Prysmian

Corporate governance structure

Reference: pages 31-35.

Prysmian applies the traditional Italian governance model: Shareholders' Meeting, Board of Directors and Board of Statutory Auditors, supported by an Independent Auditor (PwC S.p.A.).

Board of Directors (12 members, term 2024-2027): Francesco Gori (Chair), Valerio Battista (Deputy Chair), Massimo Battaini (CEO and General Manager), Pier Francesco Facchini (CFO), plus eight further directors including Jaska Marianne de Bakker, Ines Kolmsee, Emma Marcegaglia, Richard K. Palmer, Tarak Mehta, Susannah H. Stewart, Annalisa Stupenengo (Lead Independent Director) and Paolo Amato.

• 75% of directors are independent
• 7 men / 5 women (42%)
• No director under 50; eight aged 55-60, four over 60

Board committees: Control and Risks Committee (Chair Jaska Marianne De Bakker), Remunerations and Nominations Committee (Chair Richard K. Palmer), Sustainability Committee (Chair Ines Kolmsee; members Emma Marcegaglia, Susannah Stewart) - each with three non-executive, independent directors.

Also in place: Supervisory Board (Legislative Decree 231/2001), chaired by Silvano Corbella, and Board of Statutory Auditors (3 standing + 2 alternate auditors, 100% independent, chaired by Stefano Sarubbi).

Information flow to governance bodies

Reference: pages 36-38.

Prysmian's sustainability governance is structured across five functions that all feed into Board oversight:

1. Chief Sustainability, R&D & Innovation Officer and Sustainability team - Environmental Strategy, monitoring material impacts/opportunities
2. Chief Strategy Officer and Investor Relations - ESG Strategy, stakeholder engagement, Sustainability Statement preparation (also Secretary to the Sustainability Committee)
3. Chief HR & Organization Officer - social strategy
4. Administrative/Supervisory departments and Chief Reporting Officers - non-financial data collection, Integrated Report preparation
5. Communication team - ESG communication campaigns

The Sustainability Committee (three non-executive independent directors) reviews sustainability performance, ESG index rankings and CSR initiatives, and recommends the ESG strategy and goals to the Board of Directors, which approves them. In 2025 Prysmian established a new Chief Sustainability, R&D and Innovation Officer role to combine sustainability and innovation leadership.

ESG in remuneration schemes

Reference: pages 41-43.

A portion of short- and long-term variable remuneration for executive Directors and key management personnel is linked to ESG indicators.

MBO (annual, short-term): financial targets 60% weighting; ESG scorecard 20% weighting (rTSR 20%, ROCE 20%, team targets 20%, ESG 20% within the wider plan). 2025 ESG scorecard metrics (threshold/target/max):

GROW (long-term, 3-year): Performance Shares (Cumulative Adjusted EBITDA 20%, Cumulative Free Cash Flow 20%) plus Deferred/Matching Shares, where the CEO and senior management matching component carries an ESG performance condition. Both MBO and GROW zero out ESG-linked bonus in the event of a workplace fatality.

Statement on due diligence

Reference: page 43.

Prysmian maps its due diligence process against the UNGP/OECD core elements and the relevant sections of the sustainability statement:

Due diligence is anchored in the Code of Ethics, Human Rights Policy, HSEE Policy and Supply Chain and Vendor Management document. In 2025 the Compliance and Corporate Affairs teams conducted antitrust risk assessments in specific regions and Prysmian adopted an Anti-Money Laundering Policy (signed by the Board, February 2026) alongside its Export Control Policy governing enhanced due diligence on red-flag-country transactions.

Risk management and internal controls over sustainability reporting

Reference: pages 37-38, 276.

Prysmian's Enterprise Risk Management (ERM) model, aligned with COSO and ISO 31000, groups risk into five categories (strategic, operational/environmental/social/governance, legal/compliance, financial, planning/reporting). The Group Chief Risk & Compliance Officer (CR&CO) oversees the ERM process and reports periodically to the Control and Risks Committee; climate risk is jointly overseen with the Chief Sustainability, R&D and Innovation Officer.

Sustainability reporting assurance: the 2025 Consolidated Sustainability Statement underwent a limited assurance review by PwC S.p.A. under Italy's Standard on Sustainability Assurance Engagements (SSAE). In addition, Prysmian voluntarily subjected a selection of KPIs (e.g., Scope 1/2/3 GHG emissions, % women executives, % recycled content, sustainability-linked revenues) to full reasonable assurance under ISAE 3000 Revised. Data collection runs through the Group's HSEDM digital tool for environmental/H&S indicators, centrally reviewed by the HSE team.

Strategy, business model and value chain

Reference: pages 13-16.

Prysmian is a global leader in energy and digital connection solutions: direct presence in over 50 countries, 109 plants, 30 R&D centers, ~34,000 employees (HQ Milan, Italy). Regional headcount: EMEA ~17,000, North America ~10,200, South America ~3,400, APAC ~3,000.

Four operating segments: Transmission (HVDC, Submarine Power/Telecom, Offshore Specialties - TSOs, utilities, governments); Power Grid (HVAC, Power Distribution, Overhead Lines - DSOs, utilities); Electrification (Industrial & Construction, Specialties including OEM/Renewables/Elevators/Automotive/Oil&Gas/Downhole); Digital Solutions (telecoms, data centers, cloud/wireless/fiber providers).

Value chain: design/testing -> production (power, telecom, subsea cables) -> installation (incl. cable-laying vessels) -> use and maintenance. Prysmian does not operate in fossil fuels, chemical production, controversial arms, or tobacco. Strategy 'Accelerating Growth' (Capital Markets Day, March 2025) targets Net Zero across the value chain by 2035 and >55% sustainability-linked revenues by 2028.

Interests and views of stakeholders

Reference: pages 21-24.

Stakeholder engagement follows the AA1000SES (2015) standard. Key groups and engagement channels:

Institutional investors hold 76% of shares (US 31%, UK 27%, France 12%); the 2025 DMA validation drew on internal/external stakeholder input reviewed by the Sustainability Committee, Control and Risks Committee and Board of Statutory Auditors.

Material impacts, risks and opportunities

Reference: pages 26-27.

Prysmian's 2025 DMA confirmed all ten ESRS topical standards as material: E1 Climate change, E2 Pollution, E3 Water and marine resources, E4 Biodiversity and ecosystems, E5 Circular economy, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities, S4 Consumers and end-users, and G1 Business conduct. The report states: 'All topics included in the matrix are deemed material... Non-material topics were initially assessed but have been excluded from the matrix.'

E1, S1 and G1 were confirmed material for the third consecutive year as topics with 'a major influence on the Group's strategy'. Financial materiality of S3 (Affected Communities) and S4 (Consumers and end-users) increased versus 2024, linked to growing demand for HV/EHV infrastructure and submarine interconnectors. E5 (Circular Economy) and S2 (Workers in the Value Chain) remained the most material topics on both axes; E2, E3 and E4 impacts/risks/opportunities remained broadly stable versus 2024.

Process to identify and assess material IROs

Reference: pages 27-31.

The 2025 DMA was a full review, formalized in a new 'Double Materiality Assessment' Procedure, conducted in four steps:

1. Planning and context analysis - regulatory/industry review with Strategy & Investor Relations, aligned to latest EFRAG guidance
2. Impact assessment - review of the long list of impacts (actual/potential, short/medium/long-term), scored on scale, scope, irremediable character and likelihood; value chain segmented between cable production and underground/submarine installation
3. Risk and opportunities assessment - financial impact rated 1 (minor, <EUR10m) to 4 (very high, >EUR100m) against EBITDA/Free Cash Flow; a rating >=2 (moderate, EUR10-50m) was the materiality threshold
4. Consolidation, validation and integration - cross-validated by Administration and Risk Management, approved by senior management and distributed to the Board's Sustainability Committee

External references consulted: EFRAG Sector Classification Standard, SASB Materiality Finder (Electrical & Electronic Equipment, Engineering & Construction Services, Telecommunication Services).

Disclosure requirements covered

Reference: pages 8-9; ESRS Content Index pages 304-307.

Prysmian's sustainability statement covers ESRS 2 (all General Disclosures) and all five environmental (E1-E5), four social (S1-S4) and the governance (G1) topical standards in full, reflecting the outcome of the DMA that all ten topics are material. Two disclosure requirements are not included in the 2025 statement: E1-9 (anticipated financial effects from climate-related risks/opportunities) and E5-6 (anticipated financial effects from resource use and circular economy) - neither appears in the ESRS Content Index, and E1-8 (internal carbon pricing) is explicitly marked 'not applicable as the Group does not have an internal carbon pricing system.'

The reporting perimeter excludes Channell (acquired June 2025; the DMA concluded its IROs are already adequately covered and its contribution to quantitative metrics is not material) and companies exempted under Directive 2013/34/EU art. 29a(8).

Transition plan for climate change mitigation

Reference: pages 66-67.

Prysmian targets Net Zero GHG emissions across the value chain by 2035, validated by the Science Based Targets initiative (SBTi) in line with the Paris Agreement, and explicitly labelled by the Group as 'in line with the 1.5C trajectory'.

SBTi-approved targets (2019 baseline):

• Short-term (2030): -60% Scope 1&2 (market-based); -65% Scope 3
• Long-term (2035): -90% Scope 1, 2 and 3, maintained through 2050+

Four decarbonisation levers: product/solution design; decarbonisation of the supply chain; procurement and self-production of renewable energy; energy efficiency and electrification of production/installation.

2025 progress: Scope 1&2 (market-based) down 40.2% vs 2019; Scope 3 down 59.7% vs 2019. A Group Climate Transition Plan with detailed investment levers is being finalised for approval/publication in 2026. Achievement of long-term/Net Zero goals depends partly on external grid decarbonisation.

Policies related to climate change

Reference: page 79 (Policies), pages 96-97 (HSEE Policy).

Climate change mitigation and adaptation are governed by the Health, Safety, Environment and Energy (HSEE) Policy, which applies across the Group and extends to suppliers. The policy underpins pollution prevention, resource-use optimisation and the reduction of environmental impact throughout operations and products.

Governance: the Board of Directors formally approves the Group's climate ambition and decarbonisation targets (transition plan approval expected 2026); the Sustainability Committee monitors and guides climate strategy; the Remunerations and Nominations Committee approves climate-linked remuneration metrics. The Chief Sustainability Officer, working with the Chief Strategy Officer, is responsible for implementation, while climate risk is embedded in the Group's Enterprise Risk Management process under the Chief Risk & Compliance Officer.

Actions and resources for climate change

Reference: pages 80-86.

Key named actions linked to climate IROs: Transmission innovation, Power Grid innovation, Electrification innovation (product-level decarbonisation), Decarbonisation of production sites (energy efficiency, renewables, transition plan expected approval 2026), Decarbonisation of the Group's fleet of cable-laying vessels (decarbonisation plan expected approval 2026), Transport optimisation (modal shift, logistics efficiency), and Supplier engagement program (Scope 3 reduction).

Mitigation of transition risk includes an innovation roadmap, appointment of a Chief R&D, Innovation and Sustainability Officer and a Chief Digital Officer, and a Group Innovation Steering Committee. Physical-risk mitigation includes decarbonisation-linked resilience measures, local flood-protection infrastructure (dams/barriers), and a disaster-recovery/business-interruption insurance arrangement with a specialist international provider.

Targets related to climate change mitigation and adaptation

Reference: pages 86-88.

SBTi long-range targets (2019 baseline): Scope 1&2 -60% by 2030 / -90% by 2035; Scope 3 -65% by 2030 / -90% by 2035; Net Zero across the value chain by 2035.

Impact Sustainability Scorecard 2023-2025 (interim, LTI-linked):

Targets are set by the Sustainability Committee-approved Scorecard and cascaded to regional teams; a new 2026-2028 scorecard succeeds the 2023-2025 one.

Energy consumption and mix

Reference: pages 88-89 (limited assurance by PwC).

Fossil consumption is dominated by crude oil/petroleum products (376,101 MWh) and natural gas (717,838 MWh); renewable consumption includes purchased renewable electricity/heat (561,294 MWh) and self-generated non-fuel renewable energy (38,501 MWh). Conversion uses DEFRA 2025 factors. Energy figures are among the datapoints in scope of the Group's environmental reporting system (HSEDM), reviewed centrally by the HSE team.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 88-91 (Scope 1/2/3 datapoints subject to reasonable assurance by PwC).

Scope 3 is dominated by purchased raw materials (above all copper and aluminium) and network losses from product use (the Joule effect). Versus the 2019 SBTi baseline, 2025 market-based Scope 1&2 emissions are down 40.2% and Scope 3 emissions are down 59.7%. Methodology follows the GHG Protocol; a restatement in this report removed the well-to-tank emission factor from Scope 3 Category 11 calculations.

Internal carbon pricing

Reference: ESRS Content Index, page 304.

The ESRS Content Index explicitly states for E1-8: 'Internal carbon pricing - not applicable as the Group does not have an internal carbon pricing system.' No further detail or shadow-price mechanism is disclosed elsewhere in the Climate change chapter (pages 66-91). This differs from some peers that use an internal carbon price to screen capital allocation; Prysmian instead applies financial-impact rating thresholds (EBITDA/Free Cash Flow bands) in its double materiality assessment to prioritise climate-related risks and opportunities.

Policies related to pollution

Reference: pages 96-97.

Pollution is governed by the HSEE Policy (Health, Safety, Environment and Energy), which commits Prysmian to mitigating negative impacts on air, water and soil through pollution prevention/control and continuous monitoring, and to substituting/minimising substances of concern, especially for non-essential uses. The environmental management system underpinning the policy is ISO 14001 certified at 96% of production plants.

Note: the DMA found E2 material on impact materiality only - 'the financial materiality assessment did not identify material risks and opportunities related to ESRS E2 Pollution' - so E2 disclosures focus on impact management rather than financial risk/opportunity management.

Actions and resources related to pollution

Reference: pages 97-99.

• Selective Catalytic Reduction (SCR) system on cable-laying vessels (Ulisse, Leonardo da Vinci, Monna Lisa, Marco Polo, Alessandro Volta, Cable Enterprise): reduces vessel NOx emissions by up to 90% by converting them to nitrogen and water.
• Monitoring of pollutants emitted by operational units: since 2024, a Group procedure ('Assessment of Air and Water Pollutants', formalised 2025) categorises sites by NOx/SOx monitoring status; only NOx emissions were material at Group level in 2025.
• Substitution of substances of concern: lead-free sheathing for extruded land cables (qualified up to 400kV AC/525kV DC); phase-out plans for PFAS, MCCP (plasticiser) and TPO fibre coatings.

CapEx/OpEx for substance substitution is classified as confidential and not disclosed.

Targets related to pollution

Reference: page 100.

Prysmian has not set a single quantified Group-level pollution reduction target; instead, each business unit sets targets and action plans under the HSEE Policy and its ISO 14001-certified environmental management system (96% of plants certified). For substances of concern, the Group runs a substitution programme through 2028 (excluding metallic lead in undersea applications, pending recognised international standards for alternatives). Planned next steps are to (A) set improvement goals, (B) boost monitoring of processes/indicators, and (C) report the effectiveness of policies and actions on material pollution-related IROs.

Pollution of air, water and soil

Reference: pages 100-103.

NOx is quantified at Group level from fuel-consumption data and EMEP/EEA and Ecoinvent emission factors, cross-checked against direct measurements at representative sites (Arco Felice, Pignataro, Douvrin). Prysmian states no accidental spills occurred in 2025, so direct soil pollution was zero; water discharges at Italian plants are monitored under Single Environmental Authorization requirements.

Substances of concern and substances of very high concern

Reference: pages 101-103.

Total substances of concern and very-high-concern generated/used in production: 29,291 tons (2025) vs 26,048 tons (2024). Lead is the largest single component (23,721 tons in 2025 vs 25,101 tons in 2024), used in metallic form, lead oxide/tetroxide and lead-based pigments. Other tracked substances include medium-chain chlorinated paraffins (MCCP, 338 tons), boric acid, and (newly flagged for 2025) DBDPE (1,1'-(ethane-1,2-diyl)bis[pentabromobenzene], <2,500 tons). Solvents (used in cable marking inks and washing/maintenance) are monitored via the HSEDM digital tool; NMVOC emissions are treated as equal by weight to total solvents used.

Policies related to water and marine resources

Reference: page 108.

Water management sits under the HSEE Policy, which commits Prysmian to optimising consumption of water and raw materials and preventing pollution across plants, including those in water-stressed areas. Prysmian also references its Supply Chain and Vendor Management document to manage upstream water-related impacts (see ESRS S2). Note: financial materiality for E3 was assessed as 'Not material' - only two negative impacts (own-operations water use; upstream water use in base-metal processing) drive E3's materiality.

Actions and resources related to water and marine resources

Reference: pages 108-109.

• Mitigation plan and recirculation systems: new installations use closed-loop cooling by design; existing plants increase recirculated-water share where feasible. Analysis of 92% of production units shows ~77% are equipped with recirculation, with reuse rates above 90%.
• Water collection and metering systems: local wastewater collection/treatment before discharge to sewers or surface water; sites with 100% recirculation discharge nothing beyond evaporation losses.

In 2025 Prysmian upgraded its environmental-data collection/validation procedures and integrated water indicators into its ESG monitoring tools, with internal training to raise employee awareness. Neither project required significant CapEx/OpEx.

Targets related to water and marine resources

Reference: page 110.

Prysmian states: 'No water management targets have been set at Group level' - responsibility for reducing abstraction and increasing recirculation sits with each business unit, using site-level meters to track consumption in absolute terms and relative to production. Water is managed within the HSEDM system; 96% of Group sites hold ISO 14001 certification, which the Group states ensures the majority of plants manage water issues via certified systems, with progress tracked centrally by the HSE team.

Water consumption

Reference: page 111.

Water consumption is assumed equal to volume abstracted, measured via meters or water reports, and reported through the common HSEDM database (except Warren & Brown and Channell, on off-system estimates pending HSEDM integration in 2026). 92% of volumes are from direct measurement/extrapolation/sampling or best estimates.

Biodiversity strategy and Net Gain target

Reference: pages 115-117.

In 2025 Prysmian ran a resilience analysis of 100+ production plants using the WWF Biodiversity Risk Filter, identifying 18 sites with potentially material biodiversity risk, followed by TNFD LEAP (Locate, Evaluate, Assess, Prepare) analysis extended to onshore/offshore installation projects. Tools used: Aqueduct, IBAT, ENCORE, WWF Risk Filter.

Prysmian has set a target to apply a Net Gain approach to all priority installations by 2035 - ensuring ecosystem condition after installation is better than before, via a mitigation hierarchy (avoid, minimise, restore, offset). A compliance procedure for new installations is under development. In 2026 the LEAP approach will be extended to the supply chain. Prysmian was among the first manufacturers globally to adopt the TNFD framework.

Policies related to biodiversity and ecosystems

Reference: page 122.

Biodiversity governance is embedded in the Group's overall governance: the ecosystem/biodiversity strategy is proposed by the Chief Sustainability Officer, reviewed by the Sustainability Committee, and approved/monitored by the Board of Directors. Actions already taken - protection of Posidonia oceanica (Mediterranean seagrass), management of Special Protection Areas (SPAs), and minimising disturbance to marine mammals - flow directly from the Group's biodiversity materiality assessment. Site-specific Biodiversity Action Plans (BAPs) are developed for priority sites and installations identified through the WWF Risk Filter/LEAP process.

Actions and resources related to biodiversity and ecosystems

Reference: pages 122-125.

Project-level biodiversity mitigation is embedded in cable installation contracts. Documented examples include the NeuConnect interconnector (Isle of Grain, UK - great crested newt habitat, protected bird species) and the Bay of Biscay project (Le Verdon, France - protected frog and orchid species), each with species-specific impact assessments covering habitat fragmentation, disturbance and population effects. Offshore/onshore installation techniques assessed for biodiversity impact include dredging, jetting and trenching. Measures to protect threatened species and mitigation for undesirable events are integrated into project contracts as required by relevant authorities.

Targets related to biodiversity and ecosystems

Reference: pages 125-127.

The Group's primary quantified biodiversity target is to extend a Net Gain approach to all priority installations by 2035, applying the mitigation hierarchy (avoid, minimise, restore, offset) so that habitats, species and ecological functions are left in better condition than before each project. Supporting milestones include completing the LEAP-based prioritisation of the 18 biodiversity-risk sites identified via the WWF Risk Filter, and extending LEAP analysis to the supply chain from 2026. No interim numeric targets (e.g., hectares restored) were disclosed in the sections reviewed.

Impact metrics related to biodiversity and ecosystems change

Reference: pages 118-121.

Prysmian's biodiversity IROs are structured around direct impact drivers of biodiversity loss and impacts on ecosystem extent/condition:

• Land degradation/desertification from installation activities (own operations, potential, medium/long term)
• Biodiversity loss from climate change via value-chain GHG emissions (potential, long term)
• Land-use change from copper/bauxite mining (upstream, potential, medium/long term)
• Land degradation from industrial activity (upstream, own operations and downstream, actual, long term)

No dedicated quantitative impact metric (e.g., area of habitat affected) beyond the count of 18 biodiversity-risk sites and the qualitative species-level assessments (NeuConnect, Bay of Biscay) was found in the sections reviewed.

Policies related to resource use and circular economy

Reference: pages 133-139.

Circularity is governed by the HSEE Policy, aimed at reducing environmental impact across the product life cycle, cutting virgin raw-material use, and recovering/reusing materials (particularly copper, aluminium, plastics and cable components). The strategy is aligned with the European Green Deal and international circular-economy principles. Implementation runs through certified recycled products, sustainable packaging, and partnerships for circular-economy innovation, spanning R&D, supply chain and production functions.

Actions related to resource use and circular economy

Reference: pages 133-139.

• Recycled copper/PE jackets and low-carbon aluminium: EUR3m CapEx (2024) across 13 European/Turkish factories for recycled-PE jacket capacity; growing r-Cu and r-PE use; low-carbon aluminium sourced using industry-standard CO2 values.
• Bioplastics: Afumex Green bio-based/bio-attributed PE range (Brazil, 10+ years), with carbon footprints as low as -1.5 kg CO2/kg versus ~2-2.5 kg CO2/kg for conventional plastics.
• P-Laser technology: fully recyclable insulation (~34% lower lifecycle carbon footprint vs XLPE/EPR); EUR180m France capacity expansion (2022-2027) and a EUR20m southern-Europe compounding plant (due 2028).
• Reuse of reels: 53% of shipping reels reused in 2025 (73.9% wood, 26.1% metal/plastic); Alesea smart-reel platform covers ~5% of cable-sales turnover.
• Design To Cost (DTC) programme: >EUR50m savings, 1,400+ projects completed in 2025.
• Zero Landfill Waste Management: Heredia (Costa Rica) plant achieved Gold-level Zero Waste Management System certification in 2025; Bogota (Colombia) sent <2% of waste to landfill.

Targets related to resource use and circular economy

Reference: page 141.

*44.2% excludes Channell; including Channell, 43.7%. The recycled-content KPI is part of the Impact Scorecard 2023-2025 and the Long-Term Incentive Plan; 2025 overshoot versus target was influenced by higher US copper volumes (Encore acquisition) and a domestic copper-scrap surplus following 2025 US copper tariffs. Progress is reviewed quarterly.

Resource inflows

Reference: pages 142-147.

Main inflows: copper, aluminium, plastics/polyethylene, and cable components. Prysmian is increasing use of recycled polyethylene (r-PE) and recycled copper (r-Cu), and low-carbon aluminium sourced from suppliers using renewable energy in smelting/rod production. Share of recycled content in PE jackets and copper reached 21.3% in 2025 (2024: 16.2%; 2022 baseline: 10%), against a 2025 target of 13.4%-15.7% - exceeded, partly due to a 2025 US copper-scrap surplus following copper tariffs. Regular copper suppliers (>99% of primary copper purchased) are assessed and qualified for recycled-content options; R&D validates recycled-material compatibility ahead of deployment at scale.

Resource outflows

Reference: pages 142-147.

Outflow-related KPIs: sustainability-linked revenues reached 44.2% of total revenue in 2025 (2024: 43.1%; 2022 baseline: 30%; 2028 target: 55%), covering products meeting E Path, E3X, Green Overhead Lines, Green Al Rod & Strip, Sirocco and Transmission BU criteria. P-Laser cables are ~100% recyclable at end-of-life. Reel reuse reached 53% of shipping reels in 2025 (73.9% wood, 26.1% metal/plastic/other), supported by the Alesea smart-reel tracking platform (~5% of cable-sales turnover in 2025). Resource-outflow data uses the same Material Flow methodology as inflows.

Waste

Reference: pages 141-142.

Main waste streams are copper, aluminium, plastic, rubber and insulating-material residues, plus cable scrap. The Zero Landfill programme (Latin America) has roughly a third of sites at the 0-5% landfill target and a further third at 6-20%; Heredia (Costa Rica) achieved Gold-level Zero Waste Management System certification in 2025.

Policies related to own workforce

Reference: pages 152, 158-164.

Prysmian's people policies cover: Code of Ethics; Human Rights Policy (aligned to UNGPs/OECD Guidelines); Fair Employment/anti-discrimination principles; Occupational Health & Safety; SpeakUp/Helpline whistleblowing (aligned with EU Directive 2019/1937); Diversity & Inclusion. Oversight sits with the HR & Organization team and Group Risk & Compliance team, with H&S managed by the central HSE team; the Sustainability Committee reviews progress and reports to the Board of Directors. In 2025 a new five-year occupational health and safety strategy was validated. The DMA found S1 material on both impact and financial materiality axes.

Engaging with own workers and their representatives

Reference: page 152.

Engagement channels include the global business climate survey and feedback collected at key points in the employee lifecycle, feeding a continuous improvement process. Prysmian has expanded leadership/management training for operating in complex, multicultural environments, and strengthened work-life balance and internal-mobility programmes. Health and safety engagement operates through a Group HSE team with a cascade of regional HSE directors, supported by committees and periodic consultation/communication procedures giving employees clear channels to raise comments on material impacts, risks and opportunities affecting them.

Remediation processes and concern channels

Reference: page 152 (Governance); Helpline Policy detail cross-referenced in ESRS G1.

Employees can raise concerns via the Group's Helpline/SpeakUp channel, which guarantees anonymity/confidentiality, prohibits retaliation, and is supported by independent Compliance-team investigations with replies and case closure targeted within three months. In 2025, 234 complaints were filed through own-workforce grievance channels (2024: 174). Discrimination-related incidents reported in 2025 totalled 18 (2024: 24), spanning gender, racial/ethnic origin, nationality, religion, disability, age, sexual orientation, harassment and other categories, with EUR0 in fines/penalties/compensation recorded against these cases.

Actions on material impacts on own workforce

Reference: pages 152-181 (Own workforce actions).

Named actions include: Own Workforce Safety 'Zero & Beyond'; traffic-management procedures at installation sites; anti-collision technology upgrades for the forklift fleet; corporate security activities and a Safety Academy; wellbeing/mental-health activities; performance and talent management; human rights due diligence and audits; talent-attraction activities and the 'Build the Future' graduate programme; training and development programmes; IT security integrity assessment; pay-equity assessment and monitoring; labour-union relations management; a SpeakUp survey; and employee stock ownership plans. These map to the material IROs identified for privacy, health & safety, forced labour, working time, wages, social dialogue, freedom of association and gender equality.

Targets related to own workforce

Reference: page 179-181 (Impact Scorecard).

Targets are embedded in the Impact Sustainability Scorecard 2023-2025, linked to short- and long-term incentive plans and cascaded through regional teams.

Characteristics of the undertaking's employees

Reference: page 187 (Workforce details).

Headcount is measured on a December year-end basis and excludes Channell (acquired June 2025, outside the reporting perimeter for 2025). The Group-level 'approximately 34,000 employees' figure cited elsewhere in the report includes Channell's ~953 headcount. A full country-by-country breakdown is disclosed in the Workforce details note.

Characteristics of non-employee workers

Reference: page 187.

Non-employee workers in Prysmian's own workforce include agency/contingent workers and interns/apprentices working under Prysmian's direction and control, captured alongside permanent and temporary employees in the S1-6 headcount tables. The Occupational Health & Safety Policy explicitly extends coverage to contractors and third-party workers at Group sites; H&S metrics (e.g. the safety strategy validated in 2025) are designed to cover both employees and non-employees, including a mechanism zeroing MBO/GROW ESG bonuses Group-wide in the event of a fatal accident involving either an employee or non-employee.

Collective bargaining coverage and social dialogue

Reference: page 185.

Social dialogue and workers' representation are managed at country/regional level in line with local regulation, with labour-union relations management identified as a specific action area (page 191) alongside a 2025 SpeakUp Survey used to monitor engagement and the Leadership Impact Index (57% in 2025). The DMA identifies 'lack of social dialogue' and 'lack of freedom of association' as potential negative impacts within own operations, addressed through the Group's Fair Employment and Human Rights policies and local labour-relations management processes.

Diversity metrics

Reference: page 186.

Both KPIs are part of the audited Impact Scorecard and subject to reasonable assurance by PwC. 'Women in executive roles' (target 20-23%) is also a 2025 MBO incentive metric. Diversity policy commitments extend to age, disability, LGBTQ+ inclusion and equal treatment, referenced through the Diversity & Inclusion focus of the Fair Employment Policy and the Human Resources targets programme (page 191).

Adequate wages

Reference: pages 187, 192.

The report addresses wage adequacy primarily through the gender pay gap lens rather than a separate living/adequate-wage benchmark disclosure: the unadjusted gender pay gap was 6.82% in 2025 (2024: 9.03%), and the adjusted gender pay gap for Desk Workers, measured via the Pay Eq (Syndio) platform introduced in 2024, was 2.9% in 2025 against a 2030 target of 0-2 percentage points. The DMA also flags 'inadequate wages affecting employees' living standards, wellbeing and productivity' as a potential negative impact within own operations (own operations, potential, short term), addressed through Fair Employment Policy commitments.

Social protection

Reference: page 188-189.

Social protection coverage (unemployment, illness, employment injury/disability, parental leave, retirement) is provided through a combination of statutory country schemes and Group benefits, tracked in the Workforce details note. On family-related leave specifically, 100% of employees are eligible for maternity/paternity/parental leave, and 74-100% are eligible for caregivers' leave depending on gender/category. In 2025, 1,237 employees took maternity/paternity/parental leave and 437 took caregivers' leave, versus 655 combined family-leave takers assessed the prior year on a comparable basis.

Persons with disabilities

Reference: page 218-220 area (Diversity, Inclusion and Well-being).

Prysmian's Diversity & Inclusion and Fair Employment policies prohibit discrimination on the basis of disability and commit to an inclusive workplace. The report does not disclose a Group-level headcount percentage of employees with disabilities in the sections reviewed; disability is tracked as one of the discrimination-incident categories under S1-17 (1 disability-related discrimination incident reported in 2025, versus 2 in 2024), reflecting the sensitivity of self-identified disability data across the Group's diverse operating geographies.

Training and skills development metrics

Reference: pages 191, 217 (Training and development programmes).

Named programmes: the 'Build the Future' graduate programme; broader training-and-development programmes; talent-attraction activities; and personnel upskilling identified as a material positive impact in the S1 IRO table (own operations, actual, short term). Training also covers compliance topics relevant to the workforce (Gifts & Entertainment, Conflict of Interest, Third Party/Public Admin, Law 231, Compliance Awareness), which together delivered 7,692 total training hours in 2025 (2024: 9,511) and 25,314 total participations (2024: 19,087) across compliance-specific curricula alone.

Health and safety metrics

Reference: pages 152, 191 (Safety Assessment Plan; five-year OHS strategy).

In 2025, Prysmian validated a new five-year occupational health and safety strategy covering both employees and non-employees. The Safety Assessment Plan (scoring plant safety-management-system maturity) moved from 3.4 (2022) to 4.01 (2024), against a 2025 target range of 2.75-5. Named H&S actions: Own Workforce Safety 'Zero & Beyond'; traffic-management procedures and mitigation measures at installation sites; anti-collision technology for the forklift fleet; corporate security activities; and a Safety Academy. H&S risk (failure to foster a safety culture, leading to injuries, legal costs and reputational damage) is identified as a material financial risk in the S1 IRO table.

Work-life balance metrics

Reference: page 189-190.

Work-life balance is also promoted as a material positive impact in the S1 IRO table (own operations, actual, medium/long term) and via flexible-work initiatives referenced in the 2025 people strategy, aimed at improving retention, talent attraction and lowering recruitment costs.

Compensation metrics (pay gap and total compensation)

Reference: pages 190-191.

The 2025 jump in CEO pay/pay ratio mainly reflects IFRS2 (share-based) values in the final vesting year of the 2023-2025 long-term incentive plan. Prysmian targets a 0-2 percentage point adjusted gender pay gap for Desk Workers by 2030.

Incidents, complaints and severe human rights impacts

Reference: page 192.

Discrimination incidents in 2025 break down as: gender (4), racial/ethnic origin (5), nationality (1), disability (1), age (1), sexual orientation (2), harassment (1) and other (3). Prysmian states it 'did not identify any cases of human rights incidents among its workforce during the reporting period,' with zero cases of non-respect of the UNGPs, ILO Declaration or OECD Guidelines.

Policies related to value chain workers

Reference: pages 199, 202-205.

Value-chain worker protections are set out in the Code of Ethics, Human Rights Policy, Code of Business Conduct, Conflict Minerals Policy, and the Helpline Policy/whistleblowing platform, cross-referenced from S1. Governance sits with the Sustainability Committee (periodic progress reports) and an operational cross-functional team spanning Investor Relations, Procurement, Sustainability, Sales and Compliance; the Procurement team owns upstream engagement and the Sales team owns downstream engagement. Prysmian highlights heightened due-diligence attention on mining regions including Asia, Afghanistan, the Democratic Republic of Congo and Latin America.

Engaging with value chain workers

Reference: pages 205-208.

Engagement is delivered through supplier-facing programmes: Human rights due diligence, participation in the Copper Mark Initiative, the Supplier Engagement Program, and the annual Supplier Conference (2025 edition held). Attention is specifically focused on categories most exposed to risk: mining/logistics workers in hazardous conditions, cable-installation workers (working at height, heavy equipment, electrical hazards), and vulnerable groups (migrants, women, youths, labour unionists, remote workers). In 2025 Prysmian strengthened internal audit systems and whistleblowing channels covering the value chain.

Remediation and concern channels for value chain workers

Reference: pages 205-208.

Value chain workers can raise concerns via the same Helpline/whistleblowing platform used for own-workforce concerns (see S1-3), supplemented by supplier-facing due-diligence mechanisms: Human Rights due diligence, the Copper Mark Initiative and the Supplier Engagement Program. Prysmian states it 'deploys a robust due diligence process' focused on regions where raw materials are extracted (Asia, Afghanistan, DRC, Latin America), given identified risks of forced/child labour, inadequate pay and unguaranteed working hours linked to mining and subcontracted logistics activities.

Taking action on material impacts on value chain workers

Reference: pages 202-208.

Named actions/targets linked to value-chain worker IROs: Human rights due diligence; participation in the Copper Mark Initiative; the Supplier Engagement Program; and the 2025 Supplier Conference, all aimed at maintaining or increasing the number of sustainability audits in the supply chain. These map to identified negative impacts including occupational H&S exposure, inadequate worker protection with subcontractors, restricted freedom of association, gender inequality, child/forced labour and inadequate remuneration - concentrated upstream in raw-material extraction and logistics.

Targets for value chain workers

Reference: page 209.

Desk/risk-analysis scope covers all metals suppliers with recurring spend, raw-material suppliers with >EUR100,000 annual turnover, selected indirect-material suppliers (by country/category) and relevant high-voltage installation suppliers. Prysmian states these targets are based on internal observation rather than external scientific methodology, and have not yet been revised since being set.

Policies related to affected communities

Reference: pages 219-220.

Community-facing conduct is governed by the Code of Ethics and Human Rights Policy, supplemented by a Donations Policy (introduced 2019, updated November 2023) setting eligibility criteria, guiding principles, and disbursement/monitoring/reporting procedures for community donations. Prysmian also references its WASH Pledge commitments and a Local Needs Assessment (LNA) methodology, using national statistical data (average age, unemployment rate, crime rate) to identify where community support is most needed around Group sites and installation projects.

Engaging with affected communities

Reference: pages 220-226.

Prysmian's community-engagement approach follows four steps: (1) risk identification and assessment via a Local Needs Assessment using national statistical data; (2) local community engagement through public events (workshops, fairs, consultations) with communities, interest groups and authorities; (3) emergency management plans and corrective measures developed with local authorities where issues arise; and (4) sustainability/social-responsibility follow-through with transparent, regular updates to affected communities, customers and subcontractors on project developments and remedies.

Remediation and concern channels for affected communities

Reference: pages 220-226.

Communities can raise concerns through the Group's Helpline Policy channels, which Prysmian states protect anonymity/confidentiality and prohibit retaliation, with independent Compliance-team investigations (online, phone or in-person reporting; replies provided promptly; investigations targeted for closure within three months). Where hardship or discontent arises during cable-laying (e.g. affecting fisherfolk), Prysmian's Local Needs Assessment and emergency-management-plan process (see S3-2) is the primary remediation route, alongside WASH Pledge implementation.

Taking action on material impacts on affected communities

Reference: pages 220-227.

Named actions: developing innovative products/solutions to support communities; partnerships for training young students (including the NeuConnect project's schools training); WASH Pledge implementation; and initiatives on access/access to electricity from renewable sources and fast digital connectivity. These respond to identified impacts - positive impacts from electrification/digitalisation and community empowerment through donations/training - and to the identified risk of hardship/discontent during cable-laying operations (e.g., disruption for fisherfolk), managed via Local Needs Assessments.

Targets for affected communities

Reference: page 227; Impact Scorecard (page 18).

Both KPIs are part of the Impact Sustainability Scorecard 2023-2025 and are estimated from installed capacity (PV, onshore/offshore wind, interconnections) and FTTH/FTTB/DOCSIS 3.0 product deployment respectively. Both targets were substantially exceeded in 2025.

Policies related to consumers and end-users

Reference: page 233.

Consumer/end-user conduct is governed by the Code of Ethics and Human Rights Policy, referenced against OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Policies are integrated into product development, marketing and management to ensure consumer rights are respected across the product life cycle. The DMA found S4 material on financial materiality (opportunities/risk) grounded in the single sub-topic 'Social inclusion of consumers and/or end-users,' with its financial materiality increasing versus 2024 due to growing demand for HV/EHV infrastructure and submarine interconnectors.

Engaging with consumers and end-users

Reference: pages 236-241.

Engagement is led by the four global business-unit heads and their sales teams, with Chief Commercial Officers overseeing regional/country customer relationships aligned to the Group's global strategy. Tools include online customer experience surveys, digital channels/tools for gathering customer feedback, and Communication-team channels (print, web, publications) explaining Prysmian's role in the energy transition. Advanced digital systems integrate customer feedback into specific KPIs used to continuously improve products, services and business relationships.

Remediation and concern channels for consumers and end-users

Reference: pages 236-241.

Consumers/end-users can raise concerns through the tools and channels for gathering customer feedback and online customer experience surveys referenced in S4-2, underpinned by the Code of Ethics and Helpline Policy. Prysmian confirms no serious human rights issues or incidents related to consumers and/or end-users were reported in 2025. The identified risk of a lack of transparency in marketing practices is mitigated through these same feedback channels plus intellectual property protection processes.

Actions on consumers and end-users

Reference: pages 236-241.

Named actions: design of safe and fire-resistant cables; development of innovative monitoring solutions; and a broader 'product quality: safety, sustainability and customer proximity' programme. These respond to two identified opportunities - strengthening network resilience/security (driving demand for standard cables plus specific products such as EOSS monitoring, Elaspeed-S couplings, the E3X robot conductor and HTLS conductors) and building renewable-energy/circular-economy partnerships - and to the identified risk of insufficiently transparent marketing practices, managed via the Code of Ethics and Helpline Policy.

Targets for consumers and end-users

Reference: page 241.

No dedicated numeric S4 target beyond the Group's shared community/connectivity metrics was identified in the sections reviewed: households provided with fast digital access reached 20.6 million in 2025 (2024: 17.1 million; 2025 target 9-15 million, exceeded), which Prysmian also reports under S3 as it addresses both affected-communities and consumer/end-user social-inclusion outcomes via network expansion (see S3-5). No separate quantified target for marketing-transparency risk management or customer-satisfaction scores was found.

Business conduct policies and corporate culture

Reference: pages 251-259.

Prysmian's business-conduct framework includes: Code of Ethics; Antitrust Policy; Export Control Policy; Anti-Money Laundering (AML) Policy (Board-signed February 2026); and a new Artificial Intelligence Policy (approved by the CEO and Board, October 2025), covering AI-system taxonomy, key risks (bias, privacy violations, misinformation, IP impacts), responsible-AI principles, and use rules, reviewed with the CISO, Security & AI Committee and Control and Risks Committee. A cross-functional AI Governance Committee was created in 2025. Compliance training (Gifts & Entertainment, Conflict of Interest, Third Party/Public Admin, Law 231) is required for all functions; completion rate for online anti-bribery training was 90% in both 2025 and 2024.

Management of relationships with suppliers

Reference: pages 259-260.

Supplier payment management follows five principles: clear/defined payment terms in contracts (including for SMEs); an automated invoice-management system for real-time monitoring; proactive communication and problem-solving; ongoing performance monitoring via financial reporting tools; and compliance with local/international payment regulation (e.g., EU Directive 2011/7/EU). Responsibility is split between the Administration team (recording/validating/settling invoices) and the Procurement team (supplier dialogue, contract-condition resolution), with Internal Audit conducting periodic checks, and particular attention paid to SMEs' cash-flow vulnerability.

Prevention and detection of corruption and bribery

Reference: pages 260-261.

Prysmian maintains ISO 37001 (Anti-Bribery) and ISO 37002 (Whistleblowing) certifications. The 2025 Compliance Program included: revision/modernisation of the Code of Business Conduct; an Antitrust Compliance Program update with continued risk assessment in Brazil, Turkey and Oman; preparation of a Group-level Anti-Money Laundering Policy; risk mapping under the UK Fraud Prevention Regulation and China's Personal Information Protection Law; and revision of the Human Rights Policy. Online training on anti-bribery topics is required for all functions, with onsite training on antitrust/export-control/Helpline-channel use in higher-risk regions.

Incidents of corruption or bribery

Reference: page 266.

Prysmian states: 'No incidents related to bribery and corruption were reported during the year.' Completion rate for online anti-bribery training was 90% in 2025 (2024: 90%). Supporting compliance-training volumes in 2025 totalled 7,692 training hours delivered and 25,314 training participations (2024: 9,511 hours / 19,087 participations) across topics including Gifts & Entertainment (7,131 participations), Conflict of Interest (6,864) and Third Party/Public Administration relations (7,150, a new module introduced in 2025).

Political influence and lobbying activities

Reference: page 272.

Prysmian states it 'does not systematically engage in direct lobbying' but participates in public debate through trade/industry bodies on: sustainable finance, sustainable mobility, reduction of plastic pollution, green technologies, and European environmental policy (Energy Performance of Buildings Directive, Euro 7 Regulation, Net Zero Industry Act). The Group is enrolled in the EU Transparency Register; fees payable to trade bodies were EUR2.769 million in 2025 (2024: EUR1.692 million). No member of the Group's administrative, management or supervisory bodies held a public-administration position in the two years preceding the reporting year.

Payment practices

Reference: pages 259-260, 272.

Payment-practice management (see G1-2) is built on clear contractual payment terms, an automated invoice system for real-time monitoring, and compliance with payment-timing regulation such as EU Directive 2011/7/EU, with particular attention to protecting SME suppliers' cash flow. No Group-level average-days-to-pay or late-payment-percentage metric was found disclosed in the sections reviewed; oversight is split between the Administration team (invoice processing/settlement) and Procurement team (supplier relationship management), audited periodically by Internal Audit.