Roche

Board of Directors

Roche Board of Directors on 31 December 2024:

• Dr Severin Schwan (1967), Chairman, D*, E
• André Hoffmann (1958), Vice-Chairman, representative of the shareholder group with pooled voting rights, A*, C, D, E, G
• Dr Jörg Duschmalé (1984), representative of the shareholder group with pooled voting rights, B, C*, E, G
• Dr Patrick Frost (1968), B*, E, G
• Anita Hauser (1969), C, D, E, G
• Prof. Dr Akiko Iwasaki (1970), A, E, G
• Prof. Dr Richard P. Lifton (1953), C, E, G
• Dr Jemilah Mahmood (1959), A, E, G
• Dr Mark Schneider (1965), B, E, G
• Dr Claudia Suessmuth Dyckerhoff (1967), A, B, E, G

Committee Structure:

• A: Corporate Governance and Sustainability Committee
• B: Audit Committee
• C: Remuneration Committee
• D: Chairman's/Nomination Committee
• E: Non-executive director
• F: Executive director (currently no member)
• G: Independent member of the Board of Directors
• *: Committee chairperson

Corporate Executive Committee

Roche Corporate Executive Committee on 31 December 2024:

• Dr Thomas Schinecker (1975), CEO Roche Group
• Teresa Graham (1973), CEO Roche Pharmaceuticals
• Matt Sause (1977), CEO Roche Diagnostics
• Dr Alan Hippe (1967), Chief Financial and Information Officer
• Cristina A. Wilbur (1967), Chief People Officer
• Claudia Böckstiegel* (1964), General Counsel
• Prof. Dr Hans Clevers* (1957), Head Roche Pharma Research and Early Development (pRED)
• Dr Levi Garraway* (1968), Head Global Product Development and Chief Medical Officer
• Silke Hörnstein* (1975), Head Corporate Strategy and Sustainability
• Dr Aviv Regev* (1971), Head Genentech Research and Early Development (gRED)
• Barbara Schädler* (1962), Head Group Communications
• Boris Zaïtra* (1972), Head Corporate Business Development

*Member of the Enlarged Corporate Executive Committee

Governance of Sustainability

The Board of Directors oversees sustainability matters through the Corporate Governance and Sustainability Committee. Sustainability is integrated into our corporate strategy and is overseen by our Chief Sustainability Officer, Barend van Bergen, working with Silke Hörnstein, Head Corporate Strategy and Sustainability and member of the Enlarged Corporate Executive Committee.

Our Corporate Sustainability Steering Committee is responsible for assessing social, environmental, economic and governance trends that could impact our business through our business environment risk and opportunity assessment process.

Information provided to governance bodies

The Corporate Sustainability Steering Committee is responsible for assessing social, environmental, economic and governance trends that could impact our business. This is achieved through our business environment risk and opportunity assessment process.

We identify long-term business environment trends and the associated risks and opportunities on an annual basis, and integrate these into our Group risk management process. Each year, emerging trends (and their associated risks and opportunities) are identified from internal and external sources and are reviewed by selected internal stakeholder groups. Our Corporate Sustainability Steering Committee then evaluates and selects the ten trends most relevant to Roche.

Roche's top ten business environment trends in 2024:

1. Accelerated technological transformation
2. Increase in infectious diseases and chronic and mental illnesses
3. Progressing cyberdependency and vulnerability
4. Lasting economic instability
5. Political complexity and geoeconomic confrontations
6. Societal crises
7. Growing need for climate change adaptation
8. Accelerated spread of mis- and disinformation
9. Healthcare evolution challenged by its affordability
10. Future of work

The Board of Directors annually reviews a consolidated Group Risk Report covering all material risks and opportunities, which is discussed with the Corporate Executive Committee.

Due Diligence Statement

Roche conducts due diligence to ensure risks are mitigated and managed across our operations and value chain. We have policies in place as well as a risk management approach to prevent, detect and mitigate risk of potential infringement on human rights and its adverse impacts, including the assessment of whether there are reasonable grounds to suspect child labour.

Risk Management Process: Our Pharmaceuticals and Diagnostics Divisions and global functions conduct a formal risk and opportunity assessment at least once a year and must develop response plans for their most material risks and opportunities. The effectiveness of Roche's risk management process is regularly monitored by the Group Risk Advisory team. The overall process is reviewed by the Audit Committee of the Board of Directors and also externally when appropriate.

Supply Chain Due Diligence: We communicate our expectations to suppliers through the Roche Supplier Code of Conduct. We assess suppliers failing to provide equal pay for work of equal value and suppliers failing to provide a workplace free of harsh treatment, harassment and discrimination.

Human Rights Due Diligence: Roche upholds human rights principles across our own operations and our value chain. In a globalised world, business value chains often span across international borders, giving millions of people an opportunity to participate in the global economy; however, this also brings challenges to ensuring workers' human rights. We have implemented processes to identify, prevent, mitigate and account for actual and potential adverse impacts.

Risk Management and Internal Controls

Risk Management Framework: Risk and opportunity management is embedded into our business practices at all levels of the Roche Group. Our Risk Management Policy outlines Roche's approach to identifying, analysing, managing and reporting material risks and opportunities.

Our approach is formalised within the Group risk management process, which establishes how our divisions and Group functions assess risks and opportunities and develop response plans for the most material ones identified. This happens in parallel to the development of our business plans.

Sustainability Risk Management: Through our business environment risk and opportunity assessment process, we identify and assess the impact of environmental, social, economic and governance trends. The Corporate Sustainability Steering Committee evaluates and selects the ten trends most relevant to Roche annually.

Internal Controls: The Group Risk Advisory team fosters best practice by raising awareness of the importance of risk and opportunity management through educational initiatives including online training targeted at all employees, as well as practice labs and customised training for line managers and risk and opportunity managers.

Oversight: The effectiveness of Roche's risk management process is regularly monitored by the Group Risk Advisory team. The overall process is reviewed by the Audit Committee of the Board of Directors and also externally when appropriate. A consolidated Group Risk Report covering all material risks and opportunities is discussed with the Corporate Executive Committee and reviewed by the Board of Directors annually.

Strategy, Business Model and Value Chain

Our Purpose: Doing now what patients need next

We believe it is urgent to deliver medical solutions right now – even as we develop innovations for the future. We are passionate about transforming patients' lives. We are courageous in both decision and action. And we believe that good business means a better world.

Our Ambition: With our combined strength in Diagnostics and Pharmaceuticals we are uniquely positioned to lead the way in addressing healthcare challenges. Our ambition is clear: to prevent, stop and cure diseases, and by doing so, improve people's health while significantly reducing costs for patients and healthcare systems worldwide.

Our Business Model:

Our focus: Fitting treatments to patients Our distinctiveness: Excellence in science
Our delivery: Value for all stakeholders Our leadership: Inspiring outcomes that matter Our ways of working: Agile and networked Our set-up: Built for innovation

Strategic Priority Areas: Our shared priority areas across the Diagnostics and Pharmaceuticals Divisions are oncology, neurology and cardiovascular-metabolic diseases. By 2035, they will account for almost half of the global disease burden.

Value Chain: With our deep understanding of diseases, we will continue to address the most complex challenges in healthcare. We will accelerate our research and development and deliver truly transformational diagnostic solutions, digital products, and medicines to better serve the needs of patients along their entire journey – from prevention and screening to diagnosis, treatment and monitoring.

Innovation Ecosystem: Our autonomous research and development centres and alliances with more than 250 external partners foster a diversity of scientific approaches and agility. Our global geographical scale and reach enables us to attract talent in the leading global science clusters and to quickly bring our solutions to people who need them.

Value Creation: We create value for all our stakeholders: bringing significant medical benefit for patients, doctors and payers, being a partner of choice, offering a great place to work for employees, delivering a sustainable positive contribution to society and earning competitive returns for our investors.

Interests and Views of Stakeholders

Patient Community Engagement: Roche engages with 1,292 patient organisations around the world to help strengthen healthcare systems. Our approach focuses on embedding the patient voice into every aspect of our disease area strategies internally, as well as on working alongside patient communities to drive meaningful change within healthcare systems externally.

Global Patient Think Tank (GPTT): Following the United Nations High-Level Meeting (UNHLM) on UHC in 2023, we established the Global Patient Think Tank – a dynamic, diverse coalition of patient community representatives – supporting the amplification of the patient community's voice within the global movement for UHC and driving on-the-ground implementation of the newly approved WHO resolution on social participation in health and well-being.

Patient Benefits and Societal Impact Framework: This framework was co-created by Roche and patient organisations to systematically capture patient benefits and impact to society. The framework covers:

• Disease and treatment/solution benefits
• Health-related quality of life improvements
• Patient pathway enhancements
• Financial impact reduction
• Patient empowerment
• Societal impact

Healthcare System Partnerships: We collaborate with health systems, organisations and governments to overcome access barriers, ensuring Roche innovations reach those who need them and delivering better health outcomes. Key partnerships include EMPOWER Kenya, pre-eclampsia screening programs in Latin America, and the African Breast Cancer Ambition.

Supplier Engagement: We communicate our expectations to suppliers through the Roche Supplier Code of Conduct, addressing working conditions, equal treatment, and human rights across our value chain.

Employee Engagement: Our people are at the heart of our business. We are committed to fostering an inclusive work environment where people can thrive and which keeps employees safe and healthy, embraces diversity and reflects the communities we serve.

Material Impacts, Risks and Opportunities

Double Materiality Assessment: In 2024, we conducted a double materiality assessment (DMA) aligned with CSRD requirements. Through our ESRS-aligned DMA, we identified 14 material ESG subtopics:

Environment:

• E1: Climate change adaptation
• E1: Climate change mitigation
• E1: Energy
• E2: Pollution of air
• E3: Water

Social:

• S1: Working conditions (own operations)
• S1: Equal treatment and opportunities for all (own operations)
• S1: Other work-related rights
• S2: Working conditions (value chain)
• S4: Personal safety of consumers and/or end users
• S4: Information-related impacts for consumers and/or end users
• S4: Social inclusion of consumers and/or end users

Governance:

• G1: Corporate culture
• G1: Corruption and bribery

Integration with Strategy: The DMA outcome supported the development of the six priorities of our sustainability strategy:

Access to innovation: Access to innovation and health equity are core to our business and key to our commitment to improve patient outcomes.

Work environment: Our people are at the heart of our business. We are committed to fostering an inclusive work environment where people can thrive.

Environment: Respect for the environment has always been a priority for Roche. It is critical that we continue working across our value chain to cut emissions and minimise the impact of our products at every stage of their life cycle.

Key Business Environment Trends: Our Corporate Sustainability Steering Committee identified ten key trends most relevant to Roche, including accelerated technological transformation, increase in infectious diseases and chronic illnesses, climate change adaptation needs, and healthcare affordability challenges.

Process to Identify and Assess Material Impacts, Risks and Opportunities

Double Materiality Assessment Methodology: In 2024, our methodology was aligned with the requirements of the Corporate Sustainability Reporting Directive (CSRD) in preparation for future reporting, and the Swiss Code of Obligations (CO). This applicable legal framework requires organisations to take both an inside-out and an outside-in perspective. The inside-out view focuses on the company's impact on people and the environment, and the outside-in view looks at the risks and opportunities that impact the company's financial performance.

Environmental Topics Assessment: We assessed the materiality of environmental subtopics using a data-driven methodology. This involved gathering primary environmental data for our own operations and our upstream value chain across the different environmental subtopics. We then converted these into monetised impacts using impact valuation principles. Impact valuation is a well-established approach that aims to evaluate social, environmental and economic impacts. The impact is first assessed in physical units, such as tonnes of greenhouse gas (GHG) emissions, and is then converted into monetary equivalents.

Social and Governance Topics Assessment: For our social and governance subtopics, we conducted a qualitative assessment where we collaborated with internal subject-matter experts to identify and score the IROs.

Validation Process: To supplement our quantitative assessment, we also conducted a qualitative assessment of the IROs of our subtopics, engaging a core group of internal subject-matter experts to assess each IRO. We used the results of this phase to validate the findings of the data-driven assessment.

Business Environment Risk Assessment: We identify long-term business environment trends and the associated risks and opportunities on an annual basis through our business environment risk and opportunity assessment process. Each year, emerging trends are identified from internal and external sources and reviewed by selected internal stakeholder groups. Our Corporate Sustainability Steering Committee then evaluates and selects the ten trends most relevant to Roche.

Integration into Risk Management: Roche risk and opportunity managers are required to consider these ten trends and the associated risks and opportunities as part of their assessment of their respective business units and to formulate the appropriate response at the business unit and/or Group level as part of the Group risk management process.

External Methodology Sharing: We presented this methodology at the World Business Council for Sustainable Development (WBCSD) Enhancing Corporate Transparency forum in September 2024, welcoming input from others to further refine the process.

ESRS Disclosure Requirements Coverage

Material Topics Identification: Through our European Sustainability Reporting Standards (ESRS)-aligned double materiality assessment, we identified 14 material ESG subtopics covering environment (E1, E2, E3), social (S1, S2, S4) and governance (G1) topics.

Transition Year Approach: Given that 2024 was a transition year in preparation for CSRD-aligned reporting, our DMA methodology and material subtopics may evolve. We continue to strengthen and evolve our sustainability reporting in response to internally developed reporting criteria and increasing reporting regulation and legislation, including the Corporate Sustainability Reporting Directive (CSRD).

Current Reporting Framework: The information disclosed within this report is based both on mandatory disclosure requirements and on voluntarily provided information, as well as on our materiality assessment. The content is prepared in reference to the Global Reporting Initiative (GRI) Standards and in compliance with:

• The relevant sections of the Swiss Code of Obligations (CO)
• The recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)
• The '2024 Sustainability reporting indicators definitions and scope'

Future ESRS Alignment: We remain committed to compliance with relevant current and future requirements, including full ESRS alignment for future reporting cycles. Our sustainability strategy priorities align with the material ESRS topics identified through our assessment process.

Transition plan for climate change mitigation

Scope of the transition plan

Roche's transition plan covers the entire value chain (scopes 1, 2 and 3), including operations across all sites and geographies, as well as the supply chain. The plan encompasses both the Pharmaceuticals and Diagnostics Divisions.

All Roche sites are required to develop roadmaps that detail their efforts to contribute to short- and long-term energy- and climate-related targets, ultimately achieving zero GHG emissions without the use of offsets by 2050.

Net zero and carbon neutrality targets

• Net-zero emissions across scopes 1, 2 and 3 by 2045 (submitted to SBTi for validation in 2024)
• Absolute zero scope 1 and 2 emissions by 2050 (no offsets)
• 100% sustainable electricity by 2025
• Zero CO₂ emissions car fleet (transition underway)

Roche is the only company in the pharmaceutical industry striving for absolute zero scope 1 and 2 emissions.

Alignment with 1.5°C and SBTi validation

In 2024, Roche submitted its near- and long-term emissions reduction targets to the Science Based Targets initiative (SBTi) for validation. This includes an ambitious goal to reach net-zero emissions across scopes 1, 2 and 3 by 2045.

The updated sustainability strategy including the science-based targets was approved by the Board.

Baseline year and emissions reduction milestones

Baseline year: 2022 for SBTi GHG baseline

Historical performance:

• Since 2004, Roche has achieved an absolute decrease of 69% in scope 1 and 2 emissions
• In 2024, eco-balance per employee score improved by 35.4% compared to 2019 and 2.7% compared to 2023

Scope 3 emissions (2024 vs 2023):

• Overall scope 3 emissions decreased by 8.4%
• Combined upstream supply chain emissions (categories 1 and 2) decreased by 10.8%
• Purchased goods and services impact decreased predominantly due to lower external manufacturing spend in Pharmaceuticals
• Capital goods impact increased with major site investment projects
• Emissions from waste generated in operations decreased by 8.5%
• Emissions from business travel increased by 11.8%
• Emissions from use of sold products (diagnostics instruments) increased by 16.1% with business growth

2024 emissions breakdown (tonnes CO₂):

• Scope 1: 245,832 (4.2% of total)
• Scope 2: 69,198 (1.2% of total)
• Scope 3: 5,478,525 (94.6% of total)

Decarbonization levers and strategy

Roche has identified four key decarbonization categories along the value chain:

1. Efficiency (Scopes 1, 2 and 3)

• Optimise manufacturing, utilities and business processes for resource and energy efficiency
• Product efficiency updates including manufacturing innovations
• Mindful business travel
• Increase recycling, reduce waste to landfill and incineration

2. Sustainable sources (Scopes 1, 2 and 3)

• Transition away from fossil-based energy and raw materials sources to more sustainable alternatives
• 100% sustainable electricity by 2025
• Introduce defossilised raw-material sources
• Invest in greener fuels and transport technologies
• Deploy technology innovations including geothermal storage and heat pumps

3. Circularity (Scope 3)

• Embed circularity in products and facilities, design considering full life cycle impact
• Conduct and leverage product life cycle assessments
• Implement circular practices throughout the product life cycle
• Sustainable construction standard for major real estate projects

4. Supplier engagement (Scope 3)

• Support suppliers to decarbonise their operations, production and material usage
• Set supplier expectations and collaborate with strategic suppliers
• Scale defossilised raw-material use
• Continue low-carbon innovation of products and processes with partners

Roadmap to net zero 2045

Sites and operations (Scopes 1 and 2):

• 100% sustainable electricity by 2025
• Develop project portfolio from site zero CO₂ emissions roadmaps
• Sustainable construction standard for major real estate projects
• Transition to zero emissions car fleet
• Deploy technology innovations
• Close out site zero CO₂ emissions roadmaps
• Continued identification and application of decarbonisation levers

Products and supply chain (Scope 3):

• Set supplier expectations and collaborate with strategic suppliers
• Increase recycling, reduce waste to landfill and incineration
• Conduct and leverage product life cycle assessments
• Embed efficiency and circularity in future portfolio through design and development
• Logistics optimisation and modal shift
• Analyse clinical trials footprint and reduction opportunities
• Product efficiency updates including manufacturing innovations
• Implement circular practices throughout the product life cycle
• Introduce defossilised raw-material sources
• Invest in greener fuels and transport technologies
• Continue low-carbon innovation of products and processes with partners
• Scale defossilised raw-material use
• Continue investment in alternative construction materials and manufacturing technology
• Continued identification and application of decarbonisation levers

Key achievements and projects

Zero-emissions facility:

• The Roche Diagnostics manufacturing site expansion in Branchburg, US, commissioned in late 2024, achieved zero operational GHG emissions through integrated sustainable design including low-temperature heating, geoexchange (first in Roche USA) and heating water storage, all connected to a heat pump chiller providing heating and cooling sourced with 100% sustainable electricity

Site-level roadmaps:

• All Roche sites are developing roadmaps detailing measures for energy reduction, phase-out of unnecessary high-temperature thermal energy use, substitution of non-sustainable energy with sustainable sources, and required resources

Improved scope 3 data:

• Enhanced data measurement systems allowing expansion of reported scope 3 categories
• Implemented multi-regional emissions factor model for purchased goods and services and capital goods
• Year-on-year scope 3 emissions data by consistent methodology provided from 2022 baseline onwards

Supplier collaboration:

• In 2024, engaged with more than 400 suppliers to share Roche's sustainability approach and expectations
• Supported suppliers to commit to their own science-based emissions reduction targets and adopt SMI supplier standards
• Contributed to the Pharmaceutical Supply Chain Initiative (PSCI) Decarbonization Playbook for the Pharmaceutical Industry
• Sponsored the Energize programme to help suppliers explore renewable energy procurement
• First Energize supplier cohort purchased a multi-buyer renewable energy agreement, adding more than 280 MW

CapEx and investment commitments

Roche states that achieving net-zero emissions "will require focus, investment and wide-scale change." The company is "prepared to make the right decisions and invest wisely."

Specific investment commitments include:

• Major site investment projects including South San Francisco, Oceanside and Basel (reflected in increased capital goods emissions)
• Continue investment in alternative construction materials and manufacturing technology
• Award-winning production and warehouse expansion at Branchburg site

No specific CapEx figures are disclosed.

Use of carbon credits and removals

Roche's ambition is to reach absolute zero scope 1 and 2 emissions by 2050 without the use of offsets.

All Roche sites are required to develop roadmaps ultimately achieving zero GHG emissions without the use of offsets by 2050.

Locked-in emissions and stranded assets

No specific disclosure of locked-in emissions analysis or stranded asset assessment.

Governance and implementation

The Corporate Sustainability Steering Committee, which submits regular reports to the Corporate Executive Committee and the Corporate Governance and Sustainability Committee of the Board of Directors, is chaired by the Head Strategy and Sustainability and comprises nominees from the Pharmaceuticals and Diagnostics Divisions and Group functions.

Progress is driven by sustainability teams in the pharmaceuticals and diagnostics business areas with the established Scope 3 Decarbonisation Centre of Excellence acting as a cross-functional coordination point for value chain decarbonisation efforts.

Performance is reported externally on an annual basis.

Alignment with frameworks

Roche's transition plan aligns with:

• Science Based Targets initiative (SBTi) framework
• Sustainable Markets Initiative (SMI) supplier standards
• Pharmaceutical Supply Chain Initiative (PSCI)

External verification

Scope 1, 2 and 3 business travel GHG emissions are verified by an independent external auditor and published annually in the Roche Annual Report.

Climate Change Policies

Net-Zero Commitment: In the area of climate protection, we set ourselves the ambitious target of achieving net-zero emissions throughout our value chain by 2045 and absolute zero emissions by 2050 as part of the Science Based Targets initiative. We are the only ones in the industry striving for absolute zero. Our commitment goes beyond reducing CO₂ emissions.

Climate Action Integration: In 2024, we submitted ambitious net-zero targets to the Science Based Targets initiative and commissioned a zero-emissions facility. We are implementing a phased approach to assess our climate-related transition risks. In 2024 we prioritised developing a common understanding across Group functions and divisions of what transition risks and opportunities may impact our company and at which time horizons the risks are likely to materialise.

Sustainable Facility Development: Our recently opened Roche Innovation Center Basel exemplifies our sustainability goals, including maximising energy efficiency and using recycled concrete, rooftop solar panels and smart concepts for water-saving.

Risk Management: Transition climate change risk is faced across the value chain through e.g. failure to meet climate change objectives or comply with new climate regulations, increased raw material costs or misalignment with customer sustainability expectations. This leads to increased costs due to higher procurement costs, additional costs to comply with regulations, fines, etc.

Actions and Resources for Climate Change

Sustainable Infrastructure Investment: With a total investment of CHF 1.2 billion, our recently opened Roche Innovation Center Basel is a perfect example of our climate commitment. As one of the most modern research centres in the world, it focuses on interdisciplinary cooperation and shows how we are advancing our sustainability goals, including maximising energy efficiency and using recycled concrete, rooftop solar panels and smart concepts for water-saving.

Zero-Emissions Facility: In 2024, we commissioned a zero-emissions facility as part of our climate action initiatives.

Science Based Targets Initiative: We submitted ambitious net-zero targets to the Science Based Targets initiative in 2024, demonstrating our commitment to science-based climate action.

Value Chain Approach: Sustainable product innovations reduced waste and emissions across our operations. We are implementing actions across our value chain to cut emissions and minimise the impact of our products at every stage of their life cycle.

Risk Mitigation Investments: Significant investments are required to improve water efficiency in water-stressed areas (e.g. improving and monitoring of water treatment where water is a constrained resource, particularly in California, US). This leads to increased operational costs due to new infrastructure investments needed.

Climate Change Targets

Net-Zero by 2045: We have set ourselves the ambitious target of achieving net-zero emissions throughout our value chain by 2045 as part of the Science Based Targets initiative.

Absolute Zero by 2050: We aim to reach absolute zero scope 1 and 2 emissions by 2050. We are the only ones in the industry striving for absolute zero. Our commitment goes beyond reducing CO₂ emissions, and it will surely not end in 2050. It is an ongoing way of how we do business.

Science-Based Targets: Our targets are aligned with the Science Based Targets initiative (SBTi), which provides a framework for companies to reach net zero. In 2024, we submitted ambitious net-zero targets to the SBTi for validation.

Energy consumption and mix

Total energy consumption

Scope: Energy consumption figures include scopes 1 and 2 emissions using market-based accounting. Energy intensity is calculated per employee.

Energy mix detail

Roche reports that approximately 86% of sourced electricity is sustainable as of 2024. The company has committed to 100% sustainable electricity at all sites by 2025.

Disaggregated energy mix: The report does not provide a fully disaggregated energy consumption table broken down by fuel type (coal, crude oil/petroleum, natural gas, other fossil sources) and renewable sources (biomass, biogas, hydrogen, purchased renewable electricity/heat/steam, self-generated renewable energy) as required by ESRS E1-7. Energy consumption is reported in aggregate as total terajoules for scopes 1 and 2 combined.

Fossil/nuclear/renewable split: Not disclosed in the required ESRS format. The company reports sustainable electricity percentage but does not break down total energy consumption by fossil, nuclear, and renewable categories with consumption volumes.

Conversion note: 8,492 TJ equals approximately 2,359 GWh or 2.36 million MWh for 2024.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 emissions

Roche's Scope 1 (direct) emissions for 2024 were 245,832 tonnes CO₂ equivalent, a 2.3% increase from 240,266 tonnes in 2023. The 2022 baseline was 249,350 tonnes.

No sub-breakdown by stationary combustion, mobile combustion, process emissions, or fugitive emissions was disclosed.

Scope 2 emissions

Roche reports Scope 2 (indirect emissions from purchased energy) using the market-based method. No location-based figures were disclosed in the report.

Scope 2 emissions decreased by 29.7% from 2023 to 2024, attributed to increased use of sustainable electricity.

Scope 3 emissions

Roche's Scope 3 (value chain) emissions for 2024 were 5,478,525 tonnes CO₂ equivalent, an 8.4% decrease from 5,978,508 tonnes in 2023.

The report discloses Scope 3 emissions by GHG Protocol category. Year-on-year data is provided from the SBTi baseline year of 2022 onwards, applying a consistent methodology (hybrid activity-based GHG accounting, multi-regional supply chain emissions factors published by WifOR, ecoinvent and internal life cycle analysis).

Scope 3 emissions by category (tCO₂eq):

Methodology and scope notes:

• Categories 1, 2, 7, 9, 11, 12, 15 do not include Chugai impact.
• Categories 8, 10, 13 and 14 have been assessed and confirmed to have no material impact. Category 8: all leased premises are included in Scope 1 and 2. Category 13: impact of all on-market products is consolidated in category 11.
• Category 4 reporting boundary has been expanded; where activity data is unavailable for specific Roche distribution hubs, an estimation has been made for completeness for 2022, 2023 and 2024.
• Category 1 and 2 values for 2022 and 2023 restated following a review of emissions factors.
• Reported Scope 3 categories expanded in 2024 to include employee commuting (7), downstream transportation and distribution (9), end-of-life treatment of sold products (12), and investments (15).
• Environmental data from Flatiron Health and Spark Therapeutics are included as of 2024. Foundation Medicine (FMI) data included since 2023.

Percentage breakdown of Scope 3 emissions (2024):

Total GHG emissions

Total GHG emissions (Scopes 1, 2 market-based, and 3):

Scope 3 represents 94.6% of Roche's total 2024 GHG emissions. Scope 1 represents 4.2% and Scope 2 represents 1.2%.

GHG intensity

Roche reports energy intensity (Scopes 1 and 2 only) per employee:

No revenue-based intensity metric (tCO₂eq per M€ net revenue) was disclosed.

Biogenic CO₂ emissions

Not separately disclosed.

Regulated emissions (e.g. EU ETS)

Not separately disclosed.

Energy consumption

Total energy consumption (Scopes 1 and 2, market-based method):

Additional environmental data

Halogenated hydrocarbons (tonnes, global inventory including Chugai):

Eco-balance metric

Roche uses an internal eco-balance metric (developed by the Swiss Federal Office for the Environment, Ecological Scarcity Method: Eco-Factors 2006) to assess overall environmental impact.

Note: Eco-points for Scope 3 category 4 emissions determined with consistent measurement scope through 2019–2025 goal period (without estimated emissions).

Anticipated Financial Effects from Climate-related Risks and Opportunities

Transition Risk Financial Impacts: Transition climate change risk is faced across the value chain through e.g. failure to meet climate change objectives or comply with new climate regulations, increased raw material costs or misalignment with customer sustainability expectations. This leads to increased costs due to higher procurement costs, additional costs to comply with regulations, fines, etc.

Infrastructure Investment Needs: Significant investments are required to improve water efficiency in water-stressed areas (e.g. improving and monitoring of water treatment where water is a constrained resource, particularly in California, US). This leads to increased operational costs due to new infrastructure investments needed.

Supply Chain Financial Impacts: Water scarcity in water-stressed areas in which suppliers operate, and failures in water supply that impair supplier facilities could lead to increased costs for goods purchased from suppliers.

Investment in Sustainable Infrastructure: With a total investment of CHF 1.2 billion, our recently opened Roche Innovation Center Basel demonstrates our commitment to sustainable infrastructure, incorporating energy efficiency measures and renewable energy solutions.

Pollution Policies

Environmental Treatment Standards: We treat consumptive water, especially for active pharmaceutical ingredients in our manufacturing effluents, in compliance with all relevant regulations and pre-treatment standards, ensuring it returns to nature without harming the environment.

Regulatory Compliance: Reputational and legal fine/action risk due to non-compliance with water-related regulations or increased scrutiny on water usage affects the company's operations. We manage this through comprehensive compliance measures and monitoring systems.

Sustainable Product Development: Sustainable product innovations reduced waste and emissions across our value chain. We aim to minimise the impact of our products at every stage of their life cycle, contributing to pollution reduction.

Air Pollution Management: Pollution of air has been identified as one of our material environmental subtopics through our double materiality assessment, and we implement measures to address air quality impacts from our operations.

Actions and Resources for Pollution

Water Treatment Infrastructure: We have established comprehensive water treatment systems for our manufacturing effluents, particularly for active pharmaceutical ingredients, ensuring compliance with all relevant regulations and pre-treatment standards before water returns to nature.

Sustainable Product Innovation: Sustainable product innovations have been implemented to reduce waste and emissions across our operations and value chain, minimising environmental impact throughout product lifecycles.

Compliance Monitoring: We have implemented monitoring systems to ensure compliance with water-related regulations and to address increased scrutiny on water usage. This includes additional measures, policies and programmes to meet regulatory requirements.

Investment in Pollution Prevention: Significant investments have been made in improving water efficiency and treatment infrastructure, particularly in water-stressed areas such as California, US, to minimise environmental impact.

Pollution of air, water and soil

Roche eco-balance 2024

Pollution sources as percentage of total eco-balance:

• Emissions to air: 83.0%
• Energy consumption: 10.2%
• Emissions to water: 2.9%
• Landfilled waste: 1.1%

Emissions to water

Water consumption and emissions to water targets and performance

SHE Goals 2025:

• Reduce water consumption by 15% by 2025 (risk-weighted water consumption per employee)
• Reduce nitrogen discharge to water by 5% by 2025 (tonnes, absolute)
• Reduce phosphorus discharge to water by 90% by 2025 (tonnes, absolute)

Water stress context:

• Medium water stress: 8%
• High water stress: 9%

Based on WWF 'Water Risk Filter'

Overall eco-balance performance

In 2024, Roche reported an overall improvement of 35.4% in eco-balance per employee score compared to 2019, with a 2.7% improvement observed in 2024 compared to 2023. This improvement was attributed to consistent progress across the implementation of projects portfolio, increased use of sustainable energy and reduction of phosphorus emissions.

Methodology note: Effectiveness of water management initiatives is measured by tracking reductions in water consumption in scarcity areas, as well as monitoring water withdrawal and consumption rates.

Substances of concern and substances of very high concern

Roche disclosed narrative information regarding substances of very high concern (SVHC) in the context of process improvement and REACH compliance, but did not provide quantitative tonnage data for substances of concern or substances of very high concern.

Process improvement eliminating SVHC

In developing a novel antibacterial treatment, Roche optimised a complex, multi-step process (G2 process) that eliminated the use of three solvents on the REACH Candidate List of substances of very high concern for Authorisation:

• Dimethylacetamide (DMA)
• Dimethylformamide (DMF)
• 1,2-dimethoxyethane (DME)

This process optimization resulted in an increase in overall yield of 250%, while saving more than 90,000 kg of solvents required in the manufacturing of the drug substance. The improved process also reduced specific CO₂ emissions by 35% versus the previous (G1) process, which would avoid 14 kilotonnes of CO₂ emissions yearly based on current API forecast.

Risk assessment and compliance approach

Roche conducts environmental risk assessments to determine the impacts of particular chemicals and biomaterials on the environment and develops precautionary measures as a consequence.

Legislation calls for specific documentation for all chemicals and biomaterials handled at Roche sites. These documents include information such as hazard data and waste disposal guidance, and are made available online to employees, customers and the public.

Roche regularly performs safety, security, health and environmental protection (SHE) audits of its own business activities, supply chain and other service providers. The company expects that suppliers meet the same high SHE standards established for internal sites, checking their performance through audits at their facilities.

Financial Effects from Pollution-related Impacts

Compliance Costs: Reputational and legal fine/action risk due to non-compliance with water-related regulations or increased scrutiny on water usage leads to higher costs of compliance because of additional measures, policies and programmes, as well as costs to comply with updated regulations, or litigation costs, fines or penalties if not met or not compliant.

Revenue Impact: Non-compliance also leads to loss of revenue due to reputational damage and adverse reactions from customers.

Infrastructure Investment: Significant investments are required to improve water efficiency in water-stressed areas (e.g. improving and monitoring of water treatment where water is a constrained resource, particularly in California, US). This leads to increased operational costs due to new infrastructure investments needed.

Water and Marine Resources Policies

Water Treatment Standards: We treat consumptive water, especially for active pharmaceutical ingredients in our manufacturing effluents, in compliance with all relevant regulations and pre-treatment standards, ensuring it returns to nature without harming the environment.

Water Conservation Priority: Water conservation efforts prioritised reduction of water usage and protection of the sensitive ecosystem and its biodiversity. Water has been identified as one of our material environmental subtopics through our double materiality assessment.

Risk Management Approach: Globally we assess nature-based risks across our value chain – including those related to water stress, water quantity and quality, regulatory issues and biodiversity.

Regulatory Compliance: We implement comprehensive measures to ensure compliance with water-related regulations and to address increased scrutiny on water usage, including monitoring systems and treatment infrastructure.

Actions and Resources for Water and Marine Resources

Water Conservation Initiatives: Water conservation efforts prioritised reduction of water usage and protection of the sensitive ecosystem and its biodiversity. Our recently opened Roche Innovation Center Basel incorporates smart concepts for water-saving as part of our sustainability goals.

Treatment Infrastructure: We have established comprehensive water treatment systems, particularly for manufacturing effluents containing active pharmaceutical ingredients, ensuring treated water returns to nature without environmental harm.

Water Efficiency Investments: Significant investments are being made to improve water efficiency in water-stressed areas, particularly improving and monitoring of water treatment where water is a constrained resource, such as in California, US.

Risk Assessment: We conduct global assessments of nature-based risks across our value chain, including those related to water stress, water quantity and quality, regulatory issues and biodiversity.

Smart Water Management: Our new facilities incorporate smart water management concepts, including water-saving technologies and efficient water usage systems.

Targets related to water

2020–2025 SHE Goals

Roche has established the following water-related targets as part of its 2020–2025 safety, security, health and environmental protection (SHE) goals:

Target 1: Water Consumption Reduction

• Metric: Water consumption in m³ per employee (risk weighted)
• Target: 15% reduction by 2025
• Baseline year: 2020
• Type: Intensity-based (per employee, risk weighted)
• Scope: Own operations
• Note: The weighted result is derived by multiplying the true consumption for each site in m³ by the site's specific water risk factor. The results are summed up and the total is expressed as m³ per employee.

Target 2: Nutrient Discharges Reduction

• Metric: Nitrogen discharge and phosphorus discharge to water
• Target:
  • 5% decrease in nitrogen discharge by 2025
  • 90% decrease in phosphorus discharge by 2025
• Baseline year: 2020
• Type: Absolute
• Scope: Own operations

New Sustainability Strategy Goals (by 2030)

Goal 1: Certified Biodiversity and Water Stewardship Projects

• Target: Sites in biodiversity-sensitive/water-stressed areas and key suppliers have certified biodiversity and water stewardship projects in place by 2030
• Type: Qualitative/implementation target
• Scope: Own operations (specific sites) and value chain (key suppliers)

Goal 2: Natural Commodities Procurement

• Target: Key natural commodities are procured from credible certified sources by 2030
• Type: Qualitative/implementation target
• Scope: Value chain

Goal 3: True Cost Accounting

• Target: All business decisions account for the true cost (i.e. indirect and direct cost) of using natural commodities and water by 2045
• Type: Qualitative/implementation target
• Scope: Own operations and value chain

Site-specific Approach

• All sites have risk-weighted water consumption targets to prioritise efficiency in high-risk areas
• Twelve facilities represent 83% of Roche's absolute water consumption (m³), mainly in low-stress regions

Water Consumption by Scarcity Areas

• Low water stress: 83%
• Medium water stress: 8%
• High water stress: 9%

Note: Progress against the 2020-2025 targets is referenced on page 115 but detailed figures are not provided in the excerpts.

Water consumption

Water usage and discharge performance

*The increase in heavy metals was due to additional reporting of iron and manganese.

Water consumption in water-stressed areas

Roche reports water consumption categorized by water scarcity levels based on the WWF 'Water Risk Filter' tool:

Twelve facilities represent 83% of Roche's absolute water consumption (m³), mainly in low-stress regions.

Water intensity and targets

Risk-weighted water consumption per employee:

• 2020 (baseline): 75.92 m³
• 2024: 24.05 m³
• Progress vs. baseline: 54% reduction
• 2025 goal: 64.54 m³ (15% reduction from 2020)

Note: The weighted result is derived by multiplying the true consumption for each site in m³ by the site's specific water risk factor. The results are summed up and the total is expressed as m³ per employee.

Nutrient discharge reduction targets

Nitrogen discharge to water:

• 2020 (baseline): 39.02 tonnes
• 2024: 61.7 tonnes
• 2025 goal: 37.07 tonnes (5% reduction)
• Progress: 19% increase vs. baseline

Phosphorus discharge to water:

• 2020 (baseline): 29.65 tonnes
• 2024: 13.75 tonnes
• 2025 goal: 2.96 tonnes (90% reduction)
• Progress: 54% reduction vs. baseline

Water management approach

Roche treats consumptive water, especially for active pharmaceutical ingredients, in manufacturing effluents in compliance with all relevant regulations and pre-treatment standards, ensuring it returns to nature without harming the environment. A significant portion of water withdrawn is used for non-consumptive purposes (cooling and heating) and is discharged uncontaminated without treatment.

Site-specific initiatives include: implementing optimised equipment and manufacturing processes to minimise water consumption; enhancing cooling systems for greater water efficiency; and identifying and integrating operational processes that enable water reuse and recycling.

Scope and data coverage

Environmental data from Flatiron Health and Spark Therapeutics are included in the Roche environmental results as of 2024. Environmental data from FMI have been included since 2023.

Roche uses databases such as the World Resources Institute's 'Aqueduct' and the World Wide Fund for Nature's 'Water Risk Filter' tools to categorise sites by water risk exposure and prioritise high-risk locations.

Financial Effects from Water and Marine Resources

Operational Cost Increases: Significant investments are required to improve water efficiency in water-stressed areas (e.g. improving and monitoring of water treatment where water is a constrained resource, particularly in California, US). This leads to increased operational costs due to new infrastructure investments needed.

Supply Chain Cost Impacts: Water scarcity in water-stressed areas in which suppliers operate, and failures in water supply that impair supplier facilities could lead to increased costs for goods purchased from suppliers.

Compliance and Regulatory Costs: Reputational and legal fine/action risk due to non-compliance with water-related regulations or increased scrutiny on water usage leads to higher costs of compliance because of additional measures, policies and programmes, as well as costs to comply with updated regulations, or litigation costs, fines or penalties if not met or not compliant.

Revenue Risk: Non-compliance with water regulations also leads to loss of revenue due to reputational damage and adverse reactions from customers.

Own Workforce Policies

Work Environment Focus: Our people are at the heart of our business. We are committed to fostering an inclusive work environment where people can thrive and which keeps employees safe and healthy, embraces diversity and reflects the communities we serve. Work environment is one of the six priority areas highlighted in our updated sustainability strategy.

Safety, Health and Well-being: Every day, Roche's employees work to develop solutions to society's most pressing healthcare needs. We place their individual health, well-being and professional growth at the very heart of what we do. By protecting and promoting safety, health and well-being, we encourage innovative thinking and promote high performance. Well-being is not a box to check – it is one of our top priorities.

Mental Health and Well-being Programme: Roche's approach provides colleagues with the resources and education to look after their mental and physical health, which we believe supports them to have balance while doing their best work. Our global mental health and well-being programme promotes well-being best practices across Roche.

Diversity, Equity and Inclusion: Roche is committed to building a workforce that embraces the diversity of communities we serve, and to a culture where every person is valued, accepted and celebrated for who they are. Our leadership inspires outcomes that matter by embracing diversity, equity and inclusion. Different backgrounds, perspectives and experiences, across the entire organisation, foster innovative solutions for the benefit of patients and healthcare systems.

Human Rights Commitment: Roche upholds human rights principles across our own operations and our value chain. We have policies in place as well as a risk management approach to prevent, detect and mitigate risk of potential infringement on human rights and its adverse impacts.

Processes for Engaging with Own Workforce

LiveWell@Roche Community: Our Global Live Well Community supports employees to care for themselves and others as much as we care for patients. More than 250 dedicated Live Well Champions across the Roche network help boost awareness and impact throughout the year.

Training and Development: Through education, we aim to equip our people with the tools and resources they need to be at their best. To date, 92,563 employees have completed our employee (mental) health and well-being online training. In 2024, 1,676 colleagues joined our psychological safety workshops.

Professional Support: 2,078 employees took advantage of free professional coaching sessions to boost stress management and well-being. We continue to support employees with a range of other well-being services such as meditation, mindfulness and sleep tools, resilience training, counselling sessions and fitness options.

Employee Engagement on Well-being: We believe that when our people are thriving, we all succeed. Our approach focuses on providing colleagues with the resources and education to look after their mental and physical health, supporting them to have balance while doing their best work.

Taking Action on Material Impacts on Own Workforce

Well-being Initiatives: In 2024, we strengthened ongoing initiatives and introduced several new ones, including:

• Well-being resources – training, coaching and more: through education, we aim to equip our people with the tools and resources they need to be at their best
• 92,563 employees have completed our employee (mental) health and well-being online training
• 1,676 colleagues joined our psychological safety workshops in 2024
• 2,078 took advantage of free professional coaching sessions to boost stress management and well-being
• Range of other well-being services such as meditation, mindfulness and sleep tools, resilience training, counselling sessions and fitness options

Risk Management: Not providing industry-leading work-life balance programmes results in decreasing employee retention and a loss or lack of potential top talent, which in turn leads to an increase in recruitment costs and reputational damage. We manage this risk by protecting and promoting safety, health and well-being.

Diversity and Inclusion Actions: A low diversity, equity and inclusion level results in potential reputational damage. Roche is committed to building a workforce that embraces the diversity of communities we serve, and to a culture where every person is valued, accepted and celebrated for who they are.

LiveWell@Roche: Our Global Live Well Community supports employees to care for themselves and others as much as we care for patients. More than 250 dedicated Live Well Champions across the Roche network help boost awareness and impact throughout the year.

Characteristics of the undertaking's employees

Total headcount and FTE

Roche does not disclose total headcount or FTE figures in the provided excerpts. Employee numbers are referenced indirectly (e.g., "85,268 employees were eligible for a bonus under the Roche Bonus Program" in 2024, "24,031 eligible Roche employees" for RSUs in 2024), but comprehensive headcount data is not provided.

Headcount by gender

Gender breakdown of employees is not disclosed in the excerpts. However, the company reports on gender composition of the Board of Directors and Corporate Executive Committee:

Board of Directors (as at 31.12.2024):

• Female: 4 members
• Male: 6 members
• Total: 10 members

Corporate Executive Committee (as at 31.12.2024):

• Female: 28%
• Male: 72%

Enlarged Corporate Executive Committee (as at 31.12.2024):

• Female: 32%
• Male: 68%

The company also reports on gender distribution by age for the Operating Divisional Group:

Note: Full age distribution data appears incomplete in the excerpts.

Headcount by country or region

No comprehensive breakdown by country or region is disclosed in the excerpts.

Headcount by employment contract type

No breakdown by permanent/temporary/non-guaranteed hours contracts is disclosed in the excerpts.

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

No breakdown by full-time/part-time employment is disclosed in the excerpts.

Employee turnover

Employee turnover rate and number of employees who left are not disclosed in the excerpts.

New hires

Number of new hires and hiring rate are not disclosed in the excerpts.

Corporate Executive Committee composition

Corporate Executive Committee members (as at 31.12.2024):

Enlarged Corporate Executive Committee additional members:

Diversity, equity and inclusion goals

The company reports on DE&I corporate goals:

2024 goals:

• Achieve +1% of women in executive positions by end of 2024 (compared to Q4 2023 baseline of 37.2%): Target 37.7%
• Achieve +1% of under-represented nationalities in executive positions by 2024 (compared to Q4 2023 baseline of 17.6%): Target 18.8%

2024 results:

• Women in executive positions: 0.5% increase achieved
• Under-represented nationalities in executive positions: 0.2% decrease

Future DE&I ambitions (by 2030):

• Attain 50% of people leaders and 40% of global executives being women
• Attain 25% of executives from under-represented nationalities by 2030
• Increase inclusion index in Global Employee Opinion Survey (GEOS) to ≥80 by 2030

Note: Under-represented nationalities include individuals from countries in Asia, Latin America, Eastern Europe, Middle East and Africa.

Well-being programmes

The company reports on employee participation in well-being initiatives:

• LiveWell@Roche: More than 250 dedicated Live Well Champions across the Roche network
• Live Well Weeks 2024: Over 14,000 employees engaged globally through more than 230 events

Bonus eligibility

In 2024, 85,268 employees were eligible for a bonus under the Roche Bonus Program.

Long-term incentive participation

• S-SARs: 23,869 employees received S-SARs in 2024
• RSUs: 24,031 eligible Roche employees for RSUs in 2024

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

Human rights violations involving non-employees

In 2024, 20 substantiated incidents related to human rights violations triggered terminations of contracts. Of these incidents:

• 18 involving Roche employees
• 2 involving a contractor

All incidents were related to discrimination and harassment. None of the incidents involved a business partner.

Use of speak-up channels

In 2024, 424 employees and 53 externals used the Roche Group speak-up channels, which are operated by an external provider and are available in 53 languages in 103 countries.

Methodology note

The excerpts reference "contractors" and "externals" in various contexts (reporting channels, human rights incidents, speak-up channel usage) but do not provide comprehensive headcount or FTE data for non-employee workers in Roche's own workforce. No breakdown by type (contractor, agency, self-employed) or total workforce numbers is disclosed.

Diversity metrics

Gender diversity targets

Roche has set the following diversity ambitions supporting the sustainability strategy:

• 50% of people leaders being women
• 40% of global executives being women
• 25% of executives from under-represented nationalities by 2030

Age distribution by gender (2024)

Age distribution expressed in full-time equivalents as of 31 December 2024:

Note: The excerpt shows only partial age band data. Complete age distribution across all bands (30+) is not included in the provided excerpts.

Additional diversity information

Pay equity: Roche conducts an organisation-wide pay equity analysis every three years to ensure equal compensation for equal work, regardless of gender, race or other personal characteristics.

Inclusion index target: Increase inclusion index in Global Employee Opinion Survey (GEOS) to ≥80 by 2030.

Adequate wages

Roche's disclosure on adequate wages is limited to policy commitments and supply chain expectations. No living wage benchmark or coverage data for own employees is disclosed.

Own workforce

No specific benchmark, coverage percentage, or adequacy assessment disclosed for Roche's own employees.

Supply chain

Roche requires suppliers to pay workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits. Suppliers are expected to consider remuneration in accordance with skills, performance and experience based on local competitive conditions.

The company's human rights due diligence process evaluates "whether workers receive adequate wages" as part of risk assessments. However, no specific living wage benchmark, methodology, or coverage data is provided.

Supplier commitments are embedded in the Roche Supplier Code of Conduct and verified through PSCI-based Supplier Sustainability Assurance Visits (SSAV). The human rights risk assessment for third-party operations is conducted every three years with yearly reviews.

Methodology and targets

No living wage calculation methodology, coverage targets, or timeline commitments disclosed.

Incidents, complaints and severe human rights impacts

Supplier sustainability audits (2024)

Total supplier sustainability audits conducted: 118

• Sustainability audits triggered by high human rights risk: 38
• Sustainability audits with findings related to human rights and labour: 66

Most common critical or major findings categories:

• Excessive overtime and incorrect overtime compensation: 16%
• Improper maintenance of HR and payroll documentation: 12%
• Delayed, improper payment and calculation of wages: 8%

SSAV audits per industry (2024)

Total SSAV audits: 118

SHE audits (2024)

Number of supplier SHE audits conducted with contract manufacturers: 36

Grievance mechanism

All Roche employees and business partners are encouraged to speak up in good faith if they believe that a human rights violation has occurred.

Value Chain Workers Policies

Supplier Code of Conduct: We communicate our expectations to suppliers through the Roche Supplier Code of Conduct. This includes requirements for suppliers to provide equal pay for work of equal value and to provide a workplace free of harsh treatment, harassment and discrimination.

Human Rights in Value Chain: In a globalised world, business value chains often span across international borders, giving millions of people an opportunity to participate in the global economy; however, this also brings challenges to ensuring workers' human rights. Roche upholds human rights principles across our own operations and our value chain.

Working Conditions Requirements: Suppliers failing to provide equal pay for work of equal value contribute to gender inequality due to e.g. lack of awareness and lack of communication of necessary requirements. We address this risk through our Supplier Code of Conduct and supplier engagement processes.

Anti-Discrimination Measures: Suppliers failing to provide a workplace free of harsh treatment, harassment and discrimination (e.g. particularly towards migrant workers, but also regarding ethnicity, social origin, religion or political beliefs, age, gender, sexual identity or orientation, disability or HIV status) lead to decreased trust for Roche due to legal and regulatory non-compliance issues.

Risk Management Approach: We have policies in place as well as a risk management approach to prevent, detect and mitigate risk of potential infringement on human rights and its adverse impacts, including throughout our supply chain.

Taking Action on Value Chain Workers

Supplier Code Implementation: We communicate our expectations to suppliers through the Roche Supplier Code of Conduct. This serves as our primary mechanism for addressing working conditions in our value chain, including equal pay requirements and anti-discrimination measures.

Due Diligence Process: We conduct due diligence to ensure these risks are mitigated and managed throughout our supply chain. This includes assessment of whether there are reasonable grounds to suspect child labour in our value chain.

Risk Mitigation: We manage risks related to suppliers failing to provide equal pay for work of equal value and suppliers failing to provide a workplace free of harsh treatment, harassment and discrimination through our comprehensive supplier management and monitoring processes.

Human Rights Implementation: Roche upholds human rights principles across our value chain through policies and risk management approaches to prevent, detect and mitigate risk of potential infringement on human rights and its adverse impacts.

Monitoring and Assessment: We assess suppliers' compliance with our expectations regarding working conditions, equal treatment opportunities, and human rights protections as part of our ongoing supplier management processes.

Consumers and End-Users Policies

Patient-Centric Approach: Our purpose is: doing now what patients need next. We believe it is urgent to deliver medical solutions right now – even as we develop innovations for the future. We are passionate about transforming patients' lives. We are courageous in both decision and action. And we believe that good business means a better world.

Access to Healthcare: Expanding access to healthcare is a core pillar of Roche's business strategy. Our approach involves identifying and addressing the root causes of access barriers at global, country and local levels. We collaborate with partners to create and deliver improvements to access tailored specifically to each country's healthcare environment.

Patient Safety and Quality: Personal safety of consumers and/or end users has been identified as one of our material subtopics. We are committed to ensuring the safety and efficacy of our products throughout their lifecycle.

Information and Privacy Protection: Roche is committed to collecting and using data in a lawful, fair, legitimate and ethical way and will always respect the privacy of individuals in order to earn and maintain their trust. Our navify digital solutions securely integrate data across care settings, connecting the healthcare community and accelerating access to innovation and insights.

Social Inclusion: Social inclusion of consumers and/or end users is identified as material. We are committed to ensuring our innovations are accessible to diverse patient populations and address health inequities.

Processes for Engaging with Consumers and End-Users

Patient Organisation Engagement: Roche engages with 1,292 patient organisations around the world to help strengthen healthcare systems. Our approach focuses on embedding the patient voice into every aspect of our disease area strategies internally, as well as on working alongside patient communities to drive meaningful change within healthcare systems externally.

Patient Benefits and Societal Impact Framework: This framework was co-created by Roche and patient organisations to systematically capture patient benefits and impact to society. The framework covers disease and treatment benefits, health-related quality of life improvements, patient pathway enhancements, financial impact reduction, patient empowerment, and societal impact.

Global Patient Think Tank: We established the Global Patient Think Tank (GPTT) – a dynamic, diverse coalition of patient community representatives – supporting the amplification of the patient community's voice within the global movement for UHC and driving on-the-ground implementation of the WHO resolution on social participation in health and well-being.

UHC Compass: Roche and the GPTT have co-created a UHC Compass, which aims to empower local patient leaders and communities to engage in appropriate discussions with the right health system stakeholders to advance UHC at the grassroots level.

Clinical Trial Engagement: We increased diverse representation in clinical trials as part of our health equity initiatives, ensuring patient voices are included in the development of our therapies.

Taking Action on Consumers and End-Users

Healthcare Access Initiatives: In 2024, we continued to work with partners both locally and globally to provide sustainable patient access to quality and affordable healthcare. Key initiatives include:

• EMPOWER Kenya: screening over 132,000 women for cervical and breast cancer, with EMPOWER 2.0 launched to screen 300,000+ women
• Pre-eclampsia screening in 18 public hospitals and 14 private institutions across Argentina, Bolivia, Paraguay and Uruguay
• African Breast Cancer Ambition: improving five-year survival rates for African women with breast cancer to 80%
• City Cancer Challenge partnership reaching an estimated 66.5 million people across 15 cities

Patient Safety Measures: We implement comprehensive measures to ensure personal safety of consumers and end users throughout our product development and commercialisation processes.

Digital Health Solutions: Our navify digital solutions securely integrate data across care settings, connecting the healthcare community and accelerating access to innovation and insights. We have introduced AI-powered predictive algorithms in solutions like the Accu-Chek SmartGuide for diabetes management.

Privacy Protection: Not being able to use data generated by Roche because of privacy reasons leads to decreased revenue due to the loss of new business segments or a slower product innovation process. We manage this risk through robust data protection measures and ethical data use practices.

Health Equity Actions: We work to double the number of patients receiving our core pharmaceutical therapies in low- and lower-middle-income countries (LLMICs) by 2026 and increased diverse representation in clinical trials.

Business Conduct Policies and Corporate Culture

Code of Conduct: Our commitment to sustainable healthcare is embodied in the Roche Group Code of Conduct. Roche employees must ensure that all access programmes comply with relevant laws, regulations and industry codes, and that they engage transparently and responsibly with various stakeholders to facilitate access to our products and services.

Ethical Business Practices: We reject all forms of corrupt business behaviour and we are committed to upholding high standards of business ethics and operating with integrity across our business. We rely on our comprehensive compliance management programme to achieve this.

Corporate Culture Values: Corporate culture has been identified as one of our material governance subtopics. Our culture is built around our purpose: doing now what patients need next. We are passionate about transforming patients' lives. We are courageous in both decision and action. And we believe that good business means a better world.

Integrity and Transparency: Our policies offer guidance on ethical collaboration with a range of stakeholder groups, including patients and patient organisations, healthcare professionals, healthcare organisations and government officials. We conduct all work with integrity and transparency so that we do not unduly influence stakeholders.

Collaborative Principles: The Roche Group Code of Conduct, Roche's Position on Partnering with Patient Communities and the Roche Directive on Collaborating with Patient Groups and Patients establish guiding principles that govern the actions of all our employees. These documents embody our commitment to mutual value and respect, integrity, equity, independence and transparency.

Management of Relationships with Suppliers

Supplier Code of Conduct: We communicate our expectations to suppliers through the Roche Supplier Code of Conduct. This includes comprehensive requirements for working conditions, equal pay for work of equal value, and workplace standards free of harsh treatment, harassment and discrimination.

Supply Chain Risk Management: We assess suppliers failing to provide equal pay for work of equal value and suppliers failing to provide a workplace free of harsh treatment, harassment and discrimination (e.g. particularly towards migrant workers, but also regarding ethnicity, social origin, religion or political beliefs, age, gender, sexual identity or orientation, disability or HIV status).

Due Diligence Process: We conduct due diligence to ensure risks are mitigated and managed throughout our supply chain. This includes assessment of whether there are reasonable grounds to suspect child labour and other human rights impacts in our value chain.

Human Rights in Supply Chain: Roche upholds human rights principles across our own operations and our value chain. We have policies in place as well as a risk management approach to prevent, detect and mitigate risk of potential infringement on human rights and its adverse impacts.

Supplier Compliance Monitoring: We have established processes to monitor supplier compliance with our Code of Conduct requirements and to address any identified issues or non-compliance situations.

Prevention and Detection of Corruption and Bribery

Anti-Corruption Commitment: We reject all forms of corrupt business behaviour and we are committed to upholding high standards of business ethics and operating with integrity across our business. We rely on our comprehensive compliance management programme to achieve this.

Risk Recognition: Corrupt business behaviour, such as bribery, unfair advantages, theft, fraud, embezzlement and misuse of company assets, is persistent in today's interconnected and increasingly competitive world. Given the broad scope of Roche's operations worldwide and the different types of relationships with key stakeholders, there is exposure to the risk of corruption and non-compliance.

Compliance Management Programme: We have established a comprehensive compliance management programme to prevent and detect corruption and bribery across our operations. This programme includes policies, training, monitoring and reporting mechanisms.

Stakeholder Engagement Standards: Our policies offer guidance on ethical collaboration with a range of stakeholder groups, including patients and patient organisations, healthcare professionals, healthcare organisations and government officials, ensuring all interactions comply with anti-corruption standards.

Materiality Recognition: Corruption and bribery has been identified as one of our material governance subtopics through our double materiality assessment, reflecting the importance we place on maintaining high ethical standards.

Incidents of corruption or bribery

Overview of Code of Conduct violations

Roche reports on alleged violations of the Roche Group Code of Conduct, which encompasses anti-corruption and anti-bribery matters among other compliance topics. The Chief Compliance Officer received 745 reports of alleged violations via the Business Ethics Incident Management System (BEIMS) in 2024.

Of these 745 reports:

• 200 were still under investigation at year-end
• 31 were from previous years
• 648 reports were resolved in 2024
  • 294 were unfounded
  • 354 were founded

Disciplinary actions

As a result of the 354 founded violations:

• 98 employment contracts were terminated
• 141 resulted in a warning
• 1 led to bonus reduction
• The rest resulted in corrective measures

Business partner actions

8 agreements with business partners were terminated on grounds of unethical behaviour.

Human rights-related terminations

Separately, Roche reported that in 2024, 20 substantiated incidents related to human rights violations (specifically discrimination and harassment) triggered terminations of contracts:

• 18 involving Roche employees
• 2 involving a contractor
• None involved a business partner

Speak-up mechanism usage

In 2024, 424 employees and 53 externals used the Roche Group speak-up channels, which are operated by an external provider and available in 53 languages in 103 countries.

Convictions and fines

Roche does not explicitly disclose the number of confirmed incidents specifically related to corruption or bribery, nor does it report any convictions, legal decisions, or fines paid for violations of anti-corruption/anti-bribery laws during the reporting period.

Investigation and reporting procedures

Roche maintains multiple reporting channels:

• Chief Compliance Officer and the Compliance Officers network worldwide
• Roche Group Code of Conduct Help & Advice Line for compliance questions
• Roche Group speak-up channels (web and voice service) enabling confidential and anonymous reporting, available to employees, contractors, and external parties

All non-compliance reports are investigated, and Roche does not tolerate retaliation against employees who raise compliance concerns in good faith. The Business Ethics Incident Management System (BEIMS) enables tracking and monitoring of alleged violations from initial reports through to resolution. The Corporate Governance and Sustainability Committee and the Audit Committee of the Board of Directors are regularly informed of substantial violations and corrective actions.