Proximus

The role of the administrative, management and supervisory bodies

Board of Directors

The Board of Directors is composed of 14 people and defines Proximus' general policy and strategy and supervises operational management.

Composition: The Board of Directors is composed of no more than fourteen members, including the person appointed as Chief Executive Officer. The CEO is the only executive member of the Board. All other members are non-executive directors and 50% of the members of the Board of Directors are independent directors.

Appointment: Directors are appointed for a renewable term of up to four years. The directors are appointed at the general meeting by the shareholders. The Board of Directors exclusively recommends candidates who have been proposed by the Nomination & Remuneration Committee.

Competences: The Board of Directors meets whenever the interests of the company so require or at the request of at least two directors. In principle, the Board of Directors holds five regularly scheduled meetings annually, in addition to one meeting dedicated to the affiliates. The Board's decisions are made by a simple majority of the directors present or represented.

Committees

Proximus has four Board committees:

Audit & Compliance Committee: Consists of five non-executive directors, the majority of whom are independent. The Committee's role is to assist and advise the Board of Directors in its oversight of:

• the financial and non-financial reporting processes
• the ESG reporting processes
• the efficiency of the systems for internal control and risk management of the company
• the company's internal audit function and its efficiency
• the quality, integrity, and legal control of the statutory and consolidated annual accounts
• the relationship with the company's auditors
• the company's compliance with legal and regulatory requirements

Nomination & Remuneration Committee: Consists of five directors, the majority of whom are independent. The Committee's role is to assist and advise the Board of Directors regarding:

• the nomination of candidates for appointment to the Board of Directors and the Board Committees
• the appointment of the CEO and the members of the Leadership Squad
• the remuneration of the members of the Board of Directors and the Leadership Squad
• the annual review of the remuneration concept and strategy for all personnel

Transformation & Innovation Committee: Discusses selected files concerning technology, network, branding/marketing, sustainability, transformation, HR skills, and digitalization.

International Committee: Discusses the integration of international affiliates, the setting of KPIs for international business development, and international acquisitions.

Leadership Squad

The role of the Proximus Leadership Squad (PLS) is to support the CEO in the day-to-day management of the Group. In addition to the CEO, the PLS is composed of eight members with specific responsibilities across different business areas.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Board Committee Oversight

Audit & Compliance Committee: The Audit & Compliance Committee's role includes oversight of:

• the ESG reporting processes
• the efficiency of the systems for internal control and risk management
• the company's compliance with legal and regulatory requirements
• internal compliance with the company's Code of Conduct

Transformation & Innovation Committee: This is a permanent committee of the Board, discussing selected files that include sustainability matters among other topics such as technology, network, branding/marketing, transformation, HR skills, and digitalization.

Board Meeting Structure

The Board of Directors holds regular meetings to address strategic matters including sustainability:

• Five regularly scheduled meetings annually
• One meeting dedicated to the affiliates
• Additional annual meeting to discuss and evaluate the strategic long-term plan
• Ad hoc meetings as required

Reporting Process

Critical concerns are communicated to the Board via the Audit & Compliance Committee. The Audit & Compliance Committee is informed of all discussions and decisions made by the management within the Risk Management Committee.

ESG Integration

Proximus has embedded its nine Environmental, Social and Governance (ESG) commitments into its bold2025 strategy. The Board oversees the implementation of these commitments through various committees and regular reporting processes.

Integration of sustainability-related performance in incentive schemes

Leadership Squad Remuneration Structure

The remuneration of the members of the Leadership Squad includes sustainability considerations through:

Performance-based Variable Remuneration: A significant part of their total remuneration is variable, based on stringent quantitative and qualitative performance criteria, driven by the company's objectives in terms of performance and growth and by the company's commitment to contribute to an inclusive, safe, sustainable and prosperous digital Belgium.

Key Performance Indicators: The Nomination & Remuneration Committee determines the performance measurement targets of the CEO and the members of the Leadership Squad through Key Performance Indicators, which include ESG-related metrics.

ESG Performance Metrics

Proximus tracks several sustainability-related KPIs that are integrated into its performance management:

Environmental targets:

• Net zero by 2040: -16% year over year CO2 emissions Scope 1+2 (2024)
• Truly circular by 2030: 935,378 refurbished fix devices and 140,587 mobile devices collected

Social targets:

• Employee engagement at > 75%: achieved 76% in 2024
• Increase % women in top management functions: reached 25% in 2024
• Digital inclusion: 15,138 people trained through digital inclusion projects

Governance targets:

• Maintain high cybersecurity resilience: achieved 99% in 2024

Total Rewards Program Objectives

The main objectives of the Global Rewards Program include:

• to stimulate empowerment to meet our commitment to participate in the creation of an inclusive, safe, sustainable and prosperous digital Belgium
• to link pay to both individual performance and the overall success of the company in order to reinforce the alignment with the business strategy and successful execution

Statement on due diligence

Code of Conduct and Ethical Framework

Proximus has adopted a Code of Conduct, applicable to all employees. Proximus employees must follow mandatory training on the application of the principles of the Code of Conduct. The company has various internal policies to ensure employees act ethically.

Supplier Management

Proximus views suppliers as key partners in realizing its vision, mission and strategy. The Procurement department manages relationships with 3,200 suppliers across 52 countries.

Supplier Code of Conduct: Supplier Code of Conduct is included in all contracts to ensure adherence to ethical standards.

Supplier Engagement Program: Proximus has a Supplier Engagement Program with the top 150 suppliers, focusing on sustainability and compliance matters.

Risk Management

Proximus has organized its internal control and risk management systems to ensure continuous review and follow-up of all components. The company maintains:

• Clear definition of responsibilities
• Sufficient resources and expertise
• Appropriate information systems, procedures, and practices

Compliance and Internal Controls

The Audit & Compliance Committee plays a key role in the organization and oversight of internal controls and risk management systems. The committee ensures compliance with:

• Legal and regulatory requirements
• Company's Code of Conduct
• Dealing Code and other key policies

Related Party Transactions

The Board adopted a "related party transactions policy" which governs all transactions or other contractual relationships between the company and its Board members. This policy ensures appropriate oversight of potential conflicts of interest.

Risk management and internal controls over sustainability reporting

Internal Control System

The Proximus Board of Directors is responsible for the assessment of the systems for internal control and risk management. Proximus' internal control system is characterized by:

• Clear definition of responsibilities
• Sufficient resources and expertise
• Appropriate information systems, procedures, and practices
• Continuous review and follow-up of all components

Sustainability Reporting Controls

Proximus gives high importance to the timely and qualitative delivery of sustainability information in conformity with European Sustainability Reporting Standards (ESRS). The company has organized its internal control and risk management systems in accordance with sustainability reporting requirements.

Audit & Compliance Committee Role

The Audit & Compliance Committee (ACC) plays a key role in oversight of:

• ESG reporting processes
• Efficiency of systems for internal control and risk management
• Company's compliance with legal and regulatory requirements
• Follow-up of questions and recommendations made by auditors

External Assurance

This report has been independently verified by Deloitte. Deloitte's reports on the sustainability statements and the financial information can be found in the Auditor's reports. Deloitte Auditors SRL is responsible for the review of the sustainability reporting (CSRD).

Risk Management Committee

The Audit & Compliance Committee is informed of all discussions and decisions made by management within the Risk Management Committee. Critical concerns are communicated to the Board via the Audit & Compliance Committee.

Reporting Standards Compliance

The reporting process ensures disclosure of sustainability data that is balanced, comparable, accurate, reliable, and in line with the mandatory requirements of the Corporate Sustainability Reporting Directive (CSRD). The structure was developed in accordance with European Sustainability Reporting Standards (ESRS).

Strategy, business model and value chain

Purpose and Strategy

Proximus' sense of purpose is "Boldly building a connected world that people trust, so society blooms". This captures the DNA of the company and is built on three dimensions:

1. Actively building a connected world
2. Ensuring trustworthiness, security and sovereignty of digital societies
3. Investing in digital accessibility and inclusiveness, enabling society to flourish

bold2025 Strategy

Proximus shaped its bold2025 strategy by placing its purpose at the core and embedding its ESG commitments. The strategy relies on exceptional strengths:

• Our people
• Our gigabit network
• Our technology assets

Strategic Pillars:

• Delight customers with unrivalled experience
• Roll out #1 gigabit network for Belgium
• Grow profitably, locally and globally, through strong brands
• Engineer technology assets to enable digital ecosystems
• Act for an inclusive society and be sustainable in everything we do
• Foster an engaging culture and empowering ways of working

Business Model

Proximus Group is divided into two distinct segments:

Domestic segment: Telco and IT businesses in Belgium, the Netherlands and Luxembourg

• Residential market: Proximus (premium), Scarlet (no-frills), Mobile Vikings (100% digital), Tango (Luxembourg)
• Enterprise market: Proximus NXT (convergent B2B ICT umbrella brand)
• Wholesale market: Open network welcoming wholesale partners

International segment: Global digital communications operations

• BICS: Global communications for telecom operators
• Telesign: Digital identity and programmable communications
• Route Mobile: Cloud communication services and CPaaS solutions

Value Chain

Main Inputs:

• Employees: 13,862 employees with 25% women in top management, 98.9% permanent contracts
• Suppliers: 3,200 active suppliers across 52 countries
• Operations & society: Presence in 180+ countries, >37% of Belgian premises connectable to fiber, 67.6% 5G indoor coverage
• Financial assets: EUR 1,355 million CapEx, EUR 3,912 million net debt
• Intellectual assets: Strong and trusted brands, expertise, IP rights
• Environment: 426,250 MWh energy consumption

Business Activities: Through leading brands, meeting demands of residential, enterprise, public sector and wholesale markets in Benelux and internationally.

Main Outputs:

• Financial: EUR 1,850 million Group underlying EBITDA, EUR 0.6 per share dividend
• Social: 76% employee engagement, NPS leadership in segments
• Environmental: 422,284 tons GHG emissions, >1 million collected mobile phones
• Security: Fraud prevention blocking >666 million calls, >127 million phishing messages

International Expansion

Proximus Global was created in December 2024, integrating BICS, Telesign and Route Mobile under one umbrella. This provides comprehensive "Connect – Engage – Protect" digital communications solutions across the entire value chain.

Interests and views of stakeholders

Stakeholder Engagement Approach

Proximus aims to improve its reporting through continuous stakeholder engagement. The main social aspects of the report are shared with social partners, while the complete document is presented to shareholders during the Annual General Meeting.

Key Stakeholder Groups

Shareholders: Proximus is a publicly listed company with the Belgian State as majority shareholder (through SFPIM). The company maintains a Relationship Agreement with its majority shareholder that creates a framework for information exchange while preserving company autonomy.

Employees: With 13,862 employees globally, Proximus maintains ongoing dialogue through:

• Social partnership discussions
• Employee engagement surveys (76% engagement score in 2024)
• Regular communication on strategic developments
• Training and development programs

Customers: Serving more than 2.8 million residential customers and almost 450,000 businesses across Belgium:

• Customer experience measurement through Net Promoter Score (NPS)
• Multi-brand strategy addressing different customer segments
• Continuous service quality improvements
• Digital platform development (Proximus+ app)

Suppliers: Managing relationships with 3,200 suppliers across 52 countries:

• Supplier Engagement Program with top 150 suppliers
• Supplier Code of Conduct included in all contracts
• Focus on sustainability and CO2 emission reduction

Communities and Society: Contributing to digital inclusion and societal development:

• Digital inclusion projects training 15,138 people in 2024
• Investment in national digital infrastructure
• Cybersecurity protection services
• Support for local sports and cultural initiatives

Regulatory Bodies: Working with Belgian and European regulators:

• Collaboration with BIPT (Belgian Institute for Postal and Telecom Services)
• Compliance with CSRD and ESRS requirements
• Participation in regulatory consultations

External Recognition

Proximus completes questionnaires from ESG rating agencies such as CDP, Sustainalytics and EcoVadis to monitor performance:

• "A" score in the climate change category by CDP in 2024
• EcoVadis platinum medal in 2024

Customer Experience Focus

Net Promoter Scores demonstrate customer satisfaction:

• NPS residential convergent customers: +13
• NPS Scarlet: +22
• NPS Mobile Vikings: +46

Partnership Approach

Proximus fosters strategic partnerships to deliver value:

• Network sharing agreements (MWingz with Orange Belgium)
• Fiber deployment partnerships (Unifiber, GoFiber, Fiberklaar)
• Technology partnerships (Microsoft, Infosys)
• Innovation partnerships with universities and research institutes

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

Material Topics Integration

Proximus has embedded its nine Environmental, Social and Governance (ESG) commitments into its bold2025 strategy, addressing material impacts, risks and opportunities across all business activities.

Climate Change Impacts and Strategy

Opportunities:

• Network infrastructure enabling remote work and digital services, reducing societal carbon footprint
• Energy efficiency improvements in network operations
• Circular economy initiatives reducing waste and resource consumption

Risks:

• Physical climate risks to network infrastructure
• Transition risks from evolving climate regulations
• Increased energy costs and carbon pricing

Strategic Response:

• Net zero by 2040 commitment with 16% reduction in Scope 1+2 emissions in 2024
• Investment in energy-efficient network technologies
• Renewable energy sourcing (32% sustainable financing)

Digital Inclusion and Social Impact

Opportunities:

• Bridging digital divide through network deployment
• Enabling digital transformation for businesses and society
• Creating employment and skills development

Challenges:

• Ensuring affordable access for all citizens
• Addressing digital literacy gaps
• Managing technology transition impacts

Strategic Response:

• Universal gigabit connectivity ambition (>42% fiber coverage achieved)
• Digital inclusion programs (15,138 people trained in 2024)
• Multi-brand strategy for different market segments

Cybersecurity and Trust

Risks:

• Increasing cyber threats and fraud attempts
• Data protection and privacy concerns
• Digital sovereignty and security requirements

Opportunities:

• Building trust through superior security services
• Enabling secure digital transformation
• Positioning as trusted partner for critical infrastructure

Strategic Response:

• 99% cybersecurity resilience index achieved
• Fraud prevention blocking >666 million call attempts
• Investment in AI-based security solutions
• Proximus Ada center of excellence for AI and cybersecurity

Talent and Innovation

Challenges:

• Skills shortage in technology and digital sectors
• Rapid technological evolution requiring continuous learning
• Competition for talent in global markets

Opportunities:

• Developing future-ready workforce
• Innovation leadership in 5G, AI, and cybersecurity
• International expansion creating growth opportunities

Strategic Response:

• 82% of employees attended ≥5 training days
• Investment in reskilling and upskilling programs
• 25% women in top management functions
• Think Possible culture promoting innovation

Market Structure and Competition

Challenges:

• New market entrants increasing competition
• Regulatory changes affecting market dynamics
• Pressure on pricing and margins

Opportunities:

• Network infrastructure advantage through early fiber and 5G deployment
• Wholesale model enabling industry collaboration
• International expansion diversifying revenue sources

Strategic Response:

• Continued network leadership investments
• Partnership agreements for efficient deployment
• Creation of Proximus Global for international growth

Resource Efficiency and Circular Economy

Environmental Impacts:

• Electronic waste from device lifecycle
• Resource consumption in network operations
• Packaging and materials usage

Strategic Response:

• Truly circular by 2030 ambition
• 935,378 refurbished devices and 140,587 mobile devices collected
• Energy consumption optimization programs

Financial Sustainability

Performance Integration:

• ESG metrics integrated into executive compensation
• Long-term value creation through sustainable practices
• Stakeholder value balanced with shareholder returns
• EUR 1,850 million Group underlying EBITDA demonstrating financial strength while investing in sustainability

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

Materiality Assessment Framework

Proximus conducts materiality assessments to identify and assess material impacts, risks and opportunities. This process is integrated into the company's strategic planning and ESG reporting framework aligned with CSRD requirements.

ESG Commitments Integration

The company has defined nine Environmental, Social and Governance (ESG) commitments that form the foundation of its materiality assessment:

Environmental Commitments:

• Net zero by 2040
• Truly circular by 2030

Social Commitments:

• Digital inclusion contributions
• Employee engagement and diversity
• Customer experience excellence

Governance Commitments:

• Cybersecurity resilience
• Ethical business conduct
• Innovation leadership

Risk Management Integration

The risk management process is overseen by the Risk Management Committee, with the Audit & Compliance Committee informed of all discussions and decisions. Critical concerns are communicated to the Board via the Audit & Compliance Committee.

Stakeholder Input Process

Proximus engages various stakeholder groups to inform its materiality assessment:

• Shareholders through Annual General Meetings
• Employees through engagement surveys and social partnership
• Customers through NPS and satisfaction surveys
• Suppliers through engagement programs
• Regulators through ongoing dialogue
• Communities through digital inclusion initiatives

External Validation

The company participates in external ESG assessments to validate its materiality approach:

• CDP climate change assessment ("A" score in 2024)
• EcoVadis sustainability evaluation (Platinum medal in 2024)
• Sustainalytics ESG ratings

Strategic Integration

Material topics are integrated into the bold2025 strategy through specific performance indicators and targets tracked at Board level:

Continuous Monitoring

The materiality assessment is continuously updated through:

• Regular stakeholder feedback collection
• Industry trend analysis
• Regulatory requirement updates
• Internal risk assessment reviews
• External ESG rating feedback

Reporting and Transparency

This report covering 2024 is Proximus' first report compliant with CSRD, demonstrating the company's commitment to enhanced transparency and accountability in materiality assessment and reporting.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

This integrated annual report 2024 represents Proximus' first report compliant with the Corporate Sustainability Reporting Directive (CSRD) and is structured in accordance with the European Sustainability Reporting Standards (ESRS).

ESRS Coverage

Based on the materiality assessment, Proximus covers the following ESRS topics in its sustainability reporting:

ESRS 2 – General Disclosures: Full coverage of governance, strategy, and materiality disclosures

ESRS E1 – Climate Change: Comprehensive coverage including:

• Climate transition planning
• GHG emissions (Scopes 1, 2, and 3)
• Energy consumption and mix
• Climate-related targets and policies

ESRS E3 – Water and Marine Resources: Coverage of water consumption and management

ESRS E5 – Resource Use and Circular Economy: Coverage including:

• Circular economy policies and targets
• Resource inflows and outflows
• Waste management and device collection programs

ESRS S1 – Own Workforce: Comprehensive coverage including:

• Workforce policies and characteristics
• Diversity and inclusion metrics
• Training and development
• Health and safety
• Employee engagement

ESRS S2 – Workers in the Value Chain: Coverage of supplier-related workforce policies

ESRS S3 – Affected Communities: Coverage through digital inclusion and community programs

ESRS S4 – Consumers and End-users: Coverage through customer experience and digital accessibility

ESRS G1 – Business Conduct: Coverage including:

• Business conduct policies
• Anti-corruption measures
• Supplier management

Content Index

The report includes an ESRS Index (page 423) providing detailed mapping of disclosure requirements to specific report sections.

Assurance and Verification

The sustainability statements have been independently verified by Deloitte, as referenced in the Auditor's reports section.

Additional Frameworks

Beyond ESRS compliance, the report also addresses:

• EU Taxonomy requirements
• Task Force on Climate-related Financial Disclosures (TCFD) recommendations (TCFD Table on page 455)
• Contribution to UN Sustainable Development Goals (SDGs) (page 457)

Reporting Principles

The reporting process ensures sustainability data that is:

• Balanced
• Comparable
• Accurate
• Reliable
• In line with CSRD mandatory requirements

Integration with Financial Reporting

Sustainability information is integrated with financial reporting to provide a comprehensive view of value creation, risks, and opportunities across environmental, social, and governance dimensions.

Transition plan for climate change mitigation

Scope and coverage

The Climate Transition Plan applies to the entire Proximus Group, including all affiliates. Currently, the implementation is focused on Telecommunication and Information and Communications Technology operations within Belgium and Luxembourg, which are the most material from a GHG emissions perspective (in 2024, Domestic activities accounted for 98% of the Group's GHG footprint). In the coming years, we will need to drive action across all entities of the Group, considering their specific challenges and contributions.

Target years for net zero / carbon neutrality

Proximus Group is committed to achieving net zero GHG emissions across our entire value chain by 2040, using 2020 as the baseline – ten years ahead of Belgium's 2050 target. This goal requires cutting at least 90% of our direct and indirect total emissions and using carbon removal technologies for the remaining emissions (less than 10%).

Scope 1, 2, 3 reduction milestones with baseline years

In 2024, due to a major GHG accounting methodology update, Proximus updated its Science Based Targets initiative (SBTi) near-term targets for 2030 using the cross-sectoral pathway to ensure alignment with the 1.5°C trajectory. The updated near-term targets are:

• Scope 1 and Scope 2: Reduce absolute GHG emissions by 66% in 2030 from a 2020 base year (previously -95%)
• Scope 3: Reduce absolute GHG emissions by 42% in 2030 from a 2020 base year (previously -60%)
• Continue active annual sourcing of 100% renewable electricity through 2030

These targets were validated by the SBTi in November 2024 and are fully consistent with the boundaries defined in Proximus' GHG inventory, applying to 100% of Scope 1, 2 and 3 emissions.

Proximus is still committed to reaching net-zero greenhouse gas emissions across its value chain by 2040 (long-term target: -90% vs. 2020).

Scope 1 & 2 trajectory

Scope 1 & 2 emissions reduction levers (kT CO2 vs. 2024):

Scope 3 trajectory

Based on current assumptions and estimations, Proximus anticipates a gap between projected emissions and 2030 ambitions (gap of 44 kT CO2e or 11%) and 2040 ambitions (gap of 107 kT CO2e or 26%), highlighting the need to explore additional strategies and emission reduction initiatives.

Alignment with 1.5°C / SBTi validation status

Proximus' updated targets are aligned with the 1.5°C pathway and were validated by the Science Based Targets initiative (SBTi) in November 2024. The targets are fully consistent with the boundaries defined in Proximus' GHG inventory, applying to 100% of Scope 1, 2 and 3 emissions.

Key levers / decarbonization pillars

Scope 1 & 2 reduction levers:

The reduction of Scope 1 & 2 emissions will be achieved through three main levers:

1. Removing fossil fuels from operations through fleet electrification and investments in building decarbonization
2. Increasing energy efficiency of networks and datacenters
3. Continuing to source 100% renewable energy in an impactful way

Fleet decarbonization:

• Fleet represents approximately 80% of Scope 1 emissions
• Since 2023, exclusively ordering electric vehicles (EVs) for Belgian management fleet (representing more than 85% of fleet emissions)
• In 2024, EVs in management fleet increased from 16% to 28%
• Providing employees with alternatives to company cars through comprehensive mobility packages, such as the federal mobility budget
• Gradually integrating EVs into light technical fleet (5% in 2024)
• Assessing potential options for heavy-duty vehicles

Buildings decarbonization:

• Buildings represent approximately 20% of Scope 1 emissions
• Streamlining network by replacing technical equipment buildings with highly compact and energy-efficient units
• Gradually replacing fossil heating systems with electrical heat pumps

Renewable electricity sourcing:

• Deploying solar panels to generate local electricity for administrative and technical buildings
• Power Purchase Agreement (PPA) with Engie (effective until 2028) contributing to securing approximately 20% of Proximus' green electricity
• Remaining 80% of electricity consumption covered through Energy Attribute Certificates (EACs)
• Developing the Proximus Energy Box in collaboration with Companion.energy to optimize renewable energy usage and costs

Energy efficiency:

• Network modernization: Building gigabit network with fiber (inherently more energy-efficient than copper)
• Smart Installed Base: Deploying more modern and energy-efficient technologies and phasing out older-generation technologies (e.g., phasing out copper network and legacy switching technologies)
• Network sharing: Sharing network infrastructure to reduce energy footprint and maximize network utilization
• Datacenters: Continuous improvements in operations (e.g., detecting abnormal power usage through advanced analytics) and introducing new technologies (e.g., Smart Power Distribution Units). Reduced power consumption by 2% in 2024 compared to 2023

Scope 3 reduction levers:

Four main levers align with core business activities:

1. Network transformation: Fiber network deployment has lower carbon emissions than legacy networks
2. Supply chain engagement: Active engagement with suppliers to set 1.5°C Science-aligned emission reduction targets. For Proximus SA 37% of its emissions result from aligned suppliers, whereas on a group level 30% of total emissions result from aligned suppliers
3. Circularity and business model evolution: Focus on extending product lifecycles, refurbishment, and circular economy practices
4. Internal and external engagement with main stakeholders

CapEx / investment commitments

In 2024, Proximus dedicated:

• EUR 14.5 million as operational expenditure (OpEx) on green mobility to support fleet decarbonization, supporting for example the leasing of electrical vehicles and public transport options for employees
• EUR 49.6 million in employee re-skilling and upskilling

While the plan is based on overall financial planning, Proximus does not yet have a detailed overview of the future CapEx and OpEx investments dedicated to the transition plan. Financial resources are not specified for each material topic and action plan. Only significant financial allocations that exceed EUR 10 million are reported.

Proximus' fiber and 5G networks roll-out represents a large part of CapEx plan which is staying consistent year over year.

Locked-in emissions and stranded asset analysis

Proximus' potential locked-in emissions are mainly linked to the electricity consumption of devices leased to clients. This park of devices is an asset powered by electricity from the local electricity grid. Therefore, Proximus is dependent on the grid's carbon intensity and the investments made by governments to switch to more renewable energy sources. While this component was factored into the decarbonization trajectory, Proximus will need to re-assess the evolution of the Belgian electricity grid in the coming years to accurately quantify the potential impact on the 2040 target.

Use of carbon credits / removals

Carbon removals: The net zero goal by 2040 requires cutting at least 90% of direct and indirect total emissions and using carbon removal technologies for the remaining emissions (less than 10%).

Carbon credits outside value chain:

For several years, Proximus Group has supported the multiannual "Gold Standard"-certified climate project called the TEG Stove project, which aims at carbon emission reduction through wood consumption reduction. 100% of the credits cancelled are due to reduction projects under the Gold Standard. It is estimated that the TEG Stove project will generate around 6,000 tCO2eq in 2025. The partnership with Proximus Group will not be continued beyond 2025.

Governance and review

The Climate Transition Plan was developed in line with the bold2025 strategy and reflects Proximus' current outlook on mid- and long-term investments and strategic priorities. The sustainability team led the development of this plan in collaboration with relevant internal stakeholders and the plan was subsequently approved by Proximus' Leadership Squad and Board of Directors.

In 2025, Proximus' three-year business strategy will be updated, which will provide an opportunity to further embed the Climate Transition Plan into the company DNA and business objectives.

Targets related to climate change mitigation and adaptation

Net Zero by 2040 Commitment

Proximus has committed to achieving net zero by 2040, representing a significant climate change mitigation target.

2024 Performance Against Climate Targets

Energy and Infrastructure Targets

Sustainable Financing: 32% of total financing comes from sustainable sources, supporting the transition to low-carbon operations.

Energy Consumption: Total energy consumption of 426,250 MWh, with ongoing initiatives to improve energy efficiency across network operations.

Network Infrastructure Climate Alignment

Fiber Network Deployment: The roll-out of energy-efficient fiber networks contributes to climate targets:

• 37% of Belgian premises connectable to fiber

• More than 42% "fiber in the street" coverage
• Target of 50% fiber coverage by end 2025

5G Network Efficiency: 5G technology deployment with higher energy efficiency:

• 67.6% indoor 5G coverage achieved
• Target of 100% 5G indoor coverage by 2025

Circular Economy Targets Supporting Climate Goals

Device Collection and Refurbishment:

• 935,378 refurbished fix devices (contributing to circular economy)
• 140,587 mobile devices collected for recycling
• Target: Truly circular by 2030

Climate Risk Management

The company addresses both physical and transition climate risks through its network infrastructure investments and operational efficiency improvements.

Physical Climate Risks: Network resilience investments protect against extreme weather events.

Transition Risks: Proactive adoption of energy-efficient technologies and renewable energy sourcing to manage carbon pricing and regulatory changes.

Energy consumption and mix

Total Energy Consumption

Proximus Group's total energy consumption in 2024: 426,250 MWh

Energy Efficiency Initiatives

Network Infrastructure Optimization:

• Deployment of energy-efficient fiber networks
• 5G technology implementation with improved energy performance
• Network equipment modernization with Nokia and Ericsson partnerships

Device Efficiency Improvements:

• New Android TV Box consuming 20% to 40% less electricity compared to predecessor
• Wi-Fi 6E technology implementation improving energy efficiency

Event Operations:

• 80% of temporary event sites powered by biofuels in 2024, demonstrating commitment to sustainable energy sources
• Over 725 TB of data traffic managed across 90+ events with sustainable energy solutions

Sustainable Energy Sourcing

Financing for Sustainable Energy: 32% of total financing comes from sustainable sources, supporting renewable energy investments and energy efficiency projects.

Energy Management in Operations

Data Centers and Network Operations:

• Ongoing optimization of energy consumption across network infrastructure
• Integration of energy efficiency considerations in network planning and deployment

Technology Innovation:

• Investment in next-generation technologies that deliver improved energy performance
• Partnerships with equipment vendors for energy-efficient solutions

Energy Consumption Impact

The energy consumption figure of 426,250 MWh represents the environmental input for Proximus Group's operations across Belgium and international markets, supporting:

• Network connectivity for 2.8+ million residential customers
• IT and telecom services for 450,000+ business customers
• Global digital communications services across 180+ countries

Gross Scopes 1, 2, 3 and Total GHG emissions

Total GHG Emissions

Proximus Group's total GHG emissions in 2024: 422,284 tons CO2 equivalent

Emissions Performance

Emissions Reduction Progress

Scope 1+2 Emissions: Achieved a 16% reduction year-over-year in direct and indirect emissions from energy consumption, exceeding the 2023 performance of 13% reduction.

Scope 3 Emissions: Maintained relatively stable Scope 3 emissions with only a 0.5% increase, significantly improved from the 1% increase in 2023.

Net Zero Target Alignment

The emissions performance demonstrates progress toward Proximus' net zero by 2040 commitment:

• Strong reduction in direct operational emissions (Scope 1+2)
• Controlled growth in value chain emissions (Scope 3)
• Overall emissions trajectory aligned with science-based targets

Emissions Sources

Key sources of emissions across the Group include:

• Energy consumption: 426,250 MWh total energy use
• Network operations: Data centers, base stations, and network infrastructure
• Value chain activities: Supplier operations, device manufacturing, business travel
• International operations: Global presence across 180+ countries

Mitigation Measures

Direct Emissions Reduction:

• Energy efficiency improvements in network infrastructure
• Sustainable energy sourcing (32% sustainable financing)
• Equipment modernization and optimization

Value Chain Emissions Management:

• Supplier engagement programs with top 150 suppliers
• Circular economy initiatives (935,378 refurbished devices)
• Sustainable procurement practices

Verification and Reporting

GHG emissions data has been independently verified by Deloitte as part of the CSRD compliance process.

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

Phase-in Provision

Proximus is using the phase-in provision for ESRS E1-9 and will report on anticipated financial effects from material physical and transition risks and potential climate-related opportunities in 2025.

The following disclosure requirements are subject to the phase-in provision:

• E1-9_01-11: Phase-in provision is used and will be reported on in 2025
• E1-9_12-13: Disclosure not mandatory
• E1-9_14-23: Phase-in provision is used and will be reported on in 2025
• E1-9_24-28: Disclosure not mandatory
• E1-9_29-35: Phase-in provision is used and will be reported on in 2025
• E1-9_36-38: Disclosure not mandatory
• E1-9_39-44: Phase-in provision is used and will be reported on in 2025

Cross-reference to regulatory requirements

Certain aspects of E1-9 are subject to additional regulatory requirements:

• E1-9_01-04 (BENCHMARK): Phase-in provision is used and will be reported on in 2025
• E1-9_05 (PILLAR 3): Phase-in provision is used and will be reported on in 2025
• E1-9_17 (PILLAR 3): Phase-in provision is used and will be reported on in 2025
• E1-9_41-44 (BENCHMARK): Phase-in provision is used and will be reported on in 2025

Water consumption

Proximus has stated that impact on water is not deemed material in their Double Materiality Assessment. The explanation provided is that the company does not use water as a cooling method for its datacenters. However, Proximus continues to focus on reducing water consumption.

No quantitative water consumption metrics (total consumption, withdrawal, discharge, water stress areas, intensity, or recycling/reuse) have been disclosed in the sustainability statement for 2024.

Targets related to resource use and circular economy

Truly Circular by 2030

Proximus has committed to becoming "Truly circular by 2030", representing the company's comprehensive circular economy target.

2024 Performance Against Circular Economy Targets

Device Lifecycle Management

Collection and Refurbishment Programs:

• Significant increase in device refurbishment: +17% growth to 935,378 refurbished fix devices
• Enhanced mobile device collection: +10% growth to 140,587 mobile devices collected for recycling
• Over 1 million collected mobile phones and refurbished fix devices in total

Product Design for Circularity

New Android TV Box Design:

• 20% less plastic used compared to predecessor
• 20% to 40% less electricity consumption
• Demonstrates design for resource efficiency and energy optimization

Waste Management

Total Waste Generated: 5,873 tons of waste across Group operations

Waste Reduction Initiatives:

• Focus on extending device lifecycles through refurbishment
• Recycling programs for end-of-life equipment
• Circular design principles in new product development

Resource Efficiency in Operations

Energy Optimization:

• 426,250 MWh energy consumption with ongoing efficiency improvements
• Network infrastructure designed for longevity and upgradability
• Sustainable financing (32% of total) supporting circular economy investments

Supply Chain Circularity

Supplier Engagement:

• 3,200 active suppliers across 52 countries
• Supplier engagement programs focusing on circular economy practices
• Supplier Code of Conduct including sustainability requirements

Circular Business Models

Service-Based Models:

• Device leasing and return programs
• Network infrastructure sharing through partnerships (MWingz)
• Open network access enabling resource optimization across industry

Progress Monitoring

The circular economy targets are integrated into Proximus' bold2025 strategy and tracked as key performance indicators at Board level, with regular progress reporting to stakeholders.

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

Phase-in provision

Phase-in provision is used and will be reported on in 2025.

Financial resources allocated to circular economy

Out of a total invested capital expenditure (CapEx) of EUR 1.36 billion, Proximus invested 5% (EUR 67.5 million) in the circular economy (defined as the purchase of modems, decoders and repeaters, which are bought by Proximus Group and put on the market as a service through a renting model). The circular economy CapEx is fully reported under "Activity 5.5 Product-as-a-service and other circular use- and result-oriented service models".

Characteristics of the undertaking's employees

Total Workforce

Proximus Group employs 13,862 employees globally as of end 2024.

Employment Stability

Permanent Contracts: 98.9% of employees have permanent contracts, demonstrating strong employment security and stability.

Leadership Squad Composition

The Leadership Squad consists of 9 members (including CEO) with the following characteristics:

Leadership Squad Diversity

Gender Distribution:

• 22% women in Leadership Squad
• 78% men in Leadership Squad

Nationality Distribution:

• 56% Belgian
• 22% French
• 11% Italian
• 11% Scottish

Management Diversity

Women in Top Management Functions: 25% of top management positions are held by women, showing progress in gender diversity at senior levels.

Employee Engagement

Engagement Score: 76% employee engagement, close to the target of >75% by 2025.

Turnover Rate: 10% turnover rate, indicating strong employee retention.

Skills Development

Training Participation: 82% of employees attended 5 or more training days per year, significantly exceeding the 2023 level of 63% and approaching the 2025 target of 95%.

Training Investment: EUR 49.56 million invested in training and development programs.

Geographic Presence

Proximus operates across multiple countries with employees supporting:

• Domestic operations in Belgium, Netherlands, and Luxembourg
• International operations across 180+ countries through BICS, Telesign, and Route Mobile

Workforce Value Creation

The diverse workforce contributes to:

• Serving 2.8+ million residential customers
• Supporting 450,000+ business customers
• Operating global digital communications services
• Driving innovation in 5G, AI, and cybersecurity

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

Disclosure approach

Proximus has defined non-employees as "contractors hired by Proximus Group to perform work in a public area or within our own operations: contractors can be self-employed, or employees provided by a third party primarily engaged by the Group".

Under the ESRS S1-7 index table, Proximus has indicated that the phase-in provision is used and will be reported on in 2025. Therefore, quantitative metrics on the number, breakdown by type, and characteristics of non-employee workers are not disclosed in this 2024 reporting cycle.

Qualitative references

The report contains qualitative references to non-employees in several contexts:

• The new organization model for SME customers mentions serving "self-employed individuals" as a customer segment, but this refers to customers rather than Proximus's own workforce
• The CEO has a contract as a self-employed executive since December 2019
• Remuneration policy distinguishes between employees and "self-employed employees"
• Health and safety management includes annual information sessions for "subcontractors (non-employees)" about inherent risks and safety rules
• The Human Rights Policy and Supplier Code of Conduct apply to "all workers within our value chain" including subcontractors
• The organization works with "contractors, and business partners" who must be kept informed about policies

However, no aggregated headcount, FTE data, or categorical breakdowns (contractor vs. agency vs. self-employed) of non-employee workers in the own workforce are provided for the reporting year 2024.

Collective bargaining coverage and social dialogue

Context and strategic objectives

Proximus Group respects and upholds employees' working rights, including the right to collective bargaining, freedom of association, the existence of works councils and the workers' rights to information, consultation and participation. The Group aims to involve social partners in strategic decisions and changes that affect the organization and employees.

In Belgium, a majority of employees are covered by collective bargaining agreements.

Proximus has not yet established specific Group objectives or targets.

Policies

Collective bargaining agreements

In Belgium, Proximus has its own Joint Committee (JC), the official consultative body bringing together Proximus and union representatives, chaired by the Chairman of the Board of Directors. It consists of 18 members: nine management representatives and nine union representatives. They meet ten times a year. Before consultation in the JC, a preliminary debate is held in one of three permanent workgroups: social negotiations, well-being at work and social benefits.

Working conditions, including remuneration, are continuously discussed with employees' representatives. The representative unions submit a joint list of demands to the Joint Committee every two years, which serves as a foundation for negotiating a new Collective Agreement. The last Collective Agreement 2023-2024 was unanimously approved by union representatives in February 2023.

Other Domestic affiliates and BICS Belgium operations follow similar processes. They are not subjected to the same law, but they are covered by social dialogue and a collective labor agreement at sector level according to their respective joint committee. Certain affiliates also have social bodies and collective labor agreements at company level.

Examples from affiliates:

• Telesign's Employee Ambassador Council is a group of employee leaders who provide feedback and support the company's employer brand narrative. This council was particularly important during the announcement of the merger of Telesign with Route Mobile where they gathered insights and helped communicate updates to employees.

• In Proximus NXT IT, part of joint committee 200 in the private sector, there is active ongoing dialogue within three representative labor organs (work councils, committee for prevention and protection, union delegation). Representation was ensured for transferred colleagues from Proximus NV in July 2024.

Performance

Collective bargaining coverage

Scope: Proximus operations within the European Economic Area (EEA)

Country breakdown - Collective bargaining coverage and social dialogue

Scope: Proximus operations within the European Economic Area (EEA)

Definitions and accounting policies

The rate of employees covered by collective bargaining agreements has been calculated based on the fact that when a Collective Agreement is signed, it covers all employees working for the Proximus entity (except the executives and the senior management). The Group figure is calculated for all countries within the European Economic Area.

The social dialogue rate has been calculated based on the total number of employees working in the main headquarters with employees' representatives of the countries where Proximus has more than 50 employees: Belgium, the Netherlands and Luxembourg.

Proximus Group operates in the following countries within the European Economic Area (EEA): Belgium, the Netherlands and Luxembourg. Outside the EEA, only the following countries have more than 50 employees: USA, Serbia, India and Columbia. The countries listed are the ones where Proximus has more than 50 employees.

Social dialogue activities

Within Proximus Domestic operations and BICS Belgium operations, social dialogue is organized in accordance with legal requirements through Prevention Committees or direct employee consultations. The Prevention Committees primarily serve an advisory role to the employer. Participants in this social dialogue include the employer (or their representative), labor unions, GPP and occupational physicians.

Within Belgium, through a five-year global prevention action plan and a yearly action plan, topics such as occupational accidents, safety risk analyses, local prevention matters and psychosocial risks are discussed.

The action plan related to social dialogue within affiliates is managed locally and varies from country to country depending on local regulations. Co-determination matters are managed locally and always together with trade unions and employees' representatives. Group management is generally involved in all major issues.

Diversity metrics

Board of Directors Diversity

The Board of Directors demonstrates strong diversity across multiple dimensions:

Gender Diversity:

• 50% women (7 female directors)
• 50% men (7 male directors)

Proximus is proud to have achieved gender parity within its Board of Directors, creating a dynamic that benefits the company's management.

Nationality Diversity:

• 86% Belgian (12 directors)
• 7% French (1 director)
• 7% German (1 director)

Leadership Squad Diversity

Gender Distribution:

• 22% women (2 female members)
• 78% men (7 male members)

Nationality Distribution:

• 56% Belgian (5 members)
• 22% French (2 members)
• 11% Italian (1 member)
• 11% Scottish (1 member)

Top Management Gender Representation

Women in Top Management Functions: 25% of top management positions are held by women in 2024, showing improvement from 24% in 2023.

Target: Proximus aims to increase the percentage of women in top management functions as part of its diversity and inclusion commitment.

Board Competences and Skills Diversity

The Board members bring complementary expertise across:

• Telecom and media
• Digital transformation and digital inclusion
• Innovation and technology
• National security and cybersecurity
• Finance, audit and risk
• Regulatory and legal expertise
• Governance and human rights
• Sales and marketing
• Human capital
• Operations and supply chain
• Climate change and energy
• International experience
• Executive management experience

Age Diversity

Board members range in age from 39 to 73 years, with Leadership Squad members ranging from 49 to 62 years, providing a mix of experience levels and perspectives.

Diversity Strategy Impact

The diversity characteristics create enhanced decision-making capabilities and support Proximus' strategy of:

• Building inclusive digital solutions
• Serving diverse customer segments
• Operating across multiple international markets
• Fostering innovation and transformation

Adequate wages

Benchmark and methodology

Proximus states that "all employees are paid adequate wages in line with applicable benchmarks, local regulations and market conditions."

The company explains its methodology as follows:

"At Proximus Group, in general, we base ourselves on the minimum of our salary bands, as these reflect the minimum salary that one should get for a particular grade. These bands are based on benchmarks, legislation and collective bargaining. For entities where a job function classification system is not in place, we rely on market practices while ensuring the minimum wage in the country."

Coverage

The disclosure applies to Proximus Group (all employees), but no specific percentage or number of employees assessed is provided.

Geographic scope

The policy applies across Proximus Group operations. The document notes that "a majority of our employees" in Belgium are covered by collective bargaining agreements, and references operations in Belgium, the Netherlands, and Luxembourg (countries with more than 50 employees).

Targets and commitments

No specific targets or forward-looking commitments related to adequate wages are disclosed. The company states: "We have not yet established specific Group objectives or targets."

Value chain

No information on extending adequate wage assessments to the value chain (suppliers, contractors) is provided.

Social protection

Proximus has invoked the phase-in provision for ESRS S1-11. Full disclosure of social protection coverage metrics will be reported in 2025.

Leadership Squad Coverage (Belgium)

For the CEO and Leadership Squad members in Belgium, the following social protection arrangements are in place:

Life Insurance:

• Beneficiaries receive a gross capital lump sum equal to monthly fixed salary × 60 in the event of death during contract term

Disability Coverage:

• Work incapacity due to illness or private accident: 100% professional income guaranteed for first 3 months
• From month 4 onwards: disability insurance covers disability annuity payment on top of legal sickness-disability insurance ceiling provided by Belgian social security

Group Insurance Premiums (2024):

• CEO: Average premiums estimated at 9% of fixed remuneration
• Other Leadership Squad members: Average premiums approximately 25% of fixed remuneration

Group Insurance Premiums Over 5 Years (kEUR, before employer's taxes)

Other Social Protection Benefits

The CEO and Leadership Squad members receive additional benefits including:

• Medical insurance
• Company car use
• Welfare benefits
• Other benefits in kind

For 2024, the ratio of these benefits versus fixed remuneration is estimated at 13% for the CEO and 18% for other Leadership Squad members.

Broader Workforce Provisions

Belgium-specific programs:

• Employee Assistance Program (EAP) providing professional support for personal and work-related problems through network of psychologists
• Support network through external partner (Oh My People) for people on long-term sick leave due to stress-related problems
• Interactive Stress Assessment Tool (ISAT) available on intranet

Flexible work arrangements (varying by affiliate based on local legislation):

• Parental leave options
• Part-time schedules
• Home working flexibility

Specific working conditions and social protection arrangements vary across affiliates depending on local legislation. The action plan related to social dialogue within affiliates is managed locally and varies from country to country depending on local regulations.

Persons with disabilities

Proximus uses the phase-in provision for ESRS S1-12 and will report on persons with disabilities metrics in 2025.

Current disclosure status

According to the ESRS index:

• S1-12_01: Phase-in provision is used and will be reported on in 2025
• S1-12_02: Disclosure not mandatory
• S1-12_03: Phase-in provision is used and will be reported on in 2025

Related initiatives

Proximus collaborates with Passe Muraille, an association active in the inclusion of persons with disabilities, to test the accessibility of new smartphones and tablets for people with disabilities. In 2024, 23 devices have been tested.

Every year, Proximus launches on average 25 new models of smartphones in Belgium with the ambition to test the accessibility of all of them regarding five categories of disability (motor, visual, blind, auditory, deaf, mental). In 2024, 95% of all new smartphones have been tested, and 57% have been recognized as accessible.

Training and skills development metrics

Training Participation

2024 Performance: 82% of employees attended 5 or more training days per year

Performance Trend:

• 2024: 82%
• 2023: 63%
• Target by 2025: 95%

This represents significant improvement, with Proximus well on track to achieve its 2025 target.

Training Investment

Total Investment: EUR 49.56 million invested in training and development programs in 2024.

Skills Development Strategy

Proximus is actively investing in reskilling and upskilling programs, which is crucial for:

• Achieving sustainable employment
• Creating jobs that are durable and future-proof
• Maintaining market leadership through innovation and agility
• Keeping employees' capacities up to date with industry evolution

Financial Reporting Training

Specific mandatory training cycles established for financial reporting, covering:

• IFRS (International Financial Reporting Standards)
• Local accounting rules and regulations
• Tax and Company law & regulations
• Revenue assurance
• Pension administration
• Financial products

Specialized Training Programs

Code of Conduct Training: All Proximus employees must follow mandatory training on the application of the principles of the Code of Conduct.

Cybersecurity Training: Proximus Ada experts organize information sessions on cybersecurity threats and trends, including simulation exercises to assess and improve the company's ability to respond to cyberattacks.

AI and Digital Skills: With the rapid adoption of Generative AI and digital transformation, Proximus provides specialized training to prepare employees for future technology challenges.

Transformation Focus

As the company transforms into an international group, training programs focus on:

• Creating a unified corporate culture across Belgian and international operations
• Developing skills for global market operations
• Building capabilities in emerging technologies like AI and cybersecurity
• Preparing the workforce for digital ecosystem enablement

Performance Management Integration

Training and development metrics are integrated into leadership performance targets, with the Nomination & Remuneration Committee determining Key Performance Indicators for the CEO and Leadership Squad that include employee development objectives.

Health and safety metrics

Proximus Belgium operations

Scope: Proximus Belgium operations

Definitions: Work-related accidents are defined as occupational accidents which happen during the execution of work for the employer. Accidents that happen on the way to and from work are not included in this definition. The frequency rate of occupational accidents is calculated by multiplying the number of accidents with at least one day of absence by 1.10⁶, then dividing by the total number of worked hours by the employees based in Belgium.

Proximus Group

Scope: Proximus Group

Scope: Proximus Group

Definitions: Health & Safety management systems applied within our affiliates must be based on local legal requirements. The processes and procedures for risk assessment, evaluation and control vary from one country to another, as the legal requirements for each are different.

Work-related accidents are defined as occupational accidents which happen during the execution of work for the employer. Accidents that happen on the way to and from work are not included in this definition. The employees' work-related accident rate represents the number of respective cases per one million hours worked. Estimations of the working hours and related accident with respect to our international activities are based on the actual accidents and actual working hours in our domestic operations, which constitute 70% of the group's activities.

Fatalities

Proximus offers a health and safety management system, covering all employees based in Belgium, that complies with legal requirements and recognized standards, including the Well-being Act and VCA system. In 2024, no fatalities have been reported (Belgium operations).

In 2024, no fatalities resulting from work-related injuries and work-related ill health have been reported through current channels by any employees or any value chain workers working on Proximus premises (Group level).

Coverage and data quality notes

The data related to health and safety metrics are provided with a level of measurement uncertainty. The source of measurement uncertainty can be explained by differences between local regulations, measurement techniques and the availability of data. Proximus is working on aligning internal reporting processes at the Group level in the upcoming two to three years.

Work-life balance metrics

Disclosure status

Proximus has applied the phase-in provision for ESRS S1-15 (Work-life balance metrics). According to the ESRS index in the annexes:

S1-15_01-04: Phase-in provision is used and will be reported on in 2025.

Policy context

Proximus provides various family-related leave and flexible working arrangements as described in the Working rights, fair pay and social dialogue section:

Belgium-specific programs (from page 158):

• Internal mobility and development opportunities
• Working from home arrangements (varying from full flexibility to full office days depending on affiliate)
• Flexible work arrangements: part-time schedules and parental leave options available to accommodate diverse needs of employees
• The specific working conditions vary across affiliates depending on local legislation

Additional support for experienced talents (55+):

• Experience@Work career opportunities
• Personal development support
• Sustainable employability resources

Parental leave provisions (noted in SDG contribution table, page 449):

• Parental leave offered
• Home working and part-time schedules available
• Sick childcare support
• Childcare cost intervention
• Transition allowance, scholarship
• Children's holidays offer, kids' days
• Support from social consultants in case of difficult personal situations

Quantitative metrics

No quantitative metrics are disclosed for:

• % of employees entitled to family-related leave (by type: maternity/paternity/parental/family care)
• % of entitled employees who took family-related leave (split by gender)
• Return-to-work rate after parental leave (split by gender)

These metrics will be reported in 2025 following the phase-in approach.

Incidents, complaints and severe human rights impacts

Complaints and severe human rights impacts

There were no cases of severe human rights incidents related to Proximus' workforce reported through the existing channels in 2024. This means that there were no reports of forced labor, human trafficking and child labor. Neither were there any violations of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises.

To date, Proximus Group has not received any fines or penalties related to severe human rights incidents.

Scope: Proximus Group

This complaint concerns a court case started in 2021. The procedure is on-going.

Definitions and accounting policies: Employees have various internal channels through which they are encouraged to report suspected violations or concerns. These include management, Human Resources, the Group Department for Prevention and Protection, the Data Protection Officer and the Group Ethics and Compliance officer. The employees' complaints related to social and human rights are consolidated based on the Group 2024 sustainability reporting process. This is based on the current process and procedures implemented. We are currently working on aligning our internal governance and reporting processes within the two to three next years.

Discrimination and harassment

To date, Proximus Group has not received any fines or penalties related to discrimination and harassment cases.

This is based on the current process and procedures implemented. The source of measurement uncertainty can be explained by the differences between local regulations. We are working on aligning our internal reporting processes at Group level in the upcoming two to three years.

Scope: Proximus Group

Definitions and accounting policies: Employees have various internal channels through which they are encouraged to report incidents of discrimination. These include management, Human Resources and the Group Department for Prevention and Protection. The Group Department for Prevention and Protection is responsible for all complaints related to violence at work, moral or sexual harassment and discrimination.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Digital Inclusion Commitment

2024 Performance: 15,138 people trained through digital inclusion projects

Performance Trend:

• 2024: 15,138 people
• 2023: 15,515 people
• Target: Contribute to digital inclusion in Belgium

Community Impact Programs

Secure Public Digital Spaces Project: Proximus Ada cybersecurity experts offer skills and expertise free of charge to:

• Brussels Digital Public Spaces (DPS)
• Community associations
• Support for vulnerable and least digitally equipped citizens
• Impact: Nearly 20 DPS and associations have benefited from services
• Training: Around 200 people attended cybersecurity information sessions

AI Awareness Programs: Proximus Ada data scientists conduct AI awareness sessions for:

• Students in secondary schools
• Educational visits during "Digital Spring 2024" event

Accessibility and Inclusion

Platform Accessibility: Proximus works on improving the accessibility of its platforms and content to ensure digital services are available to all community members.

Multi-brand Strategy: Addressing different community segments through:

• Scarlet: "No-frills" brand making quality connectivity affordable for all
• Proximus: Premium services for full digital experience
• Mobile Vikings: Digital-native solutions for tech-savvy users

Infrastructure Development Impact

Gigabit Network Deployment:

• >37% of Belgian premises connectable to fiber
• >42% "fiber in the street" coverage
• 67.6% 5G indoor coverage
• Target: 100% of Belgian households and businesses to have access to gigabit connectivity

Trust and Security for Communities

Fraud Prevention: Protecting communities through:

• >666 million fraudulent call attempts blocked
• >127 million phishing messages prevented
• 30+ million fraudulent transactions blocked monthly

Cybersecurity Services: Building trust in digital society through comprehensive cybersecurity solutions for businesses and individuals.

Economic Development Impact

Job Creation: As a major economic player with 13,862 employees, Proximus contributes to:

• Employment in Belgium and internationally
• Skills development and training (82% of employees attended ≥5 training days)
• Economic growth through digital infrastructure investments

Innovation Ecosystem Support

5G Innovation Hubs: Partnerships with universities and research institutions to develop innovative solutions for communities:

• Healthcare applications (H.E.A.L.T.H. project at AZ Groeninge)
• Smart mobility solutions (Be-Mobile)
• Environmental monitoring (Groove project)

Long-term Community Value

Proximus' investments in digital infrastructure create long-term value for affected communities by:

• Enabling digital transformation of local businesses
• Supporting remote work and education capabilities
• Facilitating access to digital services and opportunities
• Building resilient and connected communities

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Customer Experience Excellence Targets

Net Promoter Score (NPS) Leadership: Proximus targets being number 1 in NPS in respective segments.

2024 Performance:

All brands showed improved NPS scores, demonstrating progress toward market leadership in customer satisfaction.

Digital Accessibility and Inclusion

Platform Accessibility: Proximus works on improving the accessibility of its platforms and content to ensure digital services are available to all consumers, including those with disabilities.

Affordable Access: Through Scarlet brand, providing "no-frills" solutions that make quality home and mobile connectivity affordable for all consumers.

Service Quality and Reliability

Network Leadership:

• Fastest Internet in Belgium: Proximus fiber recognized by Ookla as delivering the fastest Internet speeds
• 5G Performance: Recognized by OpenSignal as leader in 5G download speeds
• Coverage Excellence: Best 4G and 5G coverage according to BIPT testing

Consumer Protection and Trust

Fraud Prevention for Consumers:

• Call Shield: Blocking more than 200,000 fraudulent international voice calls monthly
• Anti-phishing: AI-based solution preventing 15 million malicious messages per month from reaching customers
• SMS Protection: Comprehensive fraud detection across communication channels

Digital Services Innovation

Proximus+ App: Comprehensive digital services platform offering:

• Service management for existing customers
• Digital services for energy consumption, mobility, activities, and budgeting
• Cashback features
• Available to both customers and non-customers

Doktr Health Services:

• 125,000+ registered users
• 95% patient satisfaction rate
• Video consultations with healthcare professionals and psychologists

Customer Service Excellence

Multi-channel Support:

• Premium servicing combining digital capabilities with human touch
• 24/7 digital assistant availability
• 121 physical shops across Belgium
• Specialized support for different customer segments

Service Quality Metrics:

• Customer Effort Score (CES): "Excellent" rating for DIY installations
• Continuous improvement in digital tools performance and stability

Connectivity Infrastructure Benefits

Fiber Connectivity Targets:

• >1 million fiber connections target for residential and business customers
• 564,000 fiber connections achieved by end 2024 (vs 397,000 in 2023)
• Ultra-stable Internet with download speeds up to 8.5 Gbps

Innovation for Consumer Benefit

5G Applications: Development of innovative 5G use cases benefiting consumers:

• Enhanced mobile experience with faster speeds and lower latency
• Support for new applications and ways of working
• Improved customer satisfaction among 5G users

Long-term Value Creation

Proximus' consumer strategy focuses on long-term value creation through:

• Superior network infrastructure investments
• Continuous innovation in digital services
• Comprehensive customer protection against fraud
• Accessible and inclusive service offerings

Business conduct policies and corporate culture

Code of Conduct

Proximus has adopted a Code of Conduct applicable to all employees. The Code contains guiding principles that inform employees and stakeholders and guide daily behaviors.

Mandatory Training: Proximus employees must follow mandatory training on the application of the principles of the Code of Conduct.

Additional Policies: On top of the Code of Conduct, Proximus has various internal policies to ensure employees act ethically.

Think Possible Culture

Proximus promotes its Think Possible culture as key to realize its strategy:

• Mindset: Think possible is first and foremost a mindset that makes us see opportunities everywhere
• Principles and Behaviors: It is also a set of principles and behaviors that guide us in finding the best solutions for customers
• International Integration: As the company transforms into an international group, it aims to create a new corporate culture that unites employees in Belgium with their international counterparts

Ethics and Governance Framework

Board of Directors Oversight: The Board of Directors follows the law and ensures every collaborator is aware of the behaviors to follow and to avoid.

Compliance Monitoring: The Audit & Compliance Committee ensures compliance with:

• Company's Code of Conduct
• Dealing Code
• Other key policies

Conflict of Interest Management

General Policy: A general policy on conflicts of interest prohibits the possession of financial interests that may affect personal judgment or professional tasks to the detriment of Proximus Group.

Related Party Transactions Policy: Adopted in 2011 and updated in 2016, this policy governs all transactions or other contractual relationships between the company and its Board members.

Disclosure Requirements: Board and each individual director must respect all rules relating to conflicts of interest. Any conflicts are reported and published in the annual report.

Corporate Governance Compliance

Belgian Corporate Governance Code: Proximus follows the Belgian Corporate Governance Code of 2020, with explicit mention of any deviations. Only two deviations are noted (provisions 7.6 and 7.9) related to remuneration, where Proximus opted not to introduce share-related remuneration due to the Belgian State being the majority shareholder.

Legal Framework: Proximus operates under:

• Law of 21 March 1991 on autonomous economic public companies
• Belgian Code of Companies and Associations
• Belgian Corporate Governance Code of 2020

Risk Management and Internal Controls

Internal Control System: Characterized by:

• Clear definition of responsibilities
• Sufficient resources and expertise
• Appropriate information systems, procedures, and practices
• Continuous review and follow-up of all components

Board Oversight: The Board of Directors is responsible for assessment of systems for internal control and risk management.

Transparency and Accountability

Relationship Agreement: Concluded with majority shareholder (Belgian State/SFPIM) to create framework for information exchange while maintaining company autonomy.

Public Reporting: Comprehensive integrated annual report providing transparency on strategy, performance, governance, and sustainability.

Values Integration

Business conduct policies are integrated with Proximus' purpose: "Boldly building a connected world that people trust, so society blooms" and its nine ESG commitments, ensuring ethical behavior supports the company's broader societal goals.

Management of relationships with suppliers

Supplier Partnership Approach

Proximus views suppliers as key partners in realizing its vision, mission and strategy. The Procurement department manages relationships with 3,200 suppliers across 52 countries.

Supplier Code of Conduct

Universal Application: Supplier Code of Conduct included in all contracts to ensure adherence to ethical standards and sustainability requirements.

Compliance Framework: The Supplier Code of Conduct establishes standards for:

• Ethical business practices
• Environmental responsibility
• Social compliance
• Governance standards

Supplier Engagement Program

Top Supplier Focus: Supplier Engagement Program with our top 150 suppliers, focusing on:

• Sustainability performance
• CO2 emission reduction
• Compliance with code requirements
• Continuous improvement initiatives

Supplier Performance Monitoring

Key Performance Indicators:

• Supplier engagement in CO2 emission reduction
• Adherence to Supplier Code of Conduct closely monitored
• Regular assessment of supplier sustainability practices

Strategic Supplier Relationships

Technology Partners:

• Nokia: Partnership for Mobile Radio Access Network (RAN) equipment upgrades
• Ericsson: Partnership for Mobile Data Core Network upgrades and modernization
• Microsoft: Five-year strategic partnership for cloud transformation and AI innovations
• Infosys: Five-year partnership for digital transformation and solution development

Network Infrastructure Partners:

• Equipment vendors for fiber and 5G network deployment
• Partners for network sharing initiatives (MWingz joint venture)
• Infrastructure providers for datacenter and cloud services

Procurement Practices

Global Sourcing: Managing supplier relationships across 52 countries to support:

• Domestic operations in Belgium, Netherlands, Luxembourg
• International operations across 180+ countries
• Diverse product and service requirements

Risk Management: Supplier relationship management includes:

• Due diligence processes
• Risk assessment and mitigation
• Business continuity planning
• Performance monitoring and evaluation

Innovation Partnerships

Collaborative Development: Working with suppliers on:

• Next-generation technology solutions
• Energy-efficient equipment and processes
• Sustainable product design and lifecycle management
• Innovation in 5G, AI, and cybersecurity solutions

Sustainability Integration

Environmental Focus: Supplier engagement includes:

• Carbon footprint reduction targets
• Circular economy practices
• Sustainable sourcing requirements
• Environmental impact monitoring

Social Responsibility: Ensuring suppliers maintain:

• Fair labor practices
• Human rights compliance
• Diversity and inclusion standards
• Community impact considerations

Contract Management

Comprehensive Framework: All supplier contracts include:

• Code of Conduct requirements
• Sustainability clauses
• Performance standards
• Compliance monitoring provisions
• Continuous improvement expectations

Prevention and detection of corruption and bribery

Code of Conduct Framework

Proximus has adopted a comprehensive Code of Conduct applicable to all employees, which includes principles for preventing corruption and bribery.

Mandatory Training: All Proximus employees must follow mandatory training on the application of the principles of the Code of Conduct, including anti-corruption measures.

Compliance Oversight

Audit & Compliance Committee: The Audit & Compliance Committee ensures compliance with:

• Company's Code of Conduct
• Internal compliance policies
• Legal and regulatory requirements related to anti-corruption

Board Oversight: The Board of Directors provides oversight of compliance with ethical standards and anti-corruption measures.

Internal Control Systems

Risk Management: Proximus maintains internal control and risk management systems that include:

• Clear definition of responsibilities
• Appropriate information systems and procedures
• Continuous review and follow-up of compliance measures
• Regular assessment of corruption and bribery risks

Conflict of Interest Management

General Policy: A general policy on conflicts of interest prohibits:

• Possession of financial interests that may affect personal judgment
• Activities that could compromise professional tasks to the detriment of Proximus Group

Related Party Transactions: The Board adopted a "related party transactions policy" that governs all transactions between the company and its Board members, helping prevent potential corruption.

Supplier and Partner Standards

Supplier Code of Conduct: Included in all contracts, the Supplier Code of Conduct establishes anti-corruption standards for all suppliers and business partners.

Due Diligence: Regular monitoring of supplier compliance with ethical standards, including anti-corruption measures.

Training and Awareness

Employee Education: Beyond mandatory Code of Conduct training, Proximus provides ongoing education on:

• Ethical business practices
• Recognition of corruption and bribery risks
• Proper procedures for reporting concerns
• Compliance with internal policies

Governance Framework

Belgian Corporate Governance Compliance: Proximus follows the Belgian Corporate Governance Code of 2020, which includes standards for ethical conduct and transparency.

Legal Compliance: Operating under Belgian law and EU regulations, including compliance with:

• Anti-corruption legislation
• Financial regulations
• Corporate governance standards

Reporting and Investigation

Internal Audit: Proximus' Internal Audit department conducts regular audits across Group operations, including assessment of compliance and ethical standards.

Transparency: Any conflicts of interest or compliance issues are reported and published in the annual report, ensuring transparency and accountability.

International Standards

Global Operations: With operations across 180+ countries, Proximus maintains consistent anti-corruption standards across all jurisdictions, adapting to local legal requirements while maintaining Group-wide ethical standards.

Incidents of corruption or bribery

Conflict of Interest Disclosures

In accordance with Belgian Corporate Governance requirements, the following conflict of interest situations were formally declared during 2024:

CEO Conflict of Interest - Performance Evaluation: In accordance with article 7:96 of the Belgian Code of Companies and Associations, CEO Guillaume Boutin declared during the Board of Directors meeting of 22 February 2024 to have a conflict of interest in connection with his performance evaluation for 2023, which was an item on the agenda of that Board meeting.

CEO Conflict of Interest - Contract Renewal: In accordance with article 7:96 of the Code of Companies and Associations, CEO Guillaume Boutin informed the Board of Directors on 25 July 2024 to have a conflict of interest in connection with the renewal of his contract and remuneration package, which was an item on the agenda of that Board meeting.

Related Party Transactions

Board Member Business Relations: Proximus has contractual relationships and provides telephony, Internet, digital and/or ICT services to many of the companies in which Board members have an executive or non-executive mandate. These transactions take place in the ordinary course of business and at arm's length.

Compliance Framework

Policy Implementation: The Board maintains a "related party transactions policy" adopted in 2011 and updated in 2016, which governs all transactions or contractual relationships between the company and its Board members.

Transparency Requirements: All conflicts of interest are formally reported in Board meetings and published in the annual report, ensuring full transparency and accountability.

No Corruption or Bribery Incidents Reported

Based on the information provided in the annual report, no incidents of corruption or bribery beyond the declared conflicts of interest were reported for 2024.

Governance Safeguards

Board Oversight: The Board of Directors and each individual director must respect all rules relating to conflicts of interest between the company and directors.

Audit & Compliance Committee: Ongoing monitoring of compliance with the Code of Conduct and internal policies helps detect and prevent corruption or bribery incidents.

Internal Controls: Comprehensive internal control and risk management systems provide safeguards against corruption and ensure proper governance.

Procedural Compliance

Belgian Legal Framework: All conflict of interest declarations follow article 7:96 of the Belgian Code of Companies and Associations, ensuring compliance with Belgian corporate law.

Publication Requirements: Conflicts of interest and related matters are published in the annual report as required by Belgian corporate governance standards.

Payment practices

Policy and Context

As imposed by Belgian law, Proximus Group has a maximum 60-day payment term for new contracts or contract extensions. Proximus standard contractual payment terms differ depending on contract types. On average, Proximus Group pays its suppliers within 61 days. 69% of our payments are aligned with standard payment terms. For the energy invoices of Proximus SA, we have a mechanism of factoring, where the standard payment terms are set on 150 days. In this case 100% of the payments are aligned with these payment terms.

Payment Practices Metrics

Scope: Proximus Group

Legal Proceedings

We have currently no legal proceedings outstanding for late payments to suppliers who have a contract with Proximus SA. We have currently 3 outstanding legal proceedings for our international business.

Methodology

The term "average supplier payment days" has been defined as "the number of days Proximus takes to pay its suppliers after receiving an invoice". This metric is calculated based on the number of invoices received during the reporting year by the Group, based on the weighted average of 90% of our invoices. For the remaining 10% of invoices, we worked on the assumption that payment practices are similar. The data was collected via our internal reporting system and has been consolidated through the 2024 sustainability reporting process.

Supplier Finance Arrangements

Proximus utilized bills of exchange to extend the payment term for one of its vendors from 30 days to the Proximus' standard payment term of 60 days. The extension to the payment term of 60 days is subject to a standard interest rate based on market conditions. Since these liabilities are for goods or services formally invoiced by suppliers and are part of the working capital used in Proximus' normal operating cycle, they remain classified as trade payables on the Balance Sheet.