Proximus

The role of the administrative, management and supervisory bodies

Reference: page 78.

Sustainability governance is structured across three levels. The Board of Directors "bears ultimate responsibility for overseeing all IROs and plays a crucial role in validating Proximus Group's sustainability targets, long-term roadmaps, short-term action plans, and KPIs across all ESG material topics" (page 78). The Audit and Compliance Committee validates ESG reporting and monitors KPI updates quarterly, and the Nomination and Remuneration Committee oversees ESG-linked incentives, also quarterly.

Below Board level, the bi-monthly Sustainability Committee at Proximus Leadership Squad (PLS) level approves domestic and international roadmaps, targets and KPIs and follows up execution. The Sustainability team acts as the Group's Center of Excellence, co-creating ambitions and roadmaps, while a Business Lead is appointed for each material topic and is end-to-end accountable for delivery (page 78).

In 2025, Board members were interviewed as part of the Double Materiality Assessment and "subsequently reviewed and validated the results" (page 78).

Information provided to and sustainability matters addressed by the Board

Reference: page 78.

"Achievements are reported bi-monthly to the Board through the CEO Activity Report, and progress is analyzed quarterly as part of the strategic review" (page 78). The Audit and Compliance Committee "validates reporting, oversees updates vs KPIs, and ensures compliance" on a quarterly basis, and also "manages sustainability-related risks, including climate risks, as part of its broader risk management oversight."

The bi-monthly Sustainability Committee at Proximus Leadership Squad level "approves combined domestic and global North Stars, long-term roadmaps, short-term action plans, and KPIs" and "follows up execution, addresses roadblocks, and defines priorities" (page 78), feeding matters upward to the Board.

In 2025, Board members were personally interviewed as part of the Double Materiality Assessment update and reviewed and validated its results (page 78), which is the clearest single instance of sustainability matters being addressed directly at Board level this year.

Integration of sustainability-related performance in incentive schemes

Reference: pages 48-50; page 105.

ESG metrics are integrated into both short-term (STI) and long-term (LTI) variable remuneration. "Our strong ESG ambitions are therefore reflected in our STI KPIs: over recent years, the weight of ESG and culture related KPIs within the STI framework has steadily increased, up to 25% in 2024" (page 50). The "Act for an inclusive society & be sustainable in everything we do" strategic pillar carries a 15% weight within the Group-performance component of the STI (page 49).

Within the climate change chapter specifically: "All employees contracted by Proximus SA in Belgium have a short-term variable remuneration incentive directly linked to the Group's performance against a set of KPIs. Within these KPIs, there is the 'Society and Sustainability' pillar, which represents 15%, of which 5% relates to scope 1 and scope 3" (page 105). For the Leadership Squad and Leadership Team, "one third [of the LTI ESG KPIs] is linked to scope 1 and scope 3 carbon emissions, representing 8.33% of the total" in 2025. The remuneration of the Board of Directors itself is not linked to climate change (page 105).

Statement on due diligence

Reference: page 79.

Proximus maps its due diligence activities against the standard core elements, stating that "while a comprehensive due diligence process addressing all ESG topics is still being formalized, the activities described in this Integrated annual report already reflect the core elements of due diligence" (page 79):

• Embedding in governance, strategy and business model: the "Sustainability governance" and "Business conduct" sections.
• Engaging with affected stakeholders: the "Interests and views of stakeholders" section.
• Identifying and assessing adverse impacts: the "Double Materiality Assessment".
• Taking actions to address adverse impacts: the actions subsection of each material topic.
• Tracking effectiveness of actions: the performance subsection of each material topic.

The statement is explicit that due diligence is not yet a single formalized Group-wide process but is distributed across the topical chapters referenced above.

Risk management and internal controls over sustainability reporting

Reference: page 79.

"The initial CSRD reporting exercise highlighted the need to strengthen our controlling environment. The primary risk identified was the reliance on predominantly manual data-collection processes" (page 79). In response, in 2025 Proximus "undertook a comprehensive review of our documentation, introducing the Sustainability Data Governance Catalogue and implementing enhanced control mechanisms to minimize the likelihood of errors," including "reasonableness tests, variance analysis, reconciliation across data sources, and a four-eyes review." The Group also "conducted a dry run of the sustainability reporting process, simulating external assurance conditions to test data readiness, validate control effectiveness, and identify areas for improvement" (page 79).

The Sustainability team owns the collection, review, consolidation and verification process, working with Finance, HR, Cybersecurity, Legal, Internal Audit and Risk Management, Group Data and Public Affairs. "For some data sources, internal control on data quality is built-in; however, for most of the data, manual verification is needed to detect inaccuracies" (page 79).

Strategy, business model and value chain

Reference: pages 79-84.

Proximus' purpose is "to boldly build a connected world that people trust, so society blooms," operationalized through the three-year bold2025 strategy and nine ESG commitments spanning network roll-out, cybersecurity, climate action, digital inclusion, ethics, and an inspiring work environment (page 80).

Financially, of EUR 1.25 billion total CapEx, "38% (EUR 479 million)" was sustainable CapEx (fiber, mobile, backbone, network simplification) and "5% (EUR 60 million)" went to the circular economy; separately, EUR 26 million was dedicated to employee working conditions, EUR 23.4 million to green mobility OpEx, and EUR 45.9 million to employee reskilling (page 81).

The Group distinguishes two value chains: Telecom and IT (raw materials, network infrastructure and hardware upstream; network construction, software and cybersecurity in-house; retail, after-sales and e-waste recycling downstream) and CPaaS and Digital Identity (cloud/API/cybersecurity inputs; platform and fraud-prevention development; omnichannel messaging delivery downstream) (pages 83-84). Key inputs include 12,933 employees, ~3,470 active suppliers across 52 countries, and 370,639 MWh of energy consumption (page 82).

Interests and views of stakeholders

Reference: pages 84-86.

Proximus engages distinct stakeholder groups through dedicated channels. Employees: the twice-yearly Speak Up survey, shared with the PLS, the HR Management Committee and the unions (page 85). Suppliers and value chain workers: the Supplier Code of Conduct, the Supplier Engagement Program, JAC membership and EcoVadis assessments; the report notes Proximus "has not yet implemented a structured approach to directly engage value chain workers" (page 85). Customers: contact centers, digital platforms, the Voice of the Customer platform, and for enterprise customers, advisory boards and co-creation workshops (page 85). Investors: the Integrated annual report, quarterly results, the AGM and roadshows (page 86). Public authorities: the Group Public Affairs department and the Regulatory team, engaging BIPT and industry bodies such as Connect Europe and GSMA (page 86). Society at large: quarterly public-perception surveys and partnerships with NGOs, consumer bodies and universities (page 86).

The 2025 DMA update itself drew on "17 interviews: 7 with Board or leadership members, 1 with a union representative, and 9 with external stakeholders," plus two internal online surveys (page 88).

Material impacts, risks and opportunities

Reference: pages 89-95.

The 2025 Double Materiality Assessment identified 38 material IROs across 21 subtopics, grouped into 7 ESRS topical standards and 1 entity-specific topic (page 89): E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users, G1 Business conduct, and entity-specific Cybersecurity. E2 Pollution, E3 Water and marine resources and E4 Biodiversity and ecosystems were not found material. Compared with the 2023 assessment, "Technology and innovation" is no longer material, while "Health and safety of end-users," "Responsible management of the customer experience" and "Business model resilience and systemic risk management" are newly material (page 90).

Material impacts/risks/opportunities are tabulated by subtopic with type (actual/potential, positive/negative/risk/opportunity), value-chain location and time horizon, and are each linked to a bold2025 strategic pillar and ESG commitment (pages 91-95). The full breakdown is summarised in the accompanying IRO count file.

Description of the process to identify and assess material IROs

Reference: pages 86-89.

The 2025 DMA update followed a five-step methodology performed "in accordance with the requirements of the European Directive on Corporate Sustainability Reporting (CSRD) and EFRAG implementation guides IG1 (Materiality Assessment) and IG2 (Value Chain)" (page 86): (1) context setting and value chain mapping, updated for the Route Mobile acquisition into two value chains, "Telecom and IT" and "CPaaS and Digital Identity"; (2) identification of IROs and topics, drawing on the previous DMA, peer benchmarking, SASB/MSCI/GRI, and a parallel TCFD project; (3) stakeholder engagement (17 interviews plus two internal surveys); (4) materiality assessment, scoring impact materiality (scale, scope, irremediability, likelihood) and financial materiality (magnitude x likelihood, aligned with the Enterprise Risk Management process) per value chain, with a conservative rule that an IRO material in either value chain is material Group-wide; and (5) results validation, ending with "final approval by the Proximus Sustainability Committee and the Board of Directors in July 2025" (page 88).

Disclosure requirements covered by the sustainability statement

Reference: ESRS Index, pages 391-398.

Proximus publishes a full ESRS content index ("ESRS Index") in the Annex, listing every ESRS 2 and topical disclosure requirement against its location in the Integrated annual report, or marking it "Not material," "Not applicable," or subject to the ESRS 1 Appendix C phase-in provision. All ESRS 2 disclosure requirements (BP-1/BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, MDR-P/A/T/M) are located in the "General information" subsections. The index separately confirms the material topical standards as E1, E5, S1, S2, S3, S4 and G1, each with its own disclosure requirements located, and states for E2, E3 and E4 that "all the other disclosure requirements are not material based on the DMA" beyond the mandatory IRO-1 process description. An entity-specific Cybersecurity chapter is reported against the MDR-P/A/T/M minimum disclosure requirements. A separate Appendix B table cross-references datapoints derived from other EU legislation (SFDR, Pillar 3, the Benchmark Regulation and the Climate Law).

Transition plan for climate change mitigation

Reference: pages 100-104; financial resources page 81.

The Climate Transition Plan "represents our vision towards a net-zero future... within our own operations (scope 1 and 2) and across our value chain (scope 3)," developed by the Sustainability team and "approved by Proximus' Leadership Squad and Board of Directors" (page 101). Proximus targets net-zero GHG emissions across its entire value chain by 2040 (2020 baseline, SBTi-validated), with updated 2030 near-term targets: scope 1+2 down 66%, scope 3 down 42%, and continued 100% renewable electricity sourcing (page 100).

Scope 1+2 levers are fossil-fuel removal (fleet electrification, building decarbonization), energy efficiency, and renewable sourcing; scope 3 levers are network transformation, supply chain engagement, circularity, and stakeholder engagement (page 101). The company discloses a gap to its own targets: "a gap between our projected emissions and our 2030 ambitions (a gap of 44 ktCO2eq or 11%) and 2040 ambitions (a gap of 107 ktCO2eq or 26%)" (page 103). Locked-in emissions are linked qualitatively to the carbon intensity of the electricity grid powering leased customer devices (page 103). Implementation is currently focused on domestic Telecom/IT operations in Belgium and Luxembourg (97% of the Group's GHG footprint); other affiliates will be brought in over coming years (page 102).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 "Methodology for assessing climate-related risks and opportunities" subsection (pages 97-99), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Proximus revised its climate-related financial analysis in 2025 "in alignment with the Task Force on Climate-related Financial Disclosure (TCFD) recommendations," covering both value chains and upstream/downstream activities (page 97).

Physical risk: 21 sites across six countries (Belgium, France, Luxembourg, USA, Singapore, India) were assessed under two IPCC scenarios: SSP5-8.5 (very high emissions, ~4.3°C by 2100) and SSP2-4.5 (intermediate, ~2.4°C by 2100), using an AI-powered climate-modelling tool (Sust Global) combined with a site-specific flood risk assessment, quantifying structural damage and business interruption (pages 97-98).

Transition risk: analysed under the IEA Net Zero Emissions by 2050 (NZE) scenario (1.5°C-aligned) complemented by the IEA Stated Policies Scenario (STEPS) as a conservative benchmark, incorporating regional carbon-pricing and energy-cost indicators (page 98-99). Scope covers Proximus Group's own operations and both value chains; the analysis is reviewed on a yearly basis for continued applicability (page 97).

Resilience in relation to climate change

Back-filled from the E1 "Climate change adaptation" subsection (pages 112-113), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Proximus states plainly that "our business model does not need to be adapted to the potential impacts of climate change at this stage," citing built-in network redundancy that allows traffic to reroute if a node is disrupted (page 113). Resilience relies on the Business Continuity Management (BCM) framework and the Proximus Emergency Response Team, with preventive measures for heat waves (ventilation designed to withstand 40°C peaks and up to 60 hot days a year) and a site-specific flood risk assessment feeding into recovery plans for asset groups (pages 112-113).

No quantified scenario-based resilience analysis as defined under ESRS has been performed, and the company states explicitly that "no specific performance metrics have been defined for climate change adaptation" (page 113). Current preventive actions are described as "considered sufficient" at this stage (page 113).

Policies related to climate change mitigation and adaptation

Reference: pages 99-100.

Climate-relevant policies include the Environmental Policy ("minimizing the use of raw materials and energy and avoiding ozone-depleting substances"), the Code of Conduct, the Supplier Code of Conduct (suppliers expected to disclose their GHG footprint, set science-aligned targets and publish a renewable-energy roadmap), the Procurement Policy (requiring product emissions as an evaluation criterion in all procurement files, via the Supplier Engagement Program), and the Business Continuity Policy, reviewed every two years under the accountability of the Group Corporate Affairs Lead (page 99). All policies except the Procurement and Business Continuity Policies are published externally; the latter two are intranet-only (page 100).

Actions and resources in relation to climate change policies

Reference: pages 101-105.

Climate action is centrally overseen by the Sustainability and Energy teams, with execution decentralized to business departments and a transversal "Energy Tribe" led by an Energy Lead (page 101). Concrete 2025 actions under the four scope-3 levers and three scope-1/2 levers include: the management fleet moving from 28% to 48% electric vehicles and the technical fleet reaching 16% EV (page 103); switching off 514 copper cabinets (+171% versus 190 in 2024) as part of fiber network transformation (page 104); a Power Purchase Agreement with Engie covering ~20% of Group green electricity, the remainder via Energy Attribute Certificates (page 103); the Supplier Engagement Program covering the top 250 suppliers on scope 3 category 1 emissions (page 104); and Mwingz mobile-site sharing with Orange Belgium targeting up to 40% fewer sites by 2026 (page 104). Internal engagement included a new Climate & Energy Community and a first Climate & Energy Conference attended by up to 800 employees (page 105).

Targets related to climate change mitigation and adaptation

Reference: page 100.

Following a 2024 review against the cross-sectoral 1.5°C pathway, validated by the SBTi in November 2024, Proximus' near-term 2030 targets (2020 base year) are: reduce absolute scope 1 and scope 2 GHG emissions by 66%, reduce absolute scope 3 GHG emissions by 42%, and continue sourcing 100% renewable electricity through 2030. The longer-term commitment is net-zero GHG emissions across the value chain by 2040, requiring "cutting at least 90% of our direct and indirect total emissions and using carbon removal technologies for the remaining emissions (less than 10%)" (page 100). The targets apply to "100% of our scope 1, 2, and 3 emissions" per the SBTi-validated inventory boundaries (page 100).

Energy consumption and mix

Reference: page 110.

Total energy consumption fell to 370,639 MWh in 2025, down 13% from 426,250 MWh in 2024, "mainly explained by the deconsolidation of electricity consumption from our three datacenters as of April 2025" plus legacy-technology decommissioning and efficiency measures (page 110). Non-renewable (fossil-source) consumption covers heating (20,774 MWh, down from 26,822 in 2023) and the vehicle fleet (62,154 MWh, down from 87,496 in 2023); the fossil share of total energy fell from 25% (2023) to 22% (2025). Renewable electricity purchased for networks, datacenters and offices totalled 285,448 MWh in 2025, and solar production from Proximus' own panels rose to 2,263 MWh. "Proximus Group does not consume energy from nuclear sources or from renewable sources such as biomass, biofuels, biogas, and renewable hydrogen" (page 110).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 106-108.

Total 2025 GHG emissions were 375 KTons, split Scope 1 5% (20 KTons), Scope 2 market-based 0% (0 KTons), and Scope 3 95% (355 KTons) (page 106). In absolute terms: gross Scope 1 fell to 19,757 tCO2eq (down 14% year-on-year, down 26% versus the 2020 baseline); gross market-based Scope 2 fell to 21 tCO2eq (effectively zero, from 785 tCO2eq in 2020), reflecting 100% renewable electricity sourcing; and total gross Scope 3 fell to 355,380 tCO2eq (down 11% year-on-year, down 14% versus baseline), of which "Purchased goods and services" is the largest category at 302,666 tCO2eq, down 9% year-on-year (pages 107-108). "Purchased goods and services" alone represents 85.2% of Scope 3, with customer use of sold products at 9.4% (page 106).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 109.

Proximus does not generate GHG removals from its own operations but has, "since 2016," supported "the multiannual Gold Standard-certified climate project called the TEG Stove project... which aims for carbon emission reduction through wood consumption reduction." 7,950 tCO2eq of carbon credits were cancelled in 2025 (up from 6,735 in 2024 and 5,949 in 2023), 100% from this Gold Standard project (page 109). The company states that "Proximus Group's support for the TEG Stove project concluded in 2025. Starting in 2026, we do not anticipate purchasing any additional carbon credits" (page 109) -- these credits are used outside the value chain and are not netted against the Group's own reported GHG emissions or targets.

Policies related to resource use and circular economy

Reference: page 120.

"Proximus has already translated and implemented general policies to ensure that circularity principles are taken into account by our operational teams. These policies are the Proximus Environmental Policy, the Proximus Code of Conduct, the Supplier Code of Conduct, and the Proximus Procurement Policy" (page 120). Employees additionally have access to "more specific guidance... on our intranet and defined specific processes that help put circularity into practice," including documented device-return processes for customers, technicians and sales agents (page 120). Circularity and waste management also sit within a multi-level regulatory context: the EU Circular Economy Action Plan, the WEEE Directive, CSRD/ESRS E5 and the EU Ecodesign for Sustainable Products Regulation, alongside regional Belgian waste plans (page 119-120).

Actions and resources related to resource use and circular economy

Reference: pages 120-122.

Circularity actions span four domains. Mobile devices: Proximus collected 144,111 used mobile devices in 2025 (up 3% from 140,587 in 2024), representing 30-40% of devices put on the market being recovered, via trade-in offers and return campaigns, plus the launch of the 6th-generation Fairphone and a device-repair pilot with BLOOO in Mons and Ghent (page 120). Fixed devices: the latest Android TV Box uses 20-40% less energy and 20% less packaging plastic than prior models; the Courcelles logistics center targets refurbishing at least 90% of Internet Boxes/TV Boxes for up to four reuse cycles (page 120-121). Networks: Mwingz mobile-site sharing with Orange Belgium reduces site duplication, and 501 tons of copper cables were collected and recycled in 2025 as copper infrastructure is phased out (page 121). Buildings: the new headquarters design optimizes energy use and reuses/refurbishes furniture (page 121).

Circularity is cross-functional, spanning the Procurement department and sustainability specialists, with a primary sponsor at PLS level; dedicated circularity FTEs are not separately disclosed as the work is embedded in existing teams (page 119).

Targets related to resource use and circular economy

Reference: pages 118-119.

Proximus' ambition is "to be a blueprint for circularity by 2030," structured around five pillars: circular by design, prioritizing reuse, optimizing recovery rates, reimagining innovation, and fostering ecosystems and collaboration (page 118). Two Company-wide targets are stated: "deliver the contribution of customer device circularity to our Climate Transition Plan by 2030" and "recycle almost all collected e-waste by 2030," with the first reporting on that e-waste metric due in 2026 (page 119). Additional operational-domain objectives cover mobile devices, fixed devices, networks and buildings, though these are described as qualitative ambitions rather than numerically measurable targets (page 119).

Resource inflows

Reference: pages 123-124.

Proximus concentrates its quantitative resource-inflow reporting on branded customer devices (Internet Boxes, TV Boxes, Wi-Fi Boosters), citing "relatively high volumes, high rotation" and the Group's influence over design as the reason for scope (page 123). Total customer-device inflow weight fell to 697 tons in 2025 from 834 tons in 2024 across Internet Boxes, TV Boxes, Boosters and (newly, for inflow weight only) mobile phones (page 124). Recycled material content per device type is also reported (e.g., Internet Boxes and Boosters both show a measured recycled-material share, down slightly year-on-year). Network material and non-core hardware inflows are explicitly not yet quantified: "Information related to network material is not yet available to us, as this is fully dependent on value chain information flows that have yet to be implemented" (page 123).

Resource outflows

Reference: pages 125-126.

Outflows are dominated by e-waste from network infrastructure and from customer-premises equipment (mobile phones, Internet Boxes, TV Boxes, Wi-Fi Boosters, fiber boxes, PABX and power units), "typically composed of ferrous and nonferrous metals... plastics... electronic components... glass used in fiber-optic cables" (page 125). Devices channeled through Proximus' refurbishment facility "do not end up as waste and are not reported as such" (page 125) -- the circularity actions under E5-2 (144,111 mobile devices collected, 90% refurbishment target for fixed devices) are therefore the main lever reducing this outflow. Proximus targets recycling "almost all collected e-waste by 2030," with first reporting on that metric due in 2026 (page 119). Quantified waste-by-treatment data is presented under "Waste" (see E5-5-Waste).

Waste

Reference: page 126.

"In 2025, Proximus Group managed to divert 99% of the waste generated from our own operations from disposal, maintaining this percentage already achieved in 2024" (page 126). Total waste diverted from disposal fell to 4,698 tons in 2025 from 5,805 tons in 2024, split between recycling (3,761 tons, the largest recovery route), other recovery operations (891 tons) and preparation for reuse (46 tons); hazardous waste (mainly batteries from network and customer devices, plus old cable types) accounted for 1,196 of the 4,698 tons diverted. Small residual volumes were incinerated without energy recovery, landfilled, or sent to other disposal methods. "There is no radioactive waste in Proximus Group's waste streams" (page 126). Waste streams span roughly twenty categories, including excavation rubble, batteries, metals, and paper and cardboard (page 125).

Policies related to own workforce

Reference: pages 128-129.

Core workforce policies include the Proximus Group Code of Conduct, applied across all affiliates under the supervision of the Group Compliance Office. The Human Rights Policy, endorsed by all affiliates, states that "all employment with Proximus Group is voluntary... We do not use child or forced labor in any of our operations or facilities," and covers freedom of association and freedom of opinion and expression (page 128). In 2025 Proximus created a new Occupational Health and Safety Policy applying to all affiliates, reviewed annually (page 129), and revised its Diversity, Equity, and Inclusion Policy to better integrate international standards while respecting local legislation (page 129). A Belgium-specific policy addresses harassment and violence-at-work complaints, supported by internal trusted persons and psychosocial prevention advisors (page 129).

Processes for engaging with own workforce and workers' representatives

Reference: page 130.

"Twice a year, Proximus Group organizes Speak Up surveys among all employees regarding their experiences at work," covering more than 12,900 employees across 17 companies in 30+ countries, with an 82% response rate in 2025 (page 130, page 133). The January survey is the primary one, measuring well-being, culture, manager effectiveness and ambassadorship (e-NPS/NPS); a shorter mid-year pulse survey assesses the effectiveness of actions taken. Results are "presented to the PLS, the Human Resources Management Committee, and the unions," and team leaders develop team-level action plans followed up by senior management (page 130). Proximus also "maintains an open and constructive dialogue with representative trade unions" through social consultation (page 84).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 130.

"Proximus Group takes a proactive approach to the remediation of actual material adverse impacts that may affect employees. Employees can report incidents through the whistleblowing channel. Incidents are thoroughly analyzed, and corrective measures are implemented to address them effectively" (page 130). Employees are regularly updated and trained via internal communication channels to build trust in these processes, and detailed whistleblower procedures (online, phone or mail, confidential and available in all affiliates where whistleblowing legislation applies) are described in the Business conduct chapter (page 130, cross-referenced to pages 180-182).

Taking action on material impacts on own workforce

Reference: pages 131-132.

On secure employment, fair pay and freedom of association: "most of our employees work under permanent contracts," supported by regularly benchmarked remuneration policies and local joint committees overseeing collective agreements (page 131). On work-life balance and health and safety: well-being programs address job quality, work relations/conflict management and psychosocial safety; occupational health and safety follows "a preventive approach... with ongoing training, health campaigns, and psychosocial support"; and specific (confidential, for security reasons) measures protect customer-facing employees and field technicians from armed robbery (page 131-132). The report also states plainly that "processes to support employees in recovering from stress-related situations or burnout are not yet standardized at the Group level" and will be reviewed within the coming year (page 132).

Targets related to own workforce

Reference: pages 132-133.

Proximus' stated strategic objective was "to reach an employee engagement above 75% by 2025" (page 132). The company reports this target as met: "This target has been met, with the employee engagement at the end of 2025 reaching 78%" (page 133), against a Group-level internal survey metric shown as 76% for both 2024 and 2025 in the accompanying performance table. Separately, a 2025 training objective targeted "95% of employees [Proximus SA] have participated in at least five days of training," against which 90% was achieved (page 143-144, see S1-13).

Characteristics of the undertaking's employees

Reference: page 134.

Total headcount was 12,933 employees in 2025, down 7% from 13,862 in 2024, "partly the result of clearer reporting definitions" (page 134). By gender: 8,966 male, 3,961 female, 6 not disclosed. By country, Belgium (9,489), Luxembourg (781), India (1,318), Serbia (447), Colombia (259), the Netherlands (261) and the USA (131) are the largest headcount locations. Of the total, 12,790 employees hold permanent contracts and 143 temporary contracts; there are no non-guaranteed-hours employees. Workforce turnover rose to 13% in 2025 (1,738 leavers) from 10% in 2024 (page 134).

Collective bargaining coverage and social dialogue

Reference: page 136.

Employees covered by collective bargaining agreements within the European Economic Area rose to 91% in 2025, from 90% in 2024 (page 136). "When a collective agreement is signed, it applies to all employees working for the Proximus Group entity (except executives and senior management)," calculated across all EEA countries, with significant employment concentrated in Belgium, the Netherlands and Luxembourg (page 136). Workplace representation coverage is reported separately for the Netherlands and for Belgium/Luxembourg combined; outside the EEA, Proximus has more than 50 employees only in the USA, Serbia, India and Colombia, which are out of scope for this metric (page 136).

Diversity metrics

Reference: pages 141-142.

"Starting from a baseline of 24% in 2023, female representation [in top management] reached 22% in 2025," described as "a marginal decline in a highly competitive talent market" (page 142); the reported top-management population grew from 178 to 220 people between 2024 and 2025, reflecting the first-time inclusion of Proximus Global's leadership. By age group, the workforce splits 1,675 under 30, 6,675 between 30-50, and 4,583 over 50 (2025) (page 142). Proximus also reports succession-pipeline progress outside the formal metric set: "in 2025, 101 successors were nominated across the Group, with 44% being women -- doubling the previous year's representation" (page 141).

Adequate wages

Reference: page 135.

"Within Proximus Group, all employees are paid adequate wages in line with applicable benchmarks, local regulations, and market conditions" (page 135) -- a nil/clean-compliance return rather than a quantified gap. The company compares "each employee's monthly gross pay against the official minimum wage in their country, using reliable sources such as Eurostat" to identify any employee paid below the legal threshold (page 135).

Health and safety metrics

Reference: page 138.

"In 2025, no fatalities resulting from work-related injuries or work-related ill health were reported for our own workforce" (page 138); the same holds for other workers on Proximus premises, though legal restrictions prevent Proximus from accessing health data needed to report ill-health fatalities for those workers. 100% of employees are covered by a health and safety management system in both 2024 and 2025. Work-related accidents fell to 60 in 2025 (a 3.0% rate) from 67 (3.3%) in 2024, measured per million hours worked with a revised reporting period (November-October) adopted for completeness (page 138).

Compensation metrics (pay gap and total compensation)

Reference: page 135.

The gender pay gap held steady at 6% in both 2024 and 2025; annual gender pay equality assessments "have consistently demonstrated that any pay differences between female and male employees are not the result of discriminatory pay practices," attributing the gap mainly to a higher proportion of women working part-time (page 135). Proximus is preparing a more comprehensive pay-equity analysis ahead of the EU Pay Transparency Directive. The CEO-to-median total remuneration ratio fell to 17 in 2025 from 22 in 2024, "attributable to the nomination of a new CEO," since the former CEO's package had carried an additional EUR 400,000 gross for international responsibilities from 2024 (page 135).

Incidents, complaints and severe human rights impacts

Reference: page 137.

"No severe human rights incidents related to Proximus Group's workforce were reported through existing channels in 2025. This means there were no reports of forced labor, human trafficking, or child labor, nor any violations of the UN Guiding Principles on Business and Human Rights" (page 137). Employee complaints related to human rights fell to 0 in 2025 from 1 in 2024. "To date, Proximus Group has not received any fines or penalties related to severe human rights incidents" (page 137). Available channels include management, HR, the Prevention and Protection department, the Data Protection Officer and the Ethics and Compliance Officer.

Policies related to value chain workers

Reference: page 147.

"Our Human Rights Policy applies to all workers within our value chain," prohibiting child labor, forced labor, human trafficking and involuntary servitude, consistent with the Universal Declaration on Human Rights and ILO Core Conventions (page 147). Expectations toward external workers are communicated through the Supplier Code of Conduct, "based on the Ten Principles of the UN Global Compact," part of every new and extended contract since 2021 and embedded in Proximus' General Terms and Conditions (page 147). A Group health and safety policy also extends obligations to subcontractors, who must comply with applicable occupational safety laws as well as Proximus' own policies (page 147).

Processes for engaging with value chain workers about impacts

Reference: pages 145-146.

As Proximus does not directly employ value chain workers, engagement runs primarily through its membership of the Joint Alliance for CSR (JAC), whose program includes Mobile Workers' Surveys, independent third-party on-site audits against JAC's Sustainability Supply Chain Guidelines, and a JAC Supplier Forum for shared best practice (page 145). Subcontracting is capped at two levels and supported by a Group-developed onboarding tool that checks reputation, social-legislation compliance, solvency and certification (page 145). For technical roles, certification (including VCA health/safety/environment certification) and scheduled strategic and operational communication sessions with partners are in place (page 146).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 146.

"Proximus Group has established secure and confidential whistleblowing channels that are accessible to both internal and external stakeholders, including workers within its value chain," covering reports of human rights violations, unethical conduct or breaches of internal policy regardless of whether the reporter is a direct employee or works for a supplier or subcontractor (page 146). As stated in the Supplier Code of Conduct, a violation can lead Proximus to "temporarily suspend the business relationship or terminate it, if necessary, without the supplier being entitled to compensation" (page 149).

Taking action on material impacts on value chain workers

Reference: pages 146-149.

Proximus classifies suppliers by criticality (the top 250 of its 3,470 suppliers represent 80% of spend) to prioritize sustainability engagement and audit effort, and screens roughly 9,200 active suppliers and partners via Dow Jones and GraydonCreditsafe for sanctions exposure (page 146). An EcoVadis scorecard (no more than three years old, minimum score of 45) is required of every tender candidate, with critical suppliers undergoing validated third-party evaluation (page 146). A 2023 salient-risk analysis ranked potential (not actual) human-rights exposure by supply-chain category (page 147). Performance is tracked via JAC: "Spend at suppliers submitted to on-site audit operations" fell to 13% in 2025 from 23% in 2024 (page 149).

Policies related to affected communities

Reference: page 152.

Four Group-wide policies address impacts on affected communities: the Code of Conduct ("guidance on contributing to the development of society"), the Human Rights Policy, the Environmental Policy ("efforts to minimize disturbances and commit to reviewing all complaints"), and the Supplier Code of Conduct, which obliges subcontractors executing network deployment to comply with EU, federal, regional and city regulations and to designate a site manager responsible for citizen complaints (page 152). In 2025, Belgian operators under Agoria signed a Telecom Charter "supporting respectful fiber network deployment," covering safety, regulatory compliance, quality standards and citizen communication, due for publication in H1 2026 (page 152).

Processes for engaging with affected communities about impacts

Reference: pages 152-153.

Fiber roll-out follows a structured multi-year engagement sequence: an "appetite meeting" with city authorities one to two years before deployment, a formal charter or documented agreement on meeting cadence, non-commercial public communication via local press and city web pages, weekly/monthly coordination meetings during deployment, and direct citizen notice (flyers for underground works, letters five to ten days ahead of facade works) (pages 152-153). For mobile sites, "Proximus works closely with municipalities to find mutually acceptable locations for the antenna that meet both local preferences and the network's radio requirements" (page 153).

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 152-153.

Remediation actions to reduce community disruption include mobile-site sharing via Mwingz (reducing each operator's site count by up to 40% by 2026, with 965 Proximus sites dismantled by end-2025), fiber-access partnerships (MoUs in Flanders and Wallonia), duct sharing to limit trenching, and advance coordination with utility companies (page 152). Engagement is not direct with residents but routed through city political representatives, a dedicated 0800 number and email per city, and -- for dissatisfaction with repair work -- the Mediation Service for Telecommunications, which publishes an annual complaints report; there is "no central database for tracking complaints" at Group level (page 153).

Taking action on material impacts on affected communities

Reference: pages 153-154.

Proximus monitors municipal satisfaction through a biannual survey of political/administrative risk and a periodic "pro-care" study; "in 2024, 93% of respondents expressed satisfaction with Proximus' worksite management. No survey was conducted in 2025" (page 153). On electromagnetic-field concerns, actions include transparent public information on the corporate website, compliance with applicable legislation, ongoing monitoring of scientific research ("when radio frequencies remain below internationally authorized thresholds, there is no evidence of adverse health effects," a position "endorsed by... the World Health Organization"), and referral of health questions to competent public bodies (ISSEP, Brussels Environment, LNE) (page 153-154).

Policies related to consumers and end-users

Reference: pages 155-156.

Consumer-facing policies include the Code of Conduct and the dedicated Data Protection and Secrecy of Electronic Communications Policy, which supports GDPR compliance (page 155-156). Proximus SA in Belgium has a full-time in-house Data Protection Officer supported by a team of in-house privacy specialists, overseen by the Proximus Data Council, an internal governance committee including senior staff from Corporate Affairs (page 156). The Supplier Code of Conduct also extends data-protection and customer-facing conduct expectations to suppliers (page 156).

Processes for engaging with consumers and end-users about impacts

Reference: pages 156-158.

For data protection, individuals can exercise GDPR rights or raise questions via email, letters or a dedicated web form; since GDPR took effect, Proximus SA has handled "approximatively 15,500" data subject requests (page 157). In 2025, Proximus launched a customer trust survey on data-protection practices, surveying 600 residential customers: "70% of our customers hold a neutral or positive view of how we handle their personal data," 69% expressed confidence in data security, and only 49% were aware of the Privacy Notice (page 157-158). For digital inclusion and customer experience, engagement runs through the Voice of the Customer platform, a customer-experience dashboard, design-thinking sessions and, for residential customers, self-service portals and mass campaigns (page 85).

Processes to remediate negative impacts and channels to raise concerns

Reference: page 158.

"Proximus has implemented a robust incident response process" for personal data breaches: a dedicated team investigates root cause and scope, assesses impact on affected individuals, notifies regulators and individuals where legally required, and applies remedial actions such as patching vulnerabilities (page 158). GDPR e-learning is mandatory; a 2025 interactive campaign was "completed by more than 90% of Proximus Group employees," with 92% of invited employees completing the newest module (page 158). Specific training was also provided to Data Ambassadors and to contact-center/customer-service staff in high-impact roles (page 158).

Taking action on material impacts on consumers and end-users

Reference: pages 161-167.

On digital inclusion, Proximus reports 16,818 people trained through digital-inclusion projects in 2025 (up from 15,138 in 2024), via partners including Child Focus's Internet Safe & Fun, Technobel, Ada, MolenGeek, 42 Belgium and BeCode (page 163), addressing a context in which "40% of Belgians are at risk of digital exclusion" per the King Baudouin Foundation (page 160). On responsible customer-experience management, actions include customizable SLAs with guaranteed repair times for business customers, Net Promoter Score-based support tracking, proactive pre-installation assessments to mitigate delayed installation, and structural root-cause analysis of recurring complaints in collaboration with mediators and consumer organizations (pages 165-167). "No confirmed severe human rights incidents connected to Proximus consumers and end-users were reported through the existing channels in 2025" (page 163).

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

Reference: page 158.

For data protection -- the only S4 subtopic where the company's own ESRS Index cites a location for this DR -- Proximus states: "We have not yet established specific Group targets. This should be addressed within the next two to three years" (page 158). In the interim, the newly launched customer trust survey (600 residential respondents, 70% neutral-or-positive on data handling, 69% confident in data security) serves as a baseline against which future progress will be tracked, rather than a numeric target (page 157-158). No equivalent target statement is made for the digital inclusion or responsible-customer-experience subtopics.

Business conduct policies and corporate culture

Reference: pages 176-179.

"All employees are expected to carry out their daily activities and achieve their business objectives in line with our Code of Conduct," which is elaborated through a suite of owned, approved policies grouped under Ethics & business conduct (Anti-Bribery/Corruption/Conflicts of Interest Policy, Dealing Code, Export Controls and Sanctions Compliance Policy, Fraud Policy, Whistleblowing Procedure, among others), Resilience & business continuity, and Supply chain & human rights (Human Rights Policy, Supplier Code of Conduct, Procurement Policy) (pages 177-179). Policies are published on the intranet (with local-language translations) and, for key policies, externally on proximus.com, with periodic and update-triggered communications to employees and contractors (page 177).

Prevention and detection of corruption and bribery

Reference: pages 180-182.

Corruption and bribery are prohibited under the Code of Conduct and the Anti-Bribery, Corruption, and Conflicts of Interest Policy. In 2025, 87% of employees considered to be at risk completed anti-bribery and conflict-of-interest training, up from 74% in 2024 (domestic completion rose from 90% to 94%) (page 181); extra workshops targeted the Procurement and Enterprise sales teams. A list of "People Discharging Managerial Responsibility" is maintained per Belgian legislation, and Route Mobile separately maintains a Designated Persons list under Indian securities regulation (page 181). The independent Internal Investigation team, reporting to the Group Cybersecurity Lead for independence from management, handles cases with a quarterly report to the Audit and Compliance Committee (page 182); whistleblowing channels are available online, by phone or by mail, with the online channel outsourced since 2024 to a large accounting firm, and a Belgian external escalation route via the Federal Ombudsman's Centre for Integrity (page 182).

Targets related to business conduct

Business conduct targets fall under MDR-T in the 2023 ESRS the report was prepared against; G1-3 became a standalone targets DR only in the 2025/2026 ESRS.

Proximus states an explicit outcome target: "We are committed to achieving zero cases of: bribery and corruption; unreported conflicts of interest; violations of the Export Controls and Sanctions Compliance Policy; infringements to the Dealing Code" (page 176). Progress against this zero-tolerance ambition is tracked via the Investigations Department's case counts: 33 policy-violation/Code of Conduct cases investigated in 2025 (down from 69 in 2024, a change attributed to case-structure rather than a decline in activity) and 14 whistleblowing cases (up from 13 in 2024) (page 183). Effectiveness is also monitored through mandatory anti-bribery training completion, which rose to 87% of at-risk employees in 2025 from 74% in 2024 (page 181).

Incidents of corruption or bribery

Reference: page 183.

"In 2025, the Investigations team handled 33 cases of policy violations or breaches of the Code of Conduct, representing a significant decrease compared with the 69 cases investigated in 2024," a change the company attributes to 2024 having included "several investigations involv[ing] large groups of employees, with each individual recorded as a separate investigation," whereas "in 2025, only individual cases were handled" (page 183). Whistleblowing activity was broadly stable at 14 cases in 2025 versus 13 in 2024 (page 183). These figures are reported as aggregate Investigations Department case counts rather than a separately itemized count of confirmed corruption/bribery convictions or fines.

Political influence and lobbying activities

Reference: pages 184-185.

"Proximus advocates for initiatives and regulations that generate positive societal impact and sustainable economic growth," focusing lobbying on digital inclusion, digital security and responsible technology use (page 184). The Group Public Affairs department manages relationships with policymakers and industry bodies (Union Wallonne des Entreprises, Voka, BECI, Agoria); Proximus is "registered in the EU Transparency Register under ID 537380918401-76," and its lobbyists are registered in Belgium (page 184). Advocacy priorities include the EU Gigabit Infrastructure Act, coordinated cybersecurity strategy, and a harmonized data-protection/fraud-prevention framework (page 184). "The company does not make financial or in-kind political contributions, either directly or indirectly. In 2025, no political donations were made" (page 185).