group calculates the annual average Full-Time Equivalent (FTE) where possible. If values are not available, estimates are made based on AR 63.

Exclusions: The following are explicitly excluded from employee counts (and implicitly from non-employee tracking):

• Apprentices, work-study and professional training contracts
• School interns
• Subcontractors

Coverage: Non-employees are covered by the health and safety management system at 100%.

Health and safety data for non-employees

FR2 definition: The FR2 gives the number of accidents with and without lost time per million hours worked.

Multi-year comparison

No multi-year comparison data for non-employee headcount or characteristics is disclosed in the excerpts provided.

Collective bargaining coverage and social dialogue

Social dialogue bodies

OPmobility has established representative bodies for employee engagement:

European Works Council (EWC)

• Established since 1996
• Composed of 35 members representing 10 European countries (France, Germany, Spain, United Kingdom, Poland, Slovakia, Romania, Hungary, Czech Republic, Belgium)
• A plenary meeting was held in 2024 with the Group's CEO
• The European Works Council Bureau (6 permanent representatives plus 4 alternates) met twice during 2024

Employee representation on Board of Directors

• Two directors representing employees:
  • Amandine Chaffois, appointed by the France Group Works Council (term renewed in 2022 for three years)
  • Martin Krivan, appointed by the European Works Council (appointed June 20, 2024)

Local social dialogue

• More than 100 Works Councils and Safety Committees present at many sites, meeting regularly
• Social dialogue conducted at local level by country and by site with elected representatives and trade unions

Collective bargaining coverage

No quantitative metrics on the percentage of employees covered by collective bargaining agreements are disclosed in the excerpts.

Social dialogue commitments

OPmobility commits to:

• Freedom of association
• Compliance with rules governing information and consultation of employee representative bodies wherever they exist
• Respect for international standards, including ILO fundamental labor standards (C87, C98, C135)
• Respect for workers' rights established by the United Nations Global Compact

Negotiation outcomes

Negotiations with trade unions and employee representatives result in numerous agreements each year, including:

• Competitiveness agreement in Germany
• Agreement on employee profit-sharing in France
• Flexibility agreement providing for implementation of a Precautionary Savings Account in France
• Agreement on employment of persons with disabilities in France

Governance

• The People and Sustainability Department has operational responsibility to ensure high-quality and effective social dialogue
• This department coordinates the European Works Council and ensures discussions with union representatives and employee organizations at all levels
• Each regional, country, site or department manager, with support of the Human Resources function, is responsible for communication and dialogue with employees and their representatives

Diversity metrics

Board of Directors composition by gender

Age band distribution of total workforce

Gender representation in management positions

Current baseline (2024):

• Senior Executive positions: 23.1% women
• Managers and Engineers: 25% women
• Managerial roles globally: 21.4% women

Targets by 2030:

• 40% women in Senior Executive positions
• 30% women amongst Managers and Engineers
• 30% women in managerial roles globally

Intermediate milestones:

2025 targets:

• Senior Executives: 28% women
• Managers: 25% women
• Engineers and Executives: 27% women

2026 targets:

• Senior Executives: 30% women
• Managers: 26% women
• Engineers and Executives: 28% women

Persons with disabilities

Note: Subject to legal restrictions on data collection. The employment rate depends on laws of various countries which are not harmonized. Counting rules depend on individual's willingness to declare a disability.

Adequate wages

Benchmark used

Op Mobility states that "all employees receive an adequate wage, in accordance with the applicable benchmarks. No employee receives a wage lower than the applicable adequate wage index."

However, the company does not disclose which specific adequate wage benchmark is used. The only concrete reference to wage standards in the document states:

"OPmobility respects the legal minimum wage in each country in which it operates, in accordance with the applicable legal or contractual standard."

The Supplier Charter requires suppliers to ensure "fair wages" but does not define this against a living wage methodology.

Coverage

The company asserts 100% coverage with the statement:

"All employees receive an adequate wage, in accordance with the applicable benchmarks. No employee receives a wage lower than the applicable adequate wage index."

No quantitative assessment or verification methodology is disclosed.

Geographic scope

Global (all countries of operation), but no living wage benchmark methodology is disclosed.

Targets

No specific targets related to living wage are disclosed.

Methodology

No methodology is disclosed for how "adequate wage" is defined, calculated, or benchmarked. The company mentions:

• Participation in "regular surveys on compensation, benefit" to ensure competitiveness
• Analysis of gender pay gaps (gross indicator 21.9%, adjusted 5.8%)
• Compliance with legal minimum wage and contractual standards

The language used ("adequate wage index") suggests a benchmark may exist internally, but it is not named, described, or compared to recognized living wage standards (e.g., Fair Wage Network, Global Living Wage Coalition, Anker Methodology, etc.).

Value chain

The Supplier Charter requires suppliers to respect "fair wages" and the Know Your Suppliers approach assesses "fair wages, reasonable working hours and a safe working environment," but no living wage benchmark for suppliers is disclosed.

Assessment

Op Mobility asserts full compliance with "adequate wages" but provides no transparent living wage benchmark. The only verifiable standard mentioned is compliance with legal minimum wage in each country. This does not meet ESRS S1-10 requirements for living wage disclosure.

Social protection

Coverage metrics

OPmobility reports coverage of employees against loss of income from major life events:

Parental leave policy (implemented April 2024)

The Group implemented a common parental leave framework applicable worldwide (IFRS scope):

• Maternity and adoption leave: Minimum duration of 16 weeks with 100% compensation
• Additional parental leave: 24 days per year paid at 100% for all employees
• Scope: All business groups (Exterior, Lighting, Modules, C-Power, H2-Power)
• Coverage: All Group employees

Supplementary social protection schemes

Executive corporate officers (Laurent Burelle, Laurent Favre, Félicie Burelle) benefit from supplementary social protection schemes, including:

• Welfare and health insurance scheme for Group employees (decision of Board of Directors, September 24, 2019)
• Defined-benefit pension plans
• Healthcare cost plans (particularly in the US)

Type of coverage

Social protection is provided through:

• Public schemes: Base coverage in compliance with local laws and regulations in all countries of operation
• Private supplementary schemes: Including welfare insurance, health insurance, and defined-benefit pension plans (notably in US, France, Belgium)

Defined-benefit pension plans - key countries

Actuarial assumptions for post-retirement benefits (December 31, 2024):

Note: M = Managers; NM = Non-managers

Methodology

• Coverage data presented for permanent employees
• Parental leave policy monitored from second half of 2024
• No percentage of total workforce covered is explicitly stated for most protections (only qualitative "Yes" confirmations)
• Unemployment insurance not available in Mexico, India and Morocco

Persons with disabilities

Overall employees with disabilities

Percentage of employees with disabilities

Note: Data collection subject to legal restrictions in some countries.

Methodology and scope

The employment rate of persons with disabilities depends on the laws of the various countries, which are not harmonized. The rules for counting this population depend most of the time, as in France, on the individual's willingness to declare a disability. This is a factor limiting their identification and therefore the actions that can be taken to better integrate employees with disabilities.

Campaigns encouraging the disclosure of these situations are conducted on a regular basis and supported by the D&EI Diversity policy.

France-specific information

In France, OPmobility is a signatory of the Manifesto for the Inclusion of Persons with Disabilities in Economic Life, and includes its action plan in a disability agreement approved by the DRIEETS (Interdepartmental Regional Directorate for the Economy, Employment and Labor and Solidarity).

The employment rate of persons with disabilities in France exceeded the legal obligation of 6%, standing at 6.89% at December 31, 2023. The 2024 rate is not yet known for this publication since annual declarations are now made in May of year N + 1.

The reporting of this indicator is governed in France by strict standards and consolidated in the annual DOETH (Mandatory declaration of the employment of workers with disabilities) statement, which serves as the basis for establishing the mandatory annual contributions paid to Agefiph.

Key commitments in France

Mission Handicap France objectives:

• Raise awareness among all teams to change the way people look at disability and train key contacts
• Keep those with disabilities in employment
• Recruiting and integrating employees with disabilities
• Increasing purchases from the sheltered and adapted work sector (STPA)
• Management and monitoring of the disability policy in France

2024 facilities and initiatives

In 2024, facilities for employees with recognized disability focused on:

• Financing of equipment (hearing aids, ergonomic seats, PRM scooters, etc.)
• Home-work transport assistance
• Coaching

Purchases from the sheltered and adapted sector support employment of workers with disabilities through partnerships with ESATs (Établissement et Service d'Aide par le Travail) or EA (Adapted Companies) for packaging services, logistics, maintenance of green spaces, etc.

Training and skills development metrics

Average training hours per employee

Overall average: 20 hours per year per employee (2024)

Average training hours by gender

Performance and career development reviews

Percentage of Managers and Engineers who participated in regular performance and career development reviews:

Training initiatives

• Employees who completed ACT FOR ALL Climate School training (2024): 900
• Employees trained in cybersecurity (2024): 10,700

Training targets

OPmobility has set a measurable target to offer 22 hours of continuous training per year to each employee by 2030, including 5 hours of digital culture for Managers and Engineers.

Reference value: 20 hours in 2024
Intermediate milestone: 21 hours per year by the end of 2026, including 3 hours of digital training for Managers and Engineers.

Scope: All Group employees, worldwide.

Health and safety metrics

Coverage

Fatalities

Recordable work-related accidents and injury rates

Days lost

Methodology notes:

• FR2 (frequency rate 2) gives the number of accidents with and without lost time per million hours worked. The Group's FR2 was 0.68 in 2024, a decrease of 36% compared to 2023 (FR2 of 1.07).
• Each site enters the number of accidents and hours worked monthly into a specific data collection tool. Business groups validate the information before consolidation at Group level.
• Occupational illnesses are reported monthly and validated by business groups.
• Days lost due to workplace accidents are reported monthly and validated by business groups.

Work-life balance metrics

Parental Leave Policy

OPmobility implemented a Group-wide parental leave policy in April 2024:

• Maternity/adoption leave: Minimum of 16 weeks at 100% compensation
• Parental leave: Additional 24 days per year (equivalent to 5 weeks more than applicable local regulations) at 100% compensation
• Coverage: All Group employees (IFRS scope) across all business groups (Exterior, Lighting, Modules, C-Power, H2-Power)

Employees Entitled to Family Leave

Return-to-Work and Equal Treatment

The Group guarantees:

• Employees on maternity, adoption, or parental leave receive a salary increase at least equivalent to the annual budget during their leave period
• Systematic annual comparison of compensation changes by gender to ensure necessary adjustments
• Monitoring of policy performance implemented from second half of 2024

Gender Pay Gap Context

While not a direct S1-15 metric, the gender equality index in France ranges from 76 to 94 out of 100 depending on entity, demonstrating attention to gender equity related to family leave policies.

Note: The parental leave policy is part of the ACT FOR ALL™ program and its Care for People dimension, supporting Diversity, Equity and Impact initiatives while promoting work-life balance.

Compensation metrics

Pay gap

OPmobility discloses both unadjusted and adjusted gender pay gaps for 2024.

Unadjusted gender pay gap: 21.9%

Adjusted gender pay gap: 5.8%

The company notes that a large share of the gross differences observed can be explained by the geographical dispersion of the female and male populations and by the level of positions held in the organization. The adjusted indicator takes into account these two criteria (employment level and geographic location).

Gender pay gap by country

Remuneration ratio

Total annual compensation ratio (2024): 118.4

This ratio represents the total annual compensation of the highest-paid individual (CEO) compared to the median employee compensation (excluding the highest-paid person).

Methodology

Pay gap calculation methodology

Unadjusted gap: Calculated without taking into account explanatory factors such as geographical location, professional category, experience, position held or qualifications. It reflects an overall difference in the average pay of men and women.

Total compensation includes:

• Annual fixed salary and target bonuses
• Long-term incentives (deferred long-term incentives)
• Benefits in kind related to company car
• Profit-sharing and incentives for French entities

Adjusted gap: Calculated by neutralizing structural factors to measure the pay gap with comparable positions and qualifications. This approach takes into account:

• Internal job classification level (only includes levels with at least 3 representatives of each gender)
• Countries (target total hourly wage converted to euros)

Remuneration ratio calculation methodology

Numerator (CEO total annual compensation) includes:

• Fixed compensation
• Annual variable compensation
• Exceptional compensation
• Directors' fees
• Benefits in kind (car)
• Long-term incentives (valuation of shares granted in 2024)

Denominator (median employee compensation) includes:

• Gross salary
• Target bonus
• Incentives and profit-sharing for French entities
• Company car/Company car allowance
• Valuation of shares received in 2024

Items from collective agreements (personal risk insurance, health insurance, supplementary pension) were not taken into account because they were identical for all employees or proportional to base salary.

Incidents, complaints and severe human rights impacts

Metrics and targets

OPmobility has supplemented its strategy with ambitious targets, associated with the impacts, risks and opportunities identified in its double materiality analysis.

Additional context

OPmobility's Legal Department is systematically informed and consulted in the event of litigation or legal procedures. To date, OPmobility has not been convicted of any discrimination. This information will be centralized to a greater extent in 2025 with the establishment of a monthly social observatory, in which correspondents from all the regions in which the Group operates will participate.

Policies related to consumers and end-users

Personal Data Protection Policy

Key content/principles:

• Addresses commitments around personal data protection
• Subject to GDPR in Europe
• Incorporates data protection principles into management of new projects from design phase (Privacy by design)
• Ensures use of data is transparent and proportionate, in accordance with the European AI Act

Governance:

• Two internal Data Protection Officers (DPOs) steer GDPR compliance
• Network of correspondents in each country supporting the DPOs

Scope:

• Group-wide application
• European operations subject to GDPR

Links to standards/frameworks:

• European General Data Protection Regulation (GDPR)
• European AI Act
• NIS2 directive requirements

Monitoring/implementation:

• GDPR compliance organization with DPOs and country correspondents
• Participation in associations: CLUSIF (French Information Security Club), CESIN (French Club of experts in digital and IS security), CIGREF (IT Club of French Groups and Companies), AFCDP (French Association of Correspondents for the protection of personal data)
• Cybersecurity strategic plan for 2026
• Annual cybersecurity awareness program including e-learning modules, communication campaigns, and phishing detection exercises
• Internal system to assess maturity level of industrial sites
• External audits: 61 sites certified with TISAX (Trusted Information Security Assessment Exchange) in 2024
• In 2024: 10,746 employees trained through e-learning module and 2 phishing exercises conducted

Taking action on material impacts on consumers

OPmobility has been a signatory of the United Nations Global Compact since 2003, demonstrating its commitment to respect for human rights and social responsibility throughout its value chain. The company has deployed mitigation measures operationalized through the strategic pillar "Operational Excellence" and a quality policy aimed at protecting consumers.

1. Compliance with standards and regulations

• Scope: Own operations
• Actions:
  • Compliance with international standards (IATF 16949) and local regulations
  • Compliance with safety standards
  • Rigorous certification tests before the marketing of parts and components
• Governance: Quality Vice-Presidents of each business group are responsible for these policies
• Outcomes: No cases of non-compliance with various international texts were reported in 2024

2. Product quality and safety

• Scope: Own operations
• Actions:
  • Use of robust and certified materials to guarantee the safety of motorists
  • Resistance, wear and performance tests
  • Implementation of rigorous quality controls throughout production

3. Traceability and risk management

• Scope: Own operations and downstream (collaboration with manufacturers)
• Actions:
  • Parts traceability systems to quickly identify any defects
  • Crisis management and product recall procedures in the event of a component defect
  • Collaboration with manufacturers for rapid corrective actions

4. Innovation and continuous improvement

• Scope: Own operations
• Actions:
  • Research and Development to integrate safer and more reliable technologies
  • Improvement of manufacturing processes thanks to quality management methods
  • Continuous training of teams to guarantee optimal quality at each stage of production
• Resources (non-financial): Continuous training of teams

5. After-sales service and customer relations

• Scope: Downstream value chain (collaboration with manufacturers)
• Actions:
  • Guarantees on the parts provided and assistance in case of issues
  • Collaboration with manufacturers to improve consumer satisfaction
  • Transparent communication on equipment performance and potential risks

Policy framework

The actions are implemented through two key policies:

Compliance with the United Nations Global Compact

• Scope: Applies to all member companies, with no specific exclusions
• Governance: Board of Directors of OPmobility
• Standards: Universal Declaration of Human Rights, International Labour Organization Declaration, Rio Declaration on Environment and Development, United Nations Convention against Corruption
• Stakeholder engagement: Consultations and partnerships with companies, governments, civil society organizations

IMS (Integrated Management System) policy

• Scope: Applies to all business groups, and to all parts design
• Governance: Management of business groups
• Standards: ISO 9001, IATF 16949 (quality standards); Safety standards
• Stakeholder engagement: Collaboration with carmakers to ensure equipment compatibility
• Resources (non-financial): Accessible to all employees via the Company intranet

Alignment with Sustainable Development Goals

• SDG 12 (responsible consumption and production): Policies to promote sustainable consumption and production, reducing environmental impact of products
• SDG 16 (peace, justice and strong institutions): Commitment to ethical and transparent business practices, building consumer and end-user confidence

Business conduct policies and corporate culture

Code of Conduct

Policy description: The Code of Conduct establishes the nature of the relationships that OPmobility wishes to maintain within the Group in order to ensure good relationships, both internally and with all stakeholders: customers, suppliers, other partners, administrations, shareholders and the financial community. It sets out OPmobility's commitments and ethics commitments which must guide its actions daily. The Code of Conduct details dangerous situations and indicates prohibited behaviors to employees, including: gifts and hospitality; relations with intermediaries; sponsorship, philanthropy and donations; lobbying; and conflicts of interest.

Scope: Applicable to all entities and partners.

Governance and oversight:

• Established at the level of the Executive Committee (CODIR)
• Promoted by all business groups
• Managed by dedicated Committees in the presence of the CODIR
• Monitored several times a year by the Compensation Committee to monitor objectives and their implementation

Key content/principles: The Code defines the nature of relationships OPmobility wishes to maintain to ensure good internal cohesion and with all stakeholders. It presents non-negotiable rules in terms of respect for Human Rights, fundamental freedoms, health and safety, diversity, the environment, and preventing discrimination, fraud, corruption and influence peddling. It also covers employees' obligations: protecting the Group's assets and image, guaranteeing product quality and safety, and complying with ethics rules and regulations. The Code includes an anti-corruption policy.

Public availability: Accessible on the Group's website and shared during onboarding sessions. Available in 22 languages on the intranet and on the Group's websites.

Links to international standards:

• United Nations Global Compact (signatory since 2003)
• French Law no. 2016-1691 of 12/09/2016 on transparency, the fight against corruption and the modernization of economic life (Sapin 2 law)

Stakeholder engagement: Development in collaboration with internal stakeholders (employees, management) and external stakeholders (customers, suppliers).

Monitoring implementation:

• Training and awareness-raising for all Group employees covering ethics and compliance rules through e-learning
• 10,700 own workers trained in the Code of Conduct at the end of 2024
• Quarterly reports on the number of participants, the results of assessments, and improvements observed
• Ethics Awareness Index: 85% in 2024
• Number of employees trained/targeted: 92% in 2024
• All employees must respect the Code of Conduct and contribute to its dissemination
• Whistleblowing mechanism available 24/7 via opmobility@ethicspoint.com or mail
• Any proven impact on human rights is subject to measures adapted to severity: training, instructions, corrective actions, or sanctions up to dismissal

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Human Rights Policy

Policy description: The Human Rights Policy defines the way in which employees must interact with business partners, suppliers, communities and other stakeholders. Respect for human rights is one of OPmobility's fundamental values. The policy is public and subject to regular review. Updated in 2024.

Scope: Applies to all countries where the Group operates and throughout the value chain.

Governance and oversight:

• A Group-wide observatory will be set up from Q1 2025 under the responsibility of the Risk Management Director, the Compliance Director and the Global HR Labor Relations Director
• The Group Ethics Manager is responsible for the policy
• The Internal Control and Compliance Committee guides the Group's compliance policies

Key content/principles: The policy includes:

• Description of human rights risks
• List of policies and procedures put in place to eliminate these risks
• Description of responsibilities
• Protection against child labor (no employment under age 15, subject to more protective local provisions)
• Prohibition of human trafficking and forced labor

Public availability: Publicly available.

Links to international standards:

• United Nations Global Compact (since 2003)
• United Nations Universal Declaration of Human Rights and its two complementary covenants
• Fundamental Conventions of the International Labour Organization (ILO)
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines
• United Nations Sustainable Development Goals (SDGs)

Monitoring implementation:

• Whistleblowing mechanism for conduct or situations contrary to the Code of Conduct
• Any proven impact on human rights is subject to measures: training, instructions, corrective actions, or sanctions
• Network of local correspondents will centralize and analyze risks of non-compliance
• Monitoring of implementation of corrective actions

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Anti-Corruption Code of Conduct

Policy description: In accordance with French law no. 2016-1691 of December 9, 2016 on transparency, the fight against corruption and the modernization of economic life (Sapin 2), an anti-corruption code of conduct has been put in place. Updated in May 2024 following review of risk mapping.

Scope: Applicable to all OPmobility business groups (Exterior, Lighting, Modules, C-Power, H2-Power).

Key content/principles: Details dangerous situations and prohibited behaviors covering:

• Gifts and hospitality
• Relations with intermediaries
• Sponsorship, philanthropy and donations
• Lobbying
• Conflicts of interest

Related policies include: policy on gifts and hospitality, policy on conflicts of interest, and policy on intermediaries. Policies on sponsorship and philanthropy activities and lobbying activities are being drafted and will be finalized in Q1 2025.

Links to international standards:

• United Nations Global Compact
• French Sapin 2 law (Law no. 2016-1691 of 12/09/2016)

Monitoring implementation:

• E-learning on anti-corruption available in 23 languages for all Group Managers and non-Managers in exposed functions
• Online training on relations with intermediaries available in 22 languages
• In 2024, 91% of risky functions covered by online training programs
• In 2024, more than 800 employees most exposed to corruption risks received face-to-face training in the 10 most at-risk countries
• Corruption risk assessment conducted in May 2024
• Strict accounting controls to monitor financial transactions
• Regular internal audits to identify and assess corruption risks
• Investigation Committee examines alerts (composed of Compliance, HR and Internal Audit departments)
• Monthly report on alert status presented to ad hoc Committee and then to CEO
• Number of convictions for violations of anti-corruption laws: 0 in 2024
• Amount of fines for violation of anti-corruption laws: €0 in 2024

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Supplier Charter

Policy description: The Supplier Charter expresses OPmobility's expectations of its suppliers in terms of Corporate Social Responsibility (CSR). By signing the charter, suppliers undertake to respect, implement and ensure respect for all its principles by their own suppliers, service providers and subcontractors.

Scope: Commits all OPmobility suppliers. Applicable to all suppliers, service providers and subcontractors.

Governance and oversight:

• Established by the Executive Committee
• Managed by the Purchasing Department
• Supplier Compliance Committee ensures relevance of procedures and processes, validates assessment criteria, and establishes supplier roadmap for Sustainability

Key content/principles: Suppliers commit to:

• Comply with international texts governing labor law (ILO conventions on refusal of forced labor, child labor, wage discrimination)
• Respect human rights
• Conduct business in accordance with principles of loyalty, integrity and fairness
• Comply with all laws and regulations combating corruption, money laundering and anti-competitive practices
• Create and maintain safe and healthy working environment
• Environmental protection (measures adapted to their activities, use of natural resources, responsible waste management, reduction of consumption)

Public availability:

• Signature of the charter by all suppliers
• Intended to be included in contractual documents
• Document published on the website
• Distribution to employees through internal communications
• Translated into 19 languages
• Available online for signature when suppliers are referenced

Links to international standards:

• United Nations' Universal Declaration of Human Rights and its two additional covenants
• Ten principles of the United Nations Global Compact
• Fundamental Conventions of the ILO and ILO Declaration on fundamental labor principles and rights
• OECD guidelines

Stakeholder engagement: Development in collaboration with internal stakeholders (employees, management) and external stakeholders (customers, suppliers).

Monitoring implementation:

• Suppliers must inform OPmobility if unable to comply with provisions
• In case of breach, supplier must inform OPmobility and cooperate in investigations
• Serious and deliberate breach constitutes breach of contractual obligations
• OPmobility reserves right to request corrective measures or terminate contracts
• 95% of Group purchases assessed as part of Know Your Suppliers approach in 2024
• EcoVadis assessments for at-risk suppliers
• 75% of medium- and high-risk suppliers enrolled in self-assessment initiative in 2024
• Regular audits of suppliers
• Supplier visits and monitoring

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Diversity & Equity Impact (D&EI) Policy

Policy description: OPmobility values all differences and commits to not carrying out any form of discrimination or harassment. The D&EI policy is based on 5 commitments covering recruitment, succession plans, training, non-discrimination, and executive incentives.

Scope: Applicable to all employees.

Governance and oversight: Group People and Sustainability Department has operational responsibility.

Key content/principles: Five commitments:

1. Base employment decisions on qualifications, experience and performance with diversity and non-discrimination as mandatory requirements
2. Train partners and raise awareness at all levels with dedicated global communication campaigns
3. Adapt policies and processes to ensure fairness in opportunities
4. Develop employees with equal opportunities without exclusion or restriction
5. Communicate internally and externally about openness and commitment to diversity

Four priority dimensions: Gender, Cross-cultural, Intergenerational, Disability.

Six perpetuation measures:

1. Recruitment: diversity in talent pool, guidelines on job offers, interviewer panels, shortlisted candidates
2. Succession plans and promotions: attention to gender and culture dimensions
3. Training and education: "Unconscious bias" training for all managers, minimum 30% female participation in qualifying programs
4. Non-discrimination and equal opportunities: whistleblowing procedure, parental leave and maternity policy (16 weeks minimum maternity, 5 weeks additional parental)
5. Incentives for executives: ACT FOR ALL diversity targets in compensation
6. Promotion and engagement: 4 dedicated events annually (Equity Week in March, Cultural Diversity Week in May, Intergenerationality Week in October, Disability Week in December)

Links to international standards:

• United Nations Global Compact (membership in 2003)
• ILO standards (Convention No. 111)
• GEEIS Label (Gender Equality European & International Standard)

Stakeholder engagement: Development in collaboration with internal stakeholders (employees, management) and external stakeholders (customers, suppliers). Consultation with managers, employees and trade unions.

Monitoring implementation:

• 24 training modules available on U Learn for managers and executives
• Number of women in Group's own workforce: 8,989 in 2024
• Proportion of Managers and Engineers that are women: 25% in 2024
• Percentage of female Senior Executives: 23.1% in 2024
• In 2024, 100 sites participated in Equity Week
• WoMen@OP internal network with 800 employees in 21 countries
• Mentoring program with 534 participants in 2024
• Partnerships with external networks ("Elles bougent" in France, WAVE)

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Skills Development Policy (currently being drafted)

Policy description: Committed to promoting the continuous learning and professional development of employees.

Scope: Applicable to all employees; some initiatives may exclude contractual partners.

Governance and oversight: Group People and Sustainability Department.

Links to international standards:

• ISO 10015 lifelong learning standards
• OECD recommendations on education and training

Stakeholder engagement: Consultation with managers, employees and trade unions to assess training needs.

Monitoring implementation:

• Accessible via internal training platforms
• Mentioned in individual employee development plans
• Average of 20 hours of training per year per employee
• Three strategic programs launched in 2024: STARTER (for young talents), CHARGER (for managers moving to management positions), BOOSTER (for Directors moving to VP positions)

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Information Technology Security Policy

Policy description: Committed to protecting data, applications, systems and networks against cyber threats and breaches.

Scope: Applicable to all entities, partners and users.

Governance and oversight: Information Systems Department.

Links to international standards:

• ISO/IEC 27001 standard
• NIST (National Institute of Standards and Technology) framework
• GDPR (General Data Protection Regulation)
• TISAX (Trusted Information Security Assessment Exchange) for the automotive industry

Stakeholder engagement: Collaboration with cybersecurity experts, commercial partners and specialized associations: CLUSIF (Reference association for cybersecurity in France), CESIN (Club of Experts in IT and digital security).

Public availability: Shared via the intranet, accessible to all employees. Communicated during training and onboarding.

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Personal Data Protection Policy

Policy description: Committed to protecting the personal data of employees, customers and partners.

Scope: Applicable to all Group entities operating in the European Union, whether or not the processing of personal data is carried out in the EU.

Governance and oversight: Information Systems Department.

Links to international standards: GDPR (General Data Protection Regulation).

Stakeholder engagement: Collaboration with the AFCDP (French Association of Correspondents for the Protection of Personal Data).

Public availability: Shared via the intranet, accessible to all employees. Communicated during training and onboarding.

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Whistleblowing Procedure

Policy description: Offers protection to whistleblowers and enables reporting of any irregularities using the whistleblowing mechanism, particularly behaviors contrary to the Code of Conduct.

Scope: All directors, former or current employees, interns, temporary or seconded workers, candidates, shareholders and all stakeholders such as contractors, suppliers, subcontractors, customers and their employees.

Key content/principles:

• Independent and secure website (24/7) and dedicated telephone lines for each country
• Strict confidentiality of whistleblowers, persons concerned and third parties
• Whistleblowers acting in good faith cannot be dismissed, sanctioned or discriminated against
• Protection against all forms of retaliation
• Abuse of mechanism may result in disciplinary sanctions
• Updated in 2024 with new version managed by Ethics Point (NAVEX)
• Multilingual website (intranet and internet)
• Available 24/7, 365 days a year

Monitoring implementation:

• 48 alerts received in 2024
• Ad hoc Committee (Group Compliance, HR, Internal Audit) examines alerts and decides on investigations and responses
• Monthly report on alert status including KPIs (types of alerts, investigation results, substantiation rate, average days to close)
• Training provided for Committee members and HR staff on confidentiality, investigation initiation and interview documentation
• Poster campaigns at all sites to inform employees

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Environmental Policy

Policy description: Global approach based on knowledge, control and reduction of environmental impacts. Implements concrete measures to combat climate change, protect biodiversity and encourage rational management of natural resources.

Key content/principles:

• Carbon neutrality targets and roadmap aligned with Paris Agreement
• Top Planet program
• "6 Environmental Basics"
• Climate School training program (900 employees completed training in 2024)
• Balanced strategy of avoiding, reducing and offsetting environmental footprint

Links to international standards: Paris Agreement alignment.

Monitoring implementation:

• CO2 emissions tracking (Scope 1: 75 kt CO2eq, Scope 2: 373 kt CO2eq in 2024)
• Renewable electricity consumption rate: 87%
• 72% of sites ISO 14001 certified
• 45% of sites ISO 50001 certified

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Health and Safety Policy

Policy description: Implemented to reduce health and safety risks with steady improvement in key performance indicators. Zero accident strategy by promoting risk analysis and reporting of hazardous situations.

Key content/principles:

• "6 Non Negotiables" safety rules covering pedestrian traffic, PPE wearing, handling of loads at height, forklift use, lockout and maintenance, work at height
• Daily monitoring to report and analyze accidents
• Awareness campaigns
• Regular training sessions, participatory workshops and educational tools

Monitoring implementation:

• Accident frequency rate (FR2) over 12 months reached lowest level in 20 years in 2024
• 72.3% of sites IATF 16949 certified in 2024
• Rigorous audits at all sites to identify non-compliance and implement corrective actions

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Corporate Culture Management

OPmobility clearly defines its core values and mission, which are communicated at all levels upon onboarding. The corporate culture is developed through e-learning, face-to-face training and team workshops. The Group promotes its culture by embedding values in recruitment processes, performance reviews and internal communications.

Core values (from Leadership Model):

• We are passionate about what we do
• We feel responsible for future generations
• We dream big and deliver
• We trust each other
• We take risks to explore new opportunities

Monitoring:

• Regular employee engagement surveys (PULSE)
• Individual interviews and focus groups
• Internal whistleblowing system to collect feedback on alignment of practices with values

Prevention and detection of corruption and bribery

OPmobility applies strict anti-corruption policies, supported by a risk mapping covering all its entities and activities, including those recently acquired. Regular audits and awareness-raising actions strengthen the effectiveness of prevention systems.

Code of Conduct

Scope:

• Covers all employees and relationships with stakeholders including customers, suppliers, other partners, administrative bodies, shareholders and the financial community

Key content:

• Includes an anti-corruption policy
• Establishes the nature of relationships OPmobility wishes to maintain within the Group to ensure good relationships, both internally and with all stakeholders
• Commits to offering safe and healthy working conditions and respect for fundamental freedoms everywhere

Governance:

• Managed by dedicated Committees in the presence of the CODIR
• Monitored several times a year by the Compensation Committee to monitor objectives and their implementation

Standards and initiatives:

• Aligned with the principles of the United Nations Global Compact

Anti-Corruption Code of Conduct

Key content:

• Addresses corruption in general, its issues and forms
• Covers means of corruption and influence peddling, including gifts and hospitality, facilitation payments, intermediaries, sponsorship and patronage, lobbying, and conflicts of interest
• Defines behavior to be adopted
• Includes internal whistleblowing system for employees and stakeholders to report behavior or situation contrary to the Code

Implementation and monitoring:

• Deployment responsibility: Compliance department with support from Human Resources and Communication teams
• Regional Compliance Officers responsible for implementing policies
• Internal whistleblowing system enabling employees and stakeholders to report contrary behavior
• Alerts examined by Investigation Committee (composed of Compliance, Human Resources and Internal Audit departments)
• Monthly reporting on alert status with key performance indicators
• Regular internal audits to identify and assess corruption risks
• Strict accounting controls to monitor financial transactions
• Online training course on relations with intermediaries available in 22 languages for all Group Managers and non-Managers in exposed functions
• Face-to-face training program for managers and most exposed employees covering anti-corruption system, legal obligations, sanctions, and whistleblowing
• In 2024, 91% of risky functions covered by online training programs
• In 2024, over 800 employees most exposed to risks trained face-to-face in 10 most at-risk countries
• Anti-corruption system and updates periodically submitted to Board of Directors

Results:

• Number of convictions for violations of anti-corruption and anti-bribery laws: 0
• Amount of fines for violation of anti-corruption and anti-bribery laws: €0

Supplier Charter

Scope:

• Commits all OPmobility suppliers

Key content:

• Commits suppliers to comply with international texts governing labor law, such as ILO conventions on refusal of forced labor, child labor and covert wage discrimination
• Commits suppliers to respect human rights
• Commits suppliers to conduct business in accordance with principles of loyalty, integrity and fairness to ensure consistent compliance with all laws and regulations combating corruption

Standards and initiatives:

• The United Nations' Universal Declaration of Human Rights and its two additional covenants (International Covenant on Economic, Social and Cultural Rights and International Covenant on Civil and Political Rights)
• The ten principles of the United Nations Global Compact

Governance:

• Established at the level of the Executive Committee
• Managed by the Purchasing Department

Public availability:

• Document published on the website
• Distribution to employees

Implementation:

• Signature of the Charter by all suppliers
• Intended to be included in contractual documents

Additional policies

Policies on sponsorship and sponsorship activities, as well as on lobbying activities, are being drafted and will be finalized soon.

Incidents of corruption or bribery

Confirmed incidents

OPmobility reported zero confirmed incidents of corruption or bribery during the 2024 reporting period.

Convictions and fines

The company reported:

• Zero convictions for violations of anti-corruption and anti-bribery laws
• €0 in fines for violation of anti-corruption and anti-bribery laws

Investigation and whistleblowing procedures

OPmobility has implemented a comprehensive whistleblowing mechanism accessible to employees and external stakeholders 24/7 via email (opmobility@ethicspoint.com) and postal address. The system is managed by an ad hoc Committee composed of the Group Compliance, Human Resources and Internal Audit Departments.

In 2024, 48 alerts were received through the whistleblowing system, which covers potential breaches including corruption, bribery, conflicts of interest, gifts and hospitality violations, and other Code of Conduct violations.

The whistleblowing mechanism guarantees:

• Strict confidentiality of whistleblower identity
• Protection against retaliation for whistleblowers acting in good faith
• Independent investigation by internal or external parties
• Multilingual access (22 languages) via website and dedicated telephone lines for each country

Anti-corruption framework

OPmobility maintains an anti-corruption compliance program including:

• Updated Anti-Corruption Code of Conduct (revised in 2024)
• Risk mapping updated in May 2024 identifying Sales, Finance, Purchasing and Logistics as most exposed functions
• E-learning training on anti-corruption available in 23 languages for all managers and exposed functions
• Face-to-face training: over 800 employees in the 10 most at-risk countries received awareness training in 2024
• 91% of risky functions covered by online training programs
• Policies on gifts and hospitality, conflicts of interest, and intermediaries

The company adheres to French Law no. 2016-1691 on transparency, the fight against corruption and modernization of economic life, as well as the United Nations Convention against Corruption.

Political influence and lobbying activities

Materiality assessment

According to the cross-reference table (page 287), ESRS G1-5 (Political influence and lobbying activities) has been assessed as non-material by OPmobility and is therefore not subject to detailed disclosure requirements.

Ethical standards and guidelines

OPmobility's Anti-Corruption Code of Conduct covers lobbying activities as one of the risk situations. The Code details dangerous situations and indicates prohibited behaviors to employees, including:

• Gifts and hospitality
• Relations with intermediaries
• Sponsorship, philanthropy and donations
• Lobbying
• Conflicts of interest

As part of a continuous improvement approach, a policy on lobbying activities is being drafted and will be finalized during the first quarter of 2025 (page 280).

The Group's anti-corruption e-learning training, available in 23 languages and taken by all Group Managers as well as non-Managers in exposed functions, covers lobbying among other topics.

Face-to-face training programs for managers and employees most exposed to corruption risks also address "the means of corruption and influence peddling, including gifts and hospitality, facilitation payments, intermediaries, sponsorship and patronage, lobbying, and conflicts of interest" (page 282).

Stakeholder engagement

OPmobility engages with trade associations through participation in working groups:

Trade associations: Attendance at AFEP, MEDEF, PFA and CLEPA meetings

• AFEP: Association Française des Entreprises Privées (French Association of Private Companies)
• MEDEF: French Company Association
• PFA: Platform for the Automotive Industry (brings together the automotive industry in France)
• CLEPA: European Association of Automotive Suppliers

(Page 157)

Disclosure status

No quantitative data on political contributions, lobbying expenditure, or trade association membership fees is disclosed in the 2024 Universal Registration Document. The topic is flagged as non-material in the company's ESRS disclosure framework.

Payment practices

Policy and approach

OPmobility applies payment terms in its contracts and orders that comply with the customs or laws in force in each country. As part of the "Purchase to Pay" process (from order to payment), the Group's systems systematically submit invoices for payment according to the terms of the order recorded at the time of its entry, or failing that, according to the terms of the invoice. Payment, after systematic control, is managed by the accounting departments of the invoiced entities.

Regarding the Company's standard payment terms, the practices of each business group are different. These can be found in the general terms and conditions of sale of each business group. Despite the efforts made by OPmobility, the Group does not have any information to date concerning the share of payments aligned with standard payment terms, and will endeavor to produce this data as of next year.

In order to ensure fair business practices and prevent late payments, OPmobility implemented the following actions in 2024:

• Contractual transparency: systematic inclusion of clear clauses on payment terms and penalties in the event of late payment in all supplier contracts

Metrics

Trade receivables overdue (French entity - OPmobility SE)

Invoices issued and unpaid at closing date:

Invoices received and unpaid at closing date:

Invoices excluded (disputed or non-recognized liabilities and receivables): 0 invoices, €0

Payment periods used as reference (contractual or legal):

• 30 days from invoice date – 30 days from the end of the month
• 45 days from invoice date – 45 days from the end of the month
• 60 days from invoice date
• Upon receipt