RTL Group

Governance roles

Reference: pages 101-102. Composition and independence datapoints are also cross-referenced to Corporate governance (page 85 ff) in the IRO-2 index (page 112).

RTL Group SA is a Luxembourg public limited company with a one-tier board. At 31 December 2025 the Board of Directors had 13 members: three executive and ten non-executive directors, of whom 30.8 per cent are independent (page 101).

• The Executive Committee (CEO, COO/Deputy CEO, CFO) "is accountable for the Group's overall sustainability performance. This includes approving the environmental, social and governance (ESG) topics, which are material for reporting purposes, as well as the processes, actions and targets for addressing material impacts, risks and opportunities" (page 101).
• The CFO holds responsibility for external Group reporting and oversees sustainability-related risk management and the internal control system, with the EVP Communications & Investor Relations, who chairs Corporate Responsibility (page 101).
• The Audit Committee has at least four non-executive directors, two independent, meets at least four times a year and "oversees ESG-related topics, such as the outcome of the double materiality assessment and the ESG reporting process" (page 102).

Gender split (page 102): Executive Committee 0/100 women/men, Board 15/85, Audit Committee 25/75.

Information provided to and matters addressed by the bodies

Reference: pages 102-103.

Sustainability reaches the bodies through three standing forums (page 102): the Bertelsmann CR Council, meeting three to four times a year; an RTL Group CR Board of RTL Group and RTL Deutschland executives, coordinating diversity, editorial independence, content responsibility and climate protection; and annual CR Network meetings with all business units.

The Executive Committee receives regular updates from the EVP Communications & Investor Relations covering "sustainability progress, including principles, targets, measures, and key figures". Progress towards business-unit targets, "including RTL Group's 2030 climate goals", is reviewed in scheduled Executive Committee meetings (pages 102-103).

Key focus areas in 2025 (page 103): further development of ESG reporting processes and data management; adjustment of the 2018 base year in line with CSRD requirements and the 2030 climate target; and a Group-wide analysis of CO2 reduction potential across the business units.

The Corporate Compliance Committee reports regularly to the Executive Committee and submits ad hoc reports on serious breaches. The Audit Committee is informed by the CFO and the EVP in the presence of the Group's auditor; the key 2025 topic was "the audit of the sustainability report with limited assurance" (page 103).

Sustainability in incentive schemes

Reference: page 103. The disclosure is short and the scope is narrow.

RTL Group's remuneration system includes a short-term performance-related component, the STIP (short-term incentive plan). The whole of the FY2025 disclosure reads:

"Sustainability-related targets have been set in the STIP for 2025 for executives at Groupe M6 in relation to the number of news programmes covering environmental topics and the reduction of energy consumption, accounting for 5 per cent of the maximum bonus payout."

Points a reader should note:

• The linkage is confined to one business unit (Groupe M6), not to Group Executive Committee members or the Board.
• Weight is stated as 5 per cent of the maximum bonus payout, but no amount, no target level and no achievement percentage for 2025 are given.
• The two metrics are the number of news programmes covering environmental topics and energy consumption reduction; no GHG-emission metric is tied to pay.
• Nothing is disclosed on the proportion of variable remuneration that is climate-linked at Group level.

The IRO-2 index lists GOV-3 twice, once under General information and once under Climate change (page 112), so this is the Group's complete answer for both.

Statement on due diligence

Reference: pages 103-104. Appendix B marks the GOV-4 paragraph 30 datapoint as material (page 114).

RTL Group discloses a mapping table, "Core elements of sustainability-related due diligence", that points each of the five core elements to the sections of the statement where it is covered (page 104):

• Embedding due diligence in governance, strategy and business model – ESRS 2 GOV-1, GOV-1-G1, GOV-2, GOV-3, GOV-3-E1, SBM-1, SBM-3 and the topic-level SBM-3 sections for E1, S1, S4 and G1, plus entity-specific information.
• Engaging with affected stakeholders in all key steps – ESRS 2 GOV-2, SBM-2, IRO-1, S1-2, S4-2, G1-1, entity-specific information.
• Identifying and assessing adverse impacts – ESRS 2 IRO-1 and the topic-level SBM-3 sections for E1, S1, S4 and G1.
• Taking actions to address those adverse impacts – E1-1, E1-3, S1-3, S1-4, S4-3, S4-4.
• Tracking the effectiveness of these efforts and communicating – E1-3, E1-4, S1-4, S1-5, S4-4, S4-5.

The table is a signposting device only; no narrative on due diligence outcomes is given at this point in the statement.

Risk management and internal controls over sustainability reporting

Reference: pages 104-105.

"Sustainability is largely embedded within RTL Group's existing risk management and internal control system." Sustainability risk assessment is carried out as part of the double materiality assessment, with results and material IROs reported to the Executive Committee and, where appropriate, the Audit Committee (page 104).

Integration carries a caveat: material DMA risks "were subsequently aggregated and incorporated into the Group's risk universe in 2025", but because the DMA applies a distinct methodology "the assessment conducted in 2024 continues to be carried out separately, considering the existing risk management methodology for financial evaluation" (page 104).

Controls over reporting (page 105):

• Risks named are "the potential inaccuracy, incompleteness or delay of information".
• A minimum control framework covers ESG-related key data points; financial-reporting controls were adapted and new sustainability-specific controls developed.
• A binding control framework applies to decentralised data collection. Business units began implementing it in 2024, "with improvements in 2025 through tailored training".
• An annual self-assessment assesses control quality and triggers mitigating actions, with business unit topic owners managing the controls.

RTL Group joined Bertelsmann's climate risk analysis for the first time in 2024 (page 105).

Strategy, business model and value chain

Reference: pages 106-107, with cross-references to Corporate profile (page 40 ff) and Review by segments (page 71 ff) recorded in the IRO-2 index (page 112).

RTL Group is "a leading entertainment company across broadcast, streaming, content and digital, with interests in 52 television channels, six streaming services and 40 radio stations", active in 28 countries with 15,768 employees at 31 December 2025 (pages 106-107). RTL Deutschland is the largest business unit; streaming services are RTL+ (Germany, Hungary) and M6+ (France).

The stated business model is "to produce, aggregate, distribute and monetise the most attractive video content, across all formats and platforms" (page 107).

Value chain is described as seven overarching chains: broadcasting, streaming, ad-tech, content production, distribution, publishing and social media (page 107).

Corporate Responsibility is structured around three strategic pillars: content, social and society, and climate change (page 107). The stated sustainability goal is the 2030 climate target, with three main areas of action: employees, locations and products; the Group target "has not been broken down into groups of services, customer categories or geographical areas" (page 107).

Appendix B records no involvement in fossil fuel activities, chemical production, controversial weapons or tobacco (paragraph 40 (d) i-iv, page 114).

Interests and views of stakeholders

Reference: pages 108-110.

RTL Group distinguishes stakeholders "who influence the company's sustainability performance or the corresponding regulatory framework" from "stakeholder groups that are affected by the company's economic, social or ecological impact" (page 108).

The engagement table (page 109) covers seven groups with channels, purpose, important topics and example results:

• Employees and their representatives – employee survey, staff appraisals, European Works Council, media advisory board at RTL Deutschland, employee networks, speak-up channels.
• Consumers and end-users – customer support, feedback options, market research and studies.
• Business partners – supplier due diligence, analysis of human rights and environmental risks in the supply chain.
• Financial market participants – annual and interim reporting, ESG ratings, investor calls and conferences.
• Political decision-makers and authorities, media and journalists, and non-profits, the last receiving free airtime for charities.

Silent stakeholders are represented by proxy: "The inclusion of representatives of silent stakeholders (such as the natural environment) in the double materiality assessment process ensures their interests and views are incorporated" (page 110). The Executive Committee is informed of stakeholder concerns "on an ad hoc basis by the relevant specialist managers" (page 110).

Material impacts, risks and opportunities

Reference: page 110, with topic-level IRO tables at pages 117 (E1), 128 (S1), 140 (S4), 145-146 (G1) and 152-161 (entity-specific).

The Group materiality table (page 110) marks as material:

• E1 Climate change – climate change mitigation (I, R, O) and energy (I, R, O).
• S1 Own workforce – working conditions (secure employment, working time, adequate wages, social dialogue, freedom of association, collective bargaining, work-life balance, health and safety) and equal treatment and opportunities for all (gender equality and equal pay, training and skills development, violence and harassment, diversity), all impacts only.
• S4 Consumers and end-users – information-related impacts, personal safety, social inclusion (impacts only).
• G1 Business conduct – corporate culture (I, R, O), protection of whistleblowers (I), political engagement and lobbying (I, R, O), supplier relationships including payment practices (I), corruption and bribery (I).
• Seven entity-specific topics, from content responsibility to representation of society and access to content.

E2, E3, E4, E5, S2 and S3 do not appear and are marked "No" throughout Appendix B (pages 114-115). Across the topical tables, 64 individually typed IRO rows are described. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Process to identify and assess material IROs

Reference: pages 110-112, with the climate-specific IRO-1 at page 118.

The 2024 assessment was carried forward unchanged: "Apart from the sale of RTL Nederland ... there have been no further significant changes within the Group or its business environment. Accordingly, the double materiality assessment performed in 2024 remains unchanged and continues to form the basis for the 2025 reporting" (page 110). Only "the wording of the material impacts, risks, and opportunities was slightly harmonised and updated in 2025".

Four-step process (pages 111-112):

1. Corporate context – portfolio, locations, business relationships and services including the value chain; internal stakeholders acted as proxies for external ones.
2. Identification – the sector-agnostic topics of ESRS 1 AR 16 as the starting list, supplemented by ISSB sector topics and the two Codes of Conduct. Horizons: short-term one year or less, medium one to five years, long over five years.
3. Assessment – qualitative scoring 1 to 5. The material threshold was set at 4. For potential negative human rights impacts, "the severity of the impacts took precedence over their likelihood".
4. Validation – Executive Committee and Audit Committee involvement; RTL Deutschland, Groupe M6 and Fremantle participated, supported by an external consultancy.

No quantitative financial thresholds are disclosed.

Disclosure requirements covered

Reference: pages 112-113 for the content index, pages 114-115 for the Appendix B datapoint list.

RTL Group prints a full "Overview of RTL Group's material disclosure requirements" table (pages 112-113), by category, ESRS, section and name, with a column for references outside the sustainability report:

• General information – BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, with GOV-5 and SBM-1 cross-referenced to Corporate governance (page 85 ff), Corporate profile (page 40 ff) and Review by segments (page 71 ff).
• Climate change – GOV-3, SBM-3, IRO-1, E1-1 to E1-8, plus EU taxonomy. E1-9 is not listed.
• Own workforce – SBM-2, SBM-3, S1-1 to S1-6, S1-8, S1-9, S1-10, S1-14, S1-16, S1-17. S1-7, S1-11, S1-12, S1-13 and S1-15 are not listed.
• Consumers and end-users – SBM-2, SBM-3, S4-1 to S4-5.
• Business conduct – GOV-1, SBM-3, G1-1 to G1-6 and MDR-T.
• Entity-specific – ES-1 to ES-7.

A second table lists the Appendix B datapoints from other EU legislation, tagging each "Yes", "No" or "Phase-in", defined in footnote 40 as "Material data points that are not yet reported in 2025 due to the transitional arrangements" (pages 114-115). Phase-in applies to the E1-9 datapoints and to S1-14 paragraph 88 (e), days lost.

Transition plan for climate change mitigation

Reference: page 119.

RTL Group states plainly that it has no ESRS-conforming transition plan. "RTL Group's previous, current and planned climate protection activities relate to the short and medium-term period from 2018 to 2030. Accordingly, the company is not currently pursuing a long-term transition plan to achieve complete climate neutrality by 2050 in line with the Paris Agreement and the requirements of the ESRS" (page 119).

What is disclosed instead:

• A climate target pursued since 2020, covering 2018 to 2030.
• "The Group's transition approach is anchored in a quantified emission reduction target that is integrated into the Bertelsmann Group climate target and aligned with science-based pathways. The scope, ambition level and methodological basis of this target, including covered emission scopes, baseline year and alignment with Science Based Targets Initiative (SBTi) criteria, are described in detail under E1-4."
• Self-characterisation as "a media company with a comparatively low direct emissions intensity".
• Not excluded from the EU Paris-aligned benchmarks under Articles 12.1 (d) to (g) and 12.2 of Regulation (EU) 2020/1818.

Appendix B marks the E1-1 paragraph 14 datapoint, "Transition plan to reach climate neutrality by 2050", as not material (page 114). No locked-in emissions assessment and no CapEx or funding plan for the transition are given.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (climate), disclosed at page 118 of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The analysis was carried out in 2024 and not repeated in 2025: "the 2024 analysis remains valid and continues to form the basis for the 2025 reporting".

Classification (¶15). Risks are split into transition and physical, and the results table classifies each hazard: physical wind (storm, cyclone, tornado), physical temperature (heatwave, wildfires, chronic heat stress), physical water (floods, drought, heavy rainfall, "assessed as low"), physical solids (subsidence, landslide), transitory political and legal conditions, and transitory procurement markets.

Methodology (¶16). "The main locations of all RTL Group business units were included in the analysis of physical climate risks", using climate models and location data, with sensitivity analysed by activity type. "Risks from the value chains, on the other hand, were assessed at an aggregated level, as RTL Group is not dependent on individual suppliers or customers."

Scenarios (¶17). Physical risk used IPCC SSP5-8.5; transition risk used the IEA Net Zero Emissions 2050 scenario. Horizons run to 2030, 2040 and 2050, per TCFD.

Gaps. No temperature projection per scenario (¶17 (a)(iii)); "The risks were not quantified".

Resilience in relation to climate change

Back-filled from ESRS 2 IRO-1 (climate) and SBM-3, disclosed at pages 116-118 of the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS-defined resilience analysis is described. The report offers one conclusion drawn from the 2024 climate risk analysis: "As an outcome of the analysis, management assumes that the business models, products and services, and cost structures, can be adapted to the consequences of advancing climate change" (page 118).

The financial-effect conclusion follows: "The analysis did not identify any climate-related risks or opportunities that would have a material financial effect and, therefore, did not result in any disclosures in the finance-related risks and opportunities report" (page 118).

Material to weigh against that conclusion:

• Risks were assessed but not quantified, physical or transition.
• "The pricing of GHG emissions is the most relevant transition risk. The Group's larger business units also generate higher emissions (RTL Deutschland, Groupe M6, Fremantle) and are thus more affected by rising CO2 prices."
• "The availability of recycled paper in particular could pose a risk of rising prices for RTL Deutschland's magazine business."

Not disclosed: significant areas of uncertainty (¶19 (b)) and capacity to adjust or adapt across the time horizons (¶19 (c) / AR 10).

Policies related to climate change mitigation and adaptation

Reference: page 119.

The governing document is the RTL Group Environmental Policy, "implemented and communicated in 2024" and "geared towards CSRD" (pages 116, 119). It "expresses the shared understanding of environmental protection at RTL Group, the aspiration and the required organisational framework to continuously improve the company's environmental performance".

Content:

• Climate protection and energy, covering energy efficiency and renewable energy use, and adaptation to climate change.
• Non-material topics are also covered: pollution minimisation, water resources, intact ecosystems and sustainable forestry, resource efficiency and circular economy.
• The 2030 climate target itself, detailed under E1-4.
• A concrete procurement rule: "The procurement of renewable energy is an important requirement for all locations that purchase more than 100 megawatt hours of electricity."
• Requirements for photovoltaic systems at the Group's own sites.

Governance and scope: the Executive Committee determines content and Group-wide goals; business unit management handles implementation. The policy sits on the intranet and "is reviewed every two years". It applies to RTL Group SA, CLT-UFA SA and their controlled subsidiaries. It reaches the value chain only indirectly, through procurement and the Supplier Code of Conduct.

Actions and resources in relation to climate change policies

Reference: pages 119-120.

The 2030 climate target "prioritises measures to avoid and reduce emissions over offsetting remaining emissions", with Group targets cascaded into business-unit targets and matching measures (page 119).

Named 2025 actions (page 120):

• RTL Deutschland "successfully completed the external audit and certification of its energy management system in accordance with the ISO 50001 standard".
• RTL Deutschland "completed the relocation and optimisation of office spaces, resulting in a significant reduction in energy consumption and savings of GHG emissions of about 2,200 t CO2e".
• "In 2025, 96 per cent (2024: 96 per cent) of electricity purchased was obtained from renewable energy sources using green electricity tariffs or guarantees of origin."
• Production certifications under Green Motion (Germany) and EcoProd (France); at Fremantle "over 30 shows complied with the standards required by Albert".
• "Groupe M6 alone covered more than 873 program hours with carbon footprints".
• A GHG Accounting Manual for TV and Film Productions, implemented in 2024.

Resources. No CapEx or OpEx amount is attached to any action. Implementation "depends on factors such as availability of green technology and low-carbon services", and "Initiatives are not dependent on the availability or allocation of resources" (page 120).

Targets related to climate change mitigation and adaptation

Reference: pages 120-121.

The target. Set in 2021: reduce GHG emissions 50 per cent by 2030 against a 2018 baseline, with "Unavoidable Scope 1 and Scope 2 emissions ... to be offset by 2030". The annual reduction rate is 4.2 per cent over 2018-2030.

Baseline restated this year. The target forms part of the Bertelsmann Group climate target, "which was subject to revalidation by the Science Based Targets Initiative (SBTi) at the end of the reporting year". RTL Group revised the 2018 baseline "to reflect portfolio effects including the sale of RTL Nederland, methodological changes, and the exclusion of selected emission sources in category 3.1 and 3.9. The revised base year value 2018 is 386,600 t CO2e (previously 279,000 t CO2e)", following SBTi Corporate Near-Term Criteria (V5.3).

Scope. Covered Scope 3 categories are purchased goods and services, upstream transportation and distribution, waste in own operations, business travel, employee commuting and upstream leased assets. "According to SBTi criteria, the level of ambition for Scope 1 and Scope 2 emissions is aligned with a 1.5 degrees Celsius pathway".

Progress (page 121, tCO2e): 386,600 (2018), 241,319 (2024), 216,201 (2025), 193,300 (2030), a "reduction of 44 per cent until the end of 2025 (2024: 38 per cent)". Groupe M6 completed SBTi validation of its own target in 2025. No adaptation target is disclosed.

Energy consumption and mix

Reference: pages 121-122.

Total energy consumption in 2025 was 93,053 MWh (2024: 100,020 MWh), the fall attributed to the sale of RTL Nederland and to office relocation and optimisation in Germany.

Coal, other fossil sources, nuclear and renewable fuels including biomass are all nil. Green electricity share at all reported locations was stable at 96 per cent.

Basis (page 121): consumption covers owned and rented offices, production studios and the own vehicle fleet, and differs slightly from the Scope 1 and 2 perimeter because leased buildings without operational control sit in Scope 3.8. Data come from meter readings, supplier reports, landlord confirmations or petrol receipts; for companies under 50 employees consumption is extrapolated per employee, "At less than 1 per cent" of electricity. Consumption is reported market-based, not location-based. No energy intensity per net revenue is presented.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 122-124.

"Of this, about 1 per cent were direct emissions (Scope 1) and 99 per cent were indirect emissions." The decrease is attributed to the sale of RTL Nederland, reduced business travel at RTL Deutschland, lower spend-related emissions and lower emissions from investments. Scope 1 from regulated emission trading schemes is 59 per cent (2024: 47).

Largest Scope 3 categories, 2025: purchased goods and services 180,598; business travelling 52,076; investments 48,748; upstream leased assets 25,640; employee commuting 10,473; capital goods 8,735. Intensity: 58 tCO2e per million euro of revenue location-based (2024: 60), 56 market-based (2024: 58).

Method: GHG Protocol Corporate, Scope 2 Guidance and Corporate Value Chain standards; GWP100 AR5; factors from IEA, UK DESNZ, ADEME, ProBas and Open CEDA. Primary supplier data "cannot be reliably determined ... and is estimated by the company at up to to 20 per cent" (page 123).

GHG removals and carbon credits

Reference: pages 124-125.

"Following RTL Group's climate target, offsetting activities are limited to date." Reduction or removal financed through purchased carbon credits outside the value chain was 1,136 tonnes of CO2 in 2025 (2024: 1,526 tonnes).

Two points to note. The company reports no GHG removals at all: the whole volume is reduction projects, with neither biogenic nor technological sinks. And cancellation lags, with 364 tonnes to be cancelled "after the GHG balance sheet has been prepared in the first quarter of 2026" (page 124).

All credits carry the Verified Carbon Standard and none is issued inside the EU. The offsetting ambition sits in E1-4: unavoidable Scope 1 and Scope 2 emissions are to be offset by 2030 (page 120).

Internal carbon pricing

Reference: page 125.

RTL Group operates a shadow price, not an internal fee or trading scheme. "RTL Group uses scenario analyses to identify potential future costs from the company's GHG emissions. For the price development, the company uses price scenarios from the IEA and other sources, from which it derives internal CO2 shadow prices differentiated by region for the years 2025 to 2050."

Two price tracks are maintained: internal CO2 prices for regulated markets (emissions trading systems or taxes), and assumptions for the price development of carbon credits used as compensation, linked to E1-7.

Scope of application. "RTL Group uses these internal CO2 shadow prices exclusively to simulate the potential costs of future GHG emissions (Scope 1, Scope 2 and Scope 3) and considers these when assessing the economic viability of decarbonisation measures required to achieve its climate targets." The same mechanism underpins the 2030 gap analysis at page 107.

Explicit exclusions. "These effects are not considered in the consolidated financial statements, nor in the determination of the useful lives and residual values of assets, the impairment testing of assets, or the measurement of the fair value of assets acquired through business combinations."

Not disclosed: the price level in euro per tonne and the share of emissions covered.

Policies related to own workforce

Reference: pages 128-130, with the Group policy overview at pages 105-106. Own workforce "comprises the company's employees ... as well as self-employed external workers, freelancers or agency workers" (page 127).

Policies covering S1 (pages 129-130):

• Code of Conduct – binding minimum standards on fair and healthy working conditions, working hours and fair remuneration, a safe workplace, measures against violence, harassment or discrimination, equal treatment, social dialogue, freedom of association and collective bargaining. In nine languages; mandatory training for all employees.
• Supplier Code of Conduct – requires partners to extend the same requirements through their own value chain.
• Policy on Fair Working Conditions – references the UN Guiding Principles, the ILO Core Labour Standards and the OECD Guidelines.
• Diversity-related policy – "RTL Group does not tolerate discrimination based on race, colour, ethnicity, national or social origin, age, gender, gender identity or expression, sexual orientation, pregnancy, marital or parental status, disability, religion or belief"; LGBTIQ+ discrimination, racism, antisemitism and sexism are named.
• Policy on Safety and Policy on Health and Wellbeing – local systems aligned with ISO 45001.
• Principles of Hiring Policy and Policy on Engaging External Personnel.

A Human Rights Statement published in 2022 applies Group-wide.

Engaging with own workforce and workers' representatives

Reference: pages 130-131.

Channels named:

• the speak-up channel, employee network groups and topic-specific working groups;
• the biannual employee survey, which "includes questions on key employee-related topics such as working hours, work-life balance, diversity, fair pay and health and safety" and carries a CR Index;
• employee representatives, including the European Works Council;
• interdisciplinary working groups assessing the IROs of material topics, feeding the double materiality assessment.

Responsibility. "Overall responsibility for involving employees and their representatives lies with RTL Group's Head of Human Resources." Survey results go to the Executive Committee, decision-makers at Group and business unit level, the European Works Council and local works councils, then to all employees. Improvement measures are elaborated by employees and management using indices on creativity, entrepreneurship, learning culture, health and wellbeing and CR overall.

In practice: a Learning Community of all business units meeting at least quarterly; Fremantle's ten employee-led groups, each sponsored by a member of the global leadership group; RTL Deutschland's Arbeitskreis Gesundheit, including works councils, company physicians and representatives for employees with disabilities; and networks including be.queer and FEMpowermentNET.

Remediation processes and channels to raise concerns

Reference: page 132. Appendix B marks the S1-3 paragraph 32 (c) grievance handling datapoint as material (page 115).

Speak Up is RTL Group's whistleblower system. Design points disclosed:

• available "in many different languages";
• reports can be made online or by telephone, and anonymously if desired;
• "particular importance was attached to ensuring access for the company's own employees and taking measures to counteract potential obstacles such as a lack of resources and information, as well as language barriers";
• external ombudspersons appointed by RTL Group offer an alternative route;
• concerns can also go to supervisors, senior management, local compliance officers, Human Resources, Legal, Finance, Internal Audit, employee representatives, or Group Compliance.

Each report is handled under the Guideline for Handling Compliance Violations and the Reporting and Handling of Significant Compliance Incidents Policy (pages 132, 147).

Effectiveness tracking. "As part of the biannual employee survey, employees are asked to rate topics related to the complaints procedure. Feedback is then incorporated into the further development of the procedure." The wider system is reviewed at least annually on complaint numbers, complainant demographics, resolution rate and average processing time (page 149).

Taking action on material impacts on own workforce

Reference: pages 132-135.

Training and skills (pages 132-133). Peoplenet is the global learning, recruitment and talent portal, with Skillsoft content, on a 70:20:10 model. Employees could join Bertelsmann's three-year Tech and Data Scholarship Initiative (2023-2025), which "offered more than 50,000 places", via Udacity, Coursera and Harvard Online. Executive programmes named are BeReady, Harvard Business School, Stanford and INSEAD. Skills-gap analysis of tech and data roles goes at least annually to the Nominations and Compensations Committees.

Health, safety and wellbeing (pages 133-134). A Group-wide Fit for Work campaign and Mental Health Month; RTL Deutschland expanded the Phileo app, launched a 24/7 counselling hotline for employees and immediate family, trained 30 mental health first aiders and issued a guideline on handling distressing video material.

Diversity (page 134). Fremantle Spain adopted "a new four-year equality plan ... through dedicated measures, anti-harassment training, work-life balance initiatives and gender-sensitive recruitment"; Groupe M6 continued weekly French Sign Language classes, "an integral part of its disability inclusion programme for nearly 20 years".

Social dialogue: a European Works Council established in 2001, meeting three to four times a year, and 18 local works councils at RTL Deutschland.

Targets related to own workforce

Reference: pages 134-135.

One quantified Group target is disclosed. "RTL Group's Executive Committee reviewed the Group's objectives and set the following quantitative target: to increase the share of women in top management positions to at least 40 per cent by the end of 2030. The Group reports on its progress towards this target each year (see S1-9)."

Progress against it, from S1-9: women held 30 per cent of Group and senior executive positions at the end of 2025, down from 31 per cent in 2024, on a base of 98 positions (page 137). On that trajectory the gap to the 2030 target widened rather than closed.

For every other material employee topic there is no target, and the company says so: "in the light of the first-time implementation of the double materiality assessment in 2024, there are currently no Group-wide targets in the sense of the requirements according to MDR-T for all other material employee-related topics" (page 135).

That covers secure employment, working time, adequate wages, social dialogue, freedom of association, collective bargaining, work-life balance, health and safety, equal pay, training, violence and harassment, and diversity, all material at page 110.

Characteristics of the undertaking's employees

Reference: pages 135-136. Headcount at 31 December 2025, excluding interns and trainees; the country split follows the employing entity's registered office.

Total 15,768 employees (2024: 17,612), a fall of 1,844 driven mainly by the disposal of RTL Nederland.

Permanent employees 11,931 (2024: 12,941), temporary 3,837 (2024: 4,671), of which 3 on non-guaranteed hours. "the majority ... (76 per cent; 2024: 73 per cent) were employed on a permanent basis".

Turnover. 9,978 left in 2025 (2024: 9,777); the overall turnover rate was 60 per cent (2024: 55 per cent), while "The turnover rate on open-end contracts was 17 per cent". The company explains the gap: it "is largely driven by Fremantle's production business, where roles behind and in front of the camera are specific for each production", with fixed-term contracts for each project's duration (page 136).

Collective bargaining coverage and social dialogue

Reference: pages 136-137. Rates are calculated on the S1-6 headcount at 31 December 2025; Germany and France are reported separately because they meet the ESRS size criteria. No estimates were used.

Precise figures appear in the narrative: "In Germany and France, the percentage of employees covered by collective agreements was 98 per cent (2024: 81 per cent) and 100 per cent (2024: 100 per cent) respectively in 2025" (page 137).

The German jump is a methodology change, not a performance improvement, and the company says so: "The increase results from a further refined data collection process, including workshops conducted with business units. The figures reported in the prior year were appropriately determined based on the data available at the time and a consistently applied methodology."

"In both Germany and France, employee representation covered 100 per cent of the workforce, unchanged from the previous year." The European Works Council supplements this transnationally (pages 134, 137).

No coverage is disclosed for employees outside the EEA, who numbered 4,332 in the "Other" country grouping at page 135.

Diversity metrics

Reference: page 137. Age bands are based on the S1-6 headcount at 31 December 2025; no estimates were used.

"19 per cent were younger than 30 (2024: 20 per cent) and 27 per cent older than 50 (2024: 24 per cent)."

The overall workforce is close to balanced, "with 46 per cent men (2024: 46 per cent) and 54 per cent women (2024: 54 per cent)", but the share of women in top management fell from 31 per cent to 30 per cent against a target of at least 40 per cent by the end of 2030 (pages 135, 137).

Top management is defined as "the Group and senior executives ... positions that are particularly important for the achievement of the Group's business and strategic goals", comprising Executive Committee members, business unit CEOs and their direct reports, Management Board members, Executive Committee direct reports at the Corporate Centre, managing directors of the businesses, heads of business unit departments and Senior Vice Presidents at the Corporate Centre (page 137).

Adequate wages

Reference: page 137.

The disclosure is a nil-exception statement: "In 2025, all employees of RTL Group were adequately remunerated in accordance with the applicable benchmarks."

Method. "The coverage rate will be calculated based on the review of all employees who worked for RTL Group during the financial year 2025 (starting from day one of employment in the reporting year). Wage adequacy is verified locally by comparing wages against a centrally provided, continuously updated list of applicable benchmarks for the countries (or sub-grouping levels such as regions, industries, etc) in which RTL Group operates as of 31 December 2025. No estimates were made in collecting the metrics for S1-10."

Two features are worth noting. The population tested is everyone who worked during the year, not only those on the books at year end, which is a wider test than headcount. And adequacy is judged against a centrally maintained benchmark list applied locally, rather than a single external reference such as a national minimum or living wage; the benchmarks are not published, so a reader cannot recompute the result.

Adequate wages is one of the material S1 sub-sub-topics (page 110), and the underlying commitment sits in the Policy on Fair Working Conditions (page 106). No employees are reported below the applicable benchmark.

Health and safety metrics

Reference: page 138.

Both movements are partly method rather than performance. The coverage jump from 24 to 87 per cent "reflects enhancements to RTL Group's evaluation methodology through targeted workshops and internal alignment initiatives", against criteria including policies, risk assessments, defined roles, measurable targets and systems aligned with or certified to ISO 45001. The accident increase is attributed to production work "which often involves on-location filming, set construction, and the use of heavy equipment", and also "reflects a more consistent application of reporting criteria".

Phase-in. "In accordance with the transitional provisions set out in the ESRS, reporting on the number of cases of reportable work-related illnesses and the number of days lost will take place" later; Appendix B tags paragraph 88 (e), days lost, as "Phase-in" (page 115). The fatality count "includes not only RTL Group's employees".

Compensation metrics (pay gap and total compensation)

Reference: page 138, with commentary at page 139.

Both moved sharply against the company, and both are explained (page 139).

On the pay gap: "The increase was primarily driven by changes in the Group's scope during the financial year 2025, leading to a reduced proportion of female employees in higher-wage countries, in particular due to the sale of RTL Nederland and structural changes at RTL Deutschland. In addition, a termination indemnity payment in the context of the exit of a long-serving Executive Committee member contributed to the increase."

On the pay ratio: "The increase was driven by a termination indemnity payment ... Excluding the termination indemnity payment, the adjusted ratio amounted to 61:1." Even adjusted, the ratio rose from 54:1 to 61:1, "mainly driven by changes in the variable remuneration components of the highest paid individual".

Method (page 138): employees with an active relationship at 31 December 2025; actual total gross income over contractual annual hours, corrected for unpaid absence and changes in employment level to give an effective hourly wage; foreign currency at the RTL Group budget exchange rate 2025.

Incidents, complaints and severe human rights impacts

Reference: page 139.

The falls are large and the company attributes them to a definitional change rather than to performance: "In the reporting year, the presentation and calculation of complaints and discrimination incidents were refined in line with the requirements of ESRS S1-17, paragraph 103. To ensure comparability, the figures for 2024 were recalculated accordingly. This recalculation does not represent an improvement in performance but serves to enhance methodological consistency with the ESRS requirements." Case documentation "was improved, particularly by systematically recording whether the person submitting the complaint was part of RTL Group's own workforce".

"As a result of these complaints and incidents, RTL Group had to pay €nil in fines, penalties, and compensation. Furthermore, RTL Group is not aware of any severe human rights issues during the reporting period."

Data source: RTL Group's case management, with Groupe M6 supplying data from its own compliance management system in line with the Group definition. No estimates were made.

Policies related to consumers and end-users

Reference: pages 141-142. Appendix B marks the S4-1 paragraph 16 policies datapoint and paragraph 17 non-respect of the UN Guiding Principles and OECD Guidelines as material (page 115).

Code of Conduct and Supplier Code of Conduct (page 141). Beyond the employee content in S1-1, the Code "also includes principles on material information-related impacts, personal safety and social inclusion in relation to consumers and end-users". It stipulates "the utmost care and strict confidentiality regarding customer data", requires "respect for privacy and the correct and responsible handling of information, opinions and images", emphasises "the preservation of editorial and journalistic independence and the protection of children and young people", and stresses "the relevance of truthful information in marketing and advertising".

Newsroom Guidelines (page 141), published on the website. Editors-in-Chief ensure local application; the Chairman of CR is responsible at Group level. They "aim to prevent, among other things, the spread of misinformation or fake news" and set binding principles for truthful and impartial reporting; prohibition of unfair research methods and political interference; respect for privacy and the presumption of innocence; sparing use of graphic content; sensitivity to children's personal rights; and separation of editorial content from advertising.

Engaging with consumers and end-users

Reference: page 142.

Engagement happens "at different stages of the value chain, in particular prior and during content and product development, and on an ongoing basis during the distribution and monitoring phase to assess audience satisfaction and potential impacts and improvements". Named channels are social media presence, meet the user events, qualitative group discussions, tracking studies and surveys via online access panels. The concrete example is RTL Deutschland's Ask your Audience Panel, "which includes several households equipped with a Home Research Box for TV and video content feedback".

Structure is decentralised, by admission. "there is no Group-wide centralised process for working with consumers and end-users given the local nature of RTL Group's business models." Overall responsibility "lies with the respective managing directors of the various businesses".

Effectiveness is not directly measured, and the company says so. "RTL Group does not operate a dedicated, stand-alone framework to measure the effectiveness of consumer and end-user engagement. Instead, selected indicators, such as audience ratings as well as the volume and nature of consumer feedback, are monitored and serve as indirect measures of engagement outcomes."

Remediation processes and channels for consumers and end-users

Reference: page 142.

The same infrastructure serves employees and consumers: "Consumers and end-users also have access to RTL Group's speak-up channels which enable confidential, encrypted and, if desired, anonymous dialogue with the Compliance department. The grievance mechanisms described to address negative impacts also apply to consumers and end-users."

Awareness. "RTL Group's Code of Conduct details the different speak-up channels and provides instructions on how to access them. This information is also published on RTL Group's corporate website." External ombudspersons and external reporting bodies remain available (page 148).

Handling. The Compliance department manages the channels and coordinates investigations. "reports submitted via the speak-up channel are systematically recorded and categorised according to their nature, including whether they originate from internal or external stakeholders."

Remedy. "Where RTL Group identifies that it has caused or contributed to a material negative impact, appropriate corrective measures are determined and implemented by the responsible specialist function within the respective business unit. Such measures may include clarification or removal of content or investigation processes."

No count of consumer or end-user reports received in 2025 is published.

Taking action on material impacts on consumers and end-users

Reference: pages 142-144.

Structural point first. RTL Group routes its S4 actions through the entity-specific chapter: "the impacts, risks and opportunities (IROs) identified for ESRS S4 Consumers and end-users are comprehensively addressed within the chapter dedicated to entity-specific material topics ... The actions outlined under ES1 to ES7 align with the measures required for mitigating IROs in the context of ESRS S4" (page 143).

Group-level actions named (pages 142-143): Group-wide training on data protection and the use of artificial intelligence; specialised journalist training such as RTL Deutschland's RTL School of Journalism; and quality assurance processes. "In 2025, RTL Group reported 0 serious human rights violations or incidents related to consumers and end-users".

Advertising actions (pages 143-144): RTL Deutschland's cross-genre climate coverage since 2019, its Diversity Week and annual Sustainability Week under the claim Für mehr Leben, support for Initiative 18, a partnership with Telekom against online hate, and the Stand UP initiative with L'Oréal Paris. M6 Unlimited runs 6green, Comportements Responsables and Journées Engagées.

Controls (page 144): due diligence on new advertising partners and controls "to ensure compliance with all legal requirements for the selection of advertising clients", including child protection.

Targets related to consumers and end-users

Reference: page 144. The disclosure is a stated absence of targets, which is itself the answer.

"The implementation of the Group strategy and operational business responsibility with the implementation of business-specific measures and targets is largely delegated to the business units and Group companies in line with the principle of subsidiarity. There are no targets set at Group level for the material topics mentioned in S4 as defined by the requirements of the MDR-T. Nevertheless, the effectiveness of related policies and actions is monitored through established governance, compliance and reporting processes at Group and business unit level. Where applicable, targets are defined and tracked within the respective business units."

The business-unit targets referred to are not listed, quantified or dated anywhere in the statement, so a reader cannot verify what exists or track progress.

The same position recurs for the seven entity-specific topics that carry the substance of RTL Group's consumer-facing impacts: "no quantitative targets and metrics are disclosed for these entity-specific topics in accordance with the requirements of MDR-T ... and MDR-M ..., as RTL Group does not consider the data on these topics to be sufficiently classified, complete or measurable" (page 151). That is a data-readiness argument, not a materiality argument.

Business conduct policies and corporate culture

Reference: pages 144-148. Appendix B marks the G1-1 paragraph 10 (b) and 10 (d) datapoints as material (page 115).

Compliance Management System (page 144). A Group-wide CMS "to prevent illegal or unethical business conduct"; each business unit has a designated compliance responsible. The Corporate Compliance Committee is chaired by the CFO and includes the General Counsel, Head of Internal Audit, Head of Human Resources and Head of Compliance. "The CMS is subject to regular self-assessments."

Policies (pages 146-148): the Code of Conduct and Supplier Code of Conduct; the Reporting and Handling of Significant Compliance Incidents Policy, addressing "corporate culture and whistleblower protection"; the Guideline for Handling Compliance Violations; the Anti-Corruption and Integrity Policy, covering gifts and invitations, third-party due diligence, money laundering and conflicts of interest; and Guidelines on donations, sponsoring and memberships.

Whistleblower protection (page 148). Channels run by phone and online, encrypted and anonymous on request. "RTL Group does not tolerate attempts at intimidation or reprisals against employees who report actual or suspected misconduct in good faith." The Luxembourg whistleblower law has applied since 16 May 2023. Code of Conduct training is given on joining, on update and as a one-year refresher; no completion rate is disclosed.

Management of relationships with suppliers

Reference: pages 148-149.

The instrument is the Supplier Code of Conduct, which "requires all business partners of RTL Group who act for, with or on behalf of the company to comply with minimum compliance standards". Requirements fall into three groups (page 149):

• integrity – compliance with applicable law, anti-corruption, antitrust law, conflicts of interest;
• treatment of employees – human rights, fair working conditions, anti-discrimination, health and safety;
• the environment – responsible use of natural resources.

Cascade through the chain. Requirements "are to be passed on by the business partner along the value chain to third parties, provided such parties are used in the context of the business partner's activities for RTL Group (for example, subcontractors)."

Due diligence. "Appropriate due diligence of business partners is an indispensable part of RTL Group's compliance programme. The review is risk-oriented when concluding business relationships and before engaging a third party. The scope and depth of the review may vary and depend on the risk profile of the Group company and ... the respective business partner."

Not disclosed: any coverage figure for supplier screening or audits, any risk-tier breakdown, and any treatment of vulnerable suppliers. Payment practices are reported separately under G1-6.

Prevention and detection of corruption and bribery

Reference: pages 149-150.

Framework. "The compliance objectives defined for the anti-corruption risk area are outlined in the Anti-corruption and Integrity Policy and conveyed in the course of various proactive and awareness-raising measures", including intranet material and a practical training course.

Reporting duty. "Non-adherence to the Anti-corruption and Integrity Policy constitutes a major compliance violation ... and must be reported", binding all employees in a managerial function and those with special compliance responsibility.

Investigation independence (page 149). A conflict-of-interest check precedes commissioning, and "Employees and managers who are or could be involved in a case cannot be part of the investigating body."

Effectiveness review. The speak-up system "is reviewed at least annually", considering "the number of complaints received, the demographics of complainants, the proportion of resolved versus unresolved complaints, and the average processing time".

Training (page 150). "In 2025, a total of 12,021 (2024: 1,720) employees were nominated for the online training course Protection against corruption, and 68 per cent (2024: 59 per cent) of these completed the online course", plus 81 in-person participants. On those figures roughly 3,850 nominated employees had not completed it.

Targets related to business conduct

Back-filled from the MDR-T section of the business conduct chapter (page 150), where targets are addressed as a Minimum Disclosure Requirement rather than a numbered DR. G1-3 became a standalone DR only in the 2025/2026 ESRS. MDR-T is itself listed in RTL Group's IRO-2 index under Business conduct (page 113), so this is a disclosure the company claims.

No quantified, dated business conduct target is disclosed. The MDR-T section gives stated endeavours: to "ensure responsible and ethical behaviour towards employees, business partners, government authorities, society and the environment"; to "promote a corporate culture that is consistent with the core principles stated within RTL Group's Code of Conduct"; and to "build and establish trusting relationships with the company's diverse stakeholders".

Two absolute positions are stated: "RTL Group has zero tolerance for violations with the law, harassment, discrimination and retaliation against whistleblowers", and "For the risk area of anti-corruption, RTL Group aims to prevent and uncover all forms of corruption".

Effectiveness tracking in the absence of targets, MDR-T's other limb: achievement "is measured in particular on the basis of the number of participants in the compliance training courses offered, as part of the reporting of actual or potential compliance-relevant issues and any subsequent (internal) investigations".

Incidents of corruption or bribery

Reference: page 150. Appendix B marks the G1-4 paragraph 24 (a) fines and 24 (b) anti-corruption standards datapoints as material (page 115).

The result is a nil return: "In 2025, there were 0 conviction(s) against corruption and bribery regulations. RTL Group therefore had to pay €nil in fines in this context."

Reporting basis: "The data on number of convictions comes from RTL Group's case management. Groupe M6 has its own compliance management system and provides its data in accordance with RTL Group's definition for Group reporting. No estimates were made when collecting the G1-4 metrics."

Two limits are worth holding in mind. The metric disclosed is convictions, narrower than the ESRS G1-4 requirement to report confirmed incidents: the number of confirmed incidents, the number in which employees were dismissed or disciplined, and the number involving contracts with business partners terminated or not renewed are not separately stated. And no prior-year comparative for convictions is given.

Related figures elsewhere: 8 employee complaints and 4 confirmed discrimination or harassment incidents, with €nil in fines, penalties and compensation (page 139).

Political influence and lobbying activities

Reference: pages 150-151.

Donations position, stated as a control rather than a figure (page 150): "In accordance with Executive Committee policies, RTL Group does not make any donations, memberships or sponsorships to politicians or political parties, individuals, profit-oriented organisations or institutions whose basic attitude is not in line with liberal democratic principles ... Compliance is confirmed by signature in a declaration of completeness at business unit level. In addition, active confirmation is provided in the letter of representation at local level."

Lobbying objectives (page 151): "The most important objectives include respect and protection of intellectual property, freedom and independence of the media, proportionate regulation of tech and data and the preservation of cultural and journalistic diversity."

Revolving-door datapoint, answered as a nil return: "There were no appointments of any members of the administrative, management and supervisory bodies who held a comparable position in public administration (including regulators) in the two years preceding such appointment in the current reporting period."

Not disclosed: total financial or in-kind political contributions by country, and registration in the EU Transparency Register or national equivalents.

Payment practices

Reference: page 151.

Basis of preparation: "RTL Group analysed the payment behaviour towards suppliers for supplier invoices issued and paid in the period from 1 October 2024 to 30 September 2025 using a representative sample. There are no uniform standard payment terms for these business relationships. The business relationships analysed cover trade payables." The sample size and selection method are not disclosed, and the measurement window is offset from the financial year.

No standard terms exist, and the company explains why: "Due to the heterogeneity of RTL Group, the standard terms of payment to its suppliers vary depending on the business units, markets and countries involved ... For this reason, RTL Group has neither Group-wide payment guidelines nor standard payment terms. This also applies to small and medium-sized suppliers."

Causes of delay are named: "factual clarification in the multi-stage invoice approval process and ... scheduled payment runs that do not take place daily". "There are currently no pending legal proceedings at RTL Group due to late payments."