Sopra Steria

The role of the administrative, management and supervisory bodies

Composition and independence of the Board of Directors

As of 31 December 2024, the Board of Directors comprised 17 members with voting rights:

• 14 Directors appointed by shareholders at the General Meeting
• 3 Directors representing employees and employee shareholders (Hélène Badosa, William Beaumond, Astrid Anciaux)

Executive vs non-executive breakdown:

• 1 Chairman (executive company officer)
• 1 member of Executive Committee (salaried)
• 15 non-executive members

Independence: 10 Directors are considered independent, accounting for 71% of Directors appointed by shareholders at the General Meeting. The independence assessment is conducted annually by the Nomination, Governance & Corporate Responsibility Committee and the Board of Directors, based on the 8 criteria set out in Article 10 of the AFEP-MEDEF Code.

Gender diversity:

• Female Directors appointed by shareholders: 6 out of 14 (43%)
• Overall gender split: 43% women, 57% men (among Directors appointed by shareholders)
• All three standing committees are chaired by women
• The five female Independent Directors are members of at least one committee

Nationality:

• 5 out of 17 Directors hold citizenship from a country other than France
• Nationalities represented: French, American, British, Irish, Belgian

Age:

• Average age: 65 years (at 31/12/2024)
• 3 out of 17 Directors are over 75 years old
• Articles of Association (Art. 14) limit the proportion of Directors aged over 75 to one third

Average length of service: 8 years

• 60% of Independent Directors have been sitting on the Board for less than six years

Committees with sustainability oversight

The Board of Directors has established three specialized committees:

Audit Committee

• Chairwoman: Marie-Hélène Rigal-Drogerys (Independent Director)
• Members (3): Marie-Hélène Rigal-Drogerys, Sylvie Rémond, Michael Gollner
• Attendance rate in 2024: 100%
• Responsible for monitoring statutory audit of financial statements, reviewing financial statements, assessing exposure to risks, and verifying procedures for gathering and checking information

Nomination, Governance & Corporate Responsibility Committee

• Chairwoman: Kathleen Clark (Sopra GMT representative)
• Members (7): Sopra GMT (represented by Kathleen Clark), Pascal Daloz, Éric Hayat, Noëlle Lenoir, Éric Pasquier, Pierre Pasquier, Rémy Weber
• Attendance rate in 2024: 92%
• Responsible for:
  • Conducting annual review of succession plan for Chairman and CEO
  • Selection process for Independent Directors
  • Monitoring proportion of Independent Directors
  • Annual review of status of each Board member regarding independence requirements
  • Double materiality assessment methodology for CSRD
  • Targets for increasing proportion of women in senior management positions

Compensation Committee

• Chairwoman: Sylvie Rémond (Independent Director)
• Members (7): Sylvie Rémond, Hélène Badosa, Sonia Criseo, André Einaudi, Éric Hayat, Jessica Scale, Sopra GMT (represented by Kathleen Clark)
• Attendance rate in 2024: 100%

Skills matrix and expertise

The Company has identified 9 key competencies for Board representation:

1. Knowledge of consulting, digital services, software development, ability to promote innovation – Represented by at least half of Directors (A)
2. International teams and organisations – Represented by at least half of Directors (A)
3. Finance, risk management and control – Represented by at least half of Directors (A)
4. Human resources and labour relations (CSR) – Represented by at least half of Directors (A)
5. Knowledge of one of the Group's main vertical markets – Represented by between one third and half of Directors (B)
6. Entrepreneurial experience – Represented by between one third and half of Directors (B)
7. CEO of a major group – Represented by between one third and half of Directors (B)
8. Mergers and acquisitions – Represented by at least half of Directors (A)
9. Operational experience within Sopra Steria Group – Represented by between one third and half of Directors (B)

Additional CSR-related competencies:

• Environmental and climate-related issues (CSR) – Represented by at least one third of Directors (C)
• Social issues (CSR) – Represented by between one third and half of Directors (B)

Separation of roles

On 19 June 2012, the Board of Directors decided to separate the roles of Chairman and Chief Executive Officer. This decision was confirmed in 2018, 2021 and 2024.

Chairman of the Board of Directors:

• Pierre Pasquier (since founding in 1968)
• Responsible for: guiding strategy implementation, assisting with Group transformation, overseeing investor relations and shareholder relations
• Works full-time, including overseeing Board work and assigned duties
• Key assignments: governance of strategy, acquisitions, shareholder relations, HR/digital/industrial transformation, employee share ownership, promotion of Group values and compliance

Chief Executive Officer:

• Cyril Malargé (since 1 March 2022)
• Responsible for: formulating strategy with Chairman, supervising implementation of decisions, operational management of all Group entities
• Supported by Executive Committee and Management Committee
• Has broadest possible powers to act in all circumstances in the name of Sopra Steria Group SA
• Certain decisions require prior approval by Board of Directors or Chairman (decisions "highly strategic in nature or likely to have significant impact on financial position or commitments")

Executive and Management Committees

Executive Committee:

• 16 members (including CEO)
• 3 women (19%)
• Supervises Group organisation, management system, major contracts, support functions and entities
• Involved in strategic planning and implementation
• Members: Cyril Malargé (CEO), Dominique Lapère (Operations), Éric Pasquier (Strategy), Fabrice Asvazadourian, Yvane Bernard-Hulin, Hervé Forestier, Axelle Lemaire, Jo Maes, Béatrice Mandine, Étienne Merveilleux du Vignaux, Louis-Maxime Nègre, John Neilson, Xavier Pecquet, Kjell Rusti, Mohammed Sijelmassi, Grégory Wintrebert

Management Committee:

• 56 members (Executive Committee + 40 operational and functional managers)
• 9 women (22%)

Specific sustainability roles

Board-level responsibility:

• Nomination, Governance & Corporate Responsibility Committee oversees sustainability matters
• Board reviews and approves sustainability strategic priorities and goals
• Audit Committee reviews results of Group's risk mapping exercise, including sustainability-related risks

Executive-level responsibility:

• Axelle Lemaire serves as Corporate Responsibility member of Executive Committee
• Sustainability & Corporate Social Responsibility Department works closely with Internal Control Department on double materiality assessment (CSRD)

Frequency of sustainability discussions

The Board of Directors and its committees meet regularly:

Board of Directors:

• Attendance rate in 2024: 92%
• Reviews and approves sustainability strategic priorities and goals
• Annual review of risk mapping including sustainability matters
• Reviews implementation of targets for women in senior management positions

Nomination, Governance & Corporate Responsibility Committee:

• Attendance rate in 2024: 92%
• Regular meetings to review diversity policy, succession planning, and corporate responsibility matters
• Developed double materiality assessment methodology for CSRD in 2024

Audit Committee:

• Attendance rate in 2024: 100%
• Regular meetings with Internal Control Department to monitor implementation and adaptation of Group rules
• Reviews risk mapping results, including sustainability-related risks

Embedding of sustainability priorities

The Board of Directors has adopted strategic sustainability priorities and goals addressing key sustainability matters identified through double materiality assessment:

Main sustainability-related multi-year strategic priorities approved by the Board:

Diversity policy

The Board of Directors' diversity policy aims to bring together perspectives, skills and experience required for effective collective decision-making.

Gender equality targets:

• Each gender should account for at least 40% of Directors
• Active pursuit of gender equality in Board's specialized committees
• Current achievement: 43% women among Directors appointed by shareholders
• Targets for increasing proportion of women in senior management positions are reviewed by Nomination, Governance & Corporate Responsibility Committee and adopted by Board
• Proportion of women in senior management positions forms part of quantifiable targets for CEO's variable compensation

International dimension:

• Foreign nationals from countries where Group operates or seeks to develop business
• Directors can participate in meetings via videoconferencing/conference call
• Additional 20% weighting in compensation apportionment for Directors living outside France

Effectiveness arrangements

Selection process for Board members:

Four-phase process led by Nomination, Governance & Corporate Responsibility Committee:

1. Needs analysis (end dates of terms, diversity objectives, skills required)
2. List of potential candidates drawn up
3. Committee members meet selected candidates
4. Board discusses candidates and decides which to put to shareholder vote

Board and committee attendance:

Independence and conflicts of interest:

• Annual review of Director independence against AFEP-MEDEF Code criteria
• Procedure for handling potential conflicts of interest
• No Senior Independent Director currently appointed (reviewed by Committee, may be reconsidered during Board chairmanship transition)

Succession planning:

• Annual review by Nomination, Governance & Corporate Responsibility Committee
• Covers Chairman and CEO succession plans
• Ensures plan covers existing requirements and Group culture

Integration of sustainability-related performance in incentive schemes

Roles covered

Chief Executive Officer: Variable compensation tied to sustainability performance.

Members of the Executive Committee: Partial – Only for the Head of Sustainability & CSR.

Operational managers: Partial – Discretionary.

Chairman of the Board of Directors and Members of the Board of Directors: No variable compensation tied to sustainability.

Sustainability KPIs tied to remuneration

For the Chief Executive Officer in 2024, sustainability criteria included:

• Equal opportunities and diversity: Proportion of women in senior management positions
• Climate goals: Reducing and mitigating the carbon footprint

For the Head of Sustainability & CSR (member of the Executive Committee):

• Group sustainable performance (material matters not further specified in excerpts)

Weighting (% of STI/LTI tied to sustainability)

Chief Executive Officer: 10% of variable compensation in 2024 was tied to meeting CSR targets validated by the Board of Directors.

Specific breakdown or weighting between individual sustainability KPIs not disclosed in the excerpts provided.

Performance period and target structure

The performance criteria concern financial year 2024. Targets were validated by the Board of Directors.

The excerpts state that "the extent to which the criteria for awarding the Chief Executive Officer's variable compensation have been met is used as a proxy for the Company's performance. These targets concern the Company's financial performance (operating profit on business activity and organic growth) and, starting in financial year 2024, its sustainability-related performance (proportion of women in senior management positions and climate goals)."

The performance level is calculated relative to the target level bestowing the right to 100% of variable compensation for the target achieved without taking account of the trigger thresholds. If the level of achievement is below the trigger threshold, the performance value is set at 0.

Linked to STI or LTI

The 10% CSR component is part of the Chief Executive Officer's annual variable compensation (short-term incentive).

Performance shares are also mentioned separately: "performance shares effectively delivered or deliverable subject to being with the Company at the end of the vesting period are redistributed over each of the financial years covered by the plan, depending on the extent to which the applicable performance conditions are met."

Threshold/target/maximum performance definition

The weighting of each sustainability criterion within the overall performance level is the same as the weighting used for the variable compensation of the Chief Executive Officer.

Actual performance level is calculated as: actual level / target level. If achievement is below the trigger threshold, the performance value is set at 0.

Disclosure of payout against sustainability KPIs in the reporting period

No specific payout amounts or achievement levels against the sustainability KPIs (proportion of women in senior management positions, climate goals) are disclosed in the provided excerpts.

The excerpts reference that detailed features of incentive schemes for company officers and the Chief Executive Officer, "including compensation for 2025 and for 2024, the description of the targets used while they existed, the associated performance indicators, as well as the portion of sustainability criteria within total variable compensation" are presented in Chapter 3, Section 3 (pages 103-113), but the actual achievement data is not reproduced in the excerpts provided.

Synopsis of incentive systems in place in 2024

Sopra Steria's Business Model and Value Chain

Our Vision

The digital revolution has triggered a radical transformation in our environment. It is speeding up changes in our clients' business models, internal processes and information systems. In this fast-changing environment, we bring our clients new ideas and support them in their transformation by making the most effective use of digital technology.

Our Business

Sopra Steria provides end-to-end solutions to address the core business needs of large companies and organisations, helping them remain competitive and grow, supporting them throughout their digital transformation in Europe and around the world.

End-to-end Approach

Our approach encompasses:

• Advise: Strategic analysis and programme definition
• Develop: Implementation and IT infrastructure transformation
• Operate: Managing and operating systems and services
• Secure: Cybersecurity across all operations

Shifting from Service-based Approach to High Value-added Offers

Embedding consulting into our value proposition

Comprehensive response to our customers' transformation needs

Expanding in digital platform management

• Cloud and associated infrastructure services

Ramping up in next-generation technologies

• Cloud
• AI
• Data
• Emerging technologies

Solutions

• SAP S/4HANA
• ServiceNow
• Related salesforce

Stepping up Cybersecurity

• Prevention
• Protection
• Detection & Response

The Value Creation Model

Sopra Steria's DNA

Entrepreneurial culture, close customer relationships, sense of commitment and corporate responsibility

Innovation & Technology

Cloud, Data, AI, Blockchain, Cybersecurity, Mobility, 5G, IoT

Our Culture and Resources

• Employees, strategic partners, startups, schools and universities
• Suppliers and subcontractors

Business/technology Expertise - End-to-end Approach

Extensive range of offers

Focus on Major Clients

• 8 priority verticals
• Targeted business areas

Strategic Positioning

Sopra Steria is keen to establish itself as a European leader in digital services and position itself as a trusted, credible European alternative to global operators. The Group is developing and strengthening its foothold in four strategic markets (Public Sector, Financial Services, Defence & Security, Aerospace), where issues relating to sovereignty and responsible digital technology are becoming increasingly critical in Europe.

Business Lines

Consulting and Systems Integration – 68% of 2024 Revenue

Consulting – 9% of 2024 revenue Sopra Steria Next, the Group's consulting brand, has over 40 years' experience in business and technological consultancy for large companies and public bodies, with over 3,500 consultants in France and Europe.

Systems Integration – 59% of 2024 revenue Systems integration is Sopra Steria's original core business and covers all aspects of the information system life cycle and major transformation programmes.

Digital Platform Services

With over 30 years' experience and a team of over 6,500 infrastructure and cloud experts around the world, Sopra Steria offers solutions tailored to clients' needs.

Cybersecurity Services

With over 2,200 experts and several state-of-the-art cybersecurity centres in Europe and worldwide, Sopra Steria has an international reach as a European leader in protecting critical systems.

Development of Business Solutions – 6% of 2024 Revenue

Sopra Steria offers business expertise via packaged solutions in three areas: banks and other financial institutions, human resources, and real estate.

Business Process Services – 15% of 2024 Revenue

Sopra Steria offers a full range of business services and business process services (BPS) solutions incorporating next-generation technologies such as AI, hyperautomation, robotics and natural language processing.

Vertical Markets

Sopra Steria has chosen eight major vertical markets that constitute its areas of excellence and make up 89% of revenue:

• Financial Services – 16% of 2024 revenue
• Public Sector – 26% of 2024 revenue
• Aeronautics, Space, Defence & Security – 22% of 2024 revenue
• Energy and Utilities – 6% of 2024 revenue
• Telecoms, Media & Entertainment – 4% of 2024 revenue
• Transport – 7% of 2024 revenue
• Insurance – 4% of 2024 revenue
• Retail – 4% of 2024 revenue

Stakeholder Engagement and Interests

Main Stakeholders and Value Creation

Sopra Steria's value creation model addresses the needs and interests of its main stakeholders:

Clients

Over 80% satisfaction rate of our 100 strategic clients according to the Customer Voice survey. The Group's commitment is being a long-lasting partner, meeting their needs as effectively as possible by providing them with the best technology as part of a responsible and sustainable value-creating approach.

Annual "Customer Voice" satisfaction survey: The Group continued its annual satisfaction survey of its top 100 strategic clients across the Group with the aim of fostering, organising and sustaining high-quality, trust-based dialogue with clients. More than 650 interviews were conducted with clients in 2024. The qualities highlighted during interviews revolve around expertise, listening, proactivity, partnership, engagement and professionalism.

Client Advisory Board: The "France" reporting unit made progress with the Client Advisory Board initiative alongside a dozen core strategic clients to share progress made by its transformation programme and work on areas of common interest.

Employees

• Attrition rate: 14.1%
• 30% of the Group's employees (including 48.2% of employees in France) owned shares in the Group through an employee share ownership plan at 31/12/2024
• 7,436 new hires within the Group
• 23,096 Group employees (45.3% of the workforce) received AI training for a total of 79,242 hours

Shareholders

• €4.65 proposed dividend in respect of financial year 2024
• €150m Share buyback programme for retirement in 2024

Suppliers & Subcontractors

836 suppliers were awarded positive EcoVadis assessments in 2024, covering more than €900 million of expenditure, in accordance with the targets set by the Group. This accounts for 77% of target expenditure for 2024.

Government & Society

• A List CDP Ranking
• More than 3,200 hours pro bono donated, benefiting more than 24,000 vulnerable people at risk of social and/or digital exclusion

Strategic Approach to Stakeholder Relations

The Group develops lasting relationships of trust with its stakeholders that enhance their performance and help make the value chain more resilient. The primacy of customer service is one of Sopra Steria's core values and delivering satisfaction is one of the Group's top priorities.

Employee Engagement

The Group prioritises close relationships with employees, with people and the management approach at the heart of the Company's strategy, promoting protection and trust, supporting human development, and encouraging accountability by valuing high standards and critical thinking.

Share ownership structure includes:

• 28.4% (43.0%) Controlled share ownership
• 68.0% (57.0%) Free float
• Employee participation: 6.2% (8.4%) Investments managed on behalf of employees

Dialogue with Investors

The Investor Relations Department engages in dialogue with the financial community throughout the year, meeting with all shareholders, investors and financial analysts. In 2024:

• 716 Individuals met
• 310 Institutions met
• 15 Conferences
• 15 Countries
• 27 Cities
• 37 Roadshows

Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model

Double Materiality Assessment Results

Sopra Steria conducted a double materiality assessment, the outcome of which confirmed the Company's priorities, some of them longstanding, while providing a fresh perspective on the value chain. These priorities reflect Sopra Steria's identity, strategy and business model, which are intrinsically linked to the quality of its relationships with its partners and the role of digital technology in society.

Key Material Issues

13 key issues regarding impact materiality and/or financial materiality were identified:

■ Climate change adaptation (ESRS E1) ■ Reducing and mitigating the carbon footprint (ESRS E1) ■ Resource and waste management (ESRS E5) ■ Priority placed on training and skills (ESRS S1) ■ Equal opportunities and diversity (ESRS S1) ■ Employee protection and trust (ESRS S1) ■ Social dialogue (ESRS S1) ■ Regional presence (ESRS S3) ■ Contribution to essential public services (ESRS S4) ■ Business conduct and compliance (ESRS G1) ■ Cybersecurity and digital sovereignty ■ Developing responsible digital technology

Integration with Strategy and Business Model

The strategic sustainability priorities and goals have been approved by supervisory, executive and management bodies, including the Board of Directors, Executive Management and the Executive Committee. These address the key sustainability matters for Sopra Steria and have direct or indirect implications for key components of the strategy, the business model and value chain (business-specific solutions, client sectors of activity, geographical regions, stakeholders).

Main Risk Categories

The most material risks specific to Sopra Steria are set out by category and in decreasing order of criticality:

Risks related to strategy and external factors

• Ability to offer appropriate, adapted solutions
• Acquisitions
• Loss of business from a major client or vertical
• Attacks on reputation

Risks related to operational activities

• Repercussions of major external crises
• Cybersecurity, protection of systems and data
• Pre-sales and delivery of projects and managed/operated services

Risks related to human resources

• Attracting talent
• Skills development and retention of key personnel

Risks related to regulatory requirements

• Compliance

Opportunities and Strategic Response

Sopra Steria positions itself as a European leader in digital services and a trusted, credible European alternative to global operators. The Group is developing and strengthening its foothold in four strategic markets (Public Sector, Financial Services, Defence & Security, Aerospace), where issues relating to sovereignty and responsible digital technology are becoming increasingly critical in Europe.

Strategic priorities for responsible digital technology are likely to influence the Group's business line skills and solutions.

Artificial intelligence has created a vast range of opportunities that the Group will seize, while taking an ethical, sovereign approach through the rAIse® programme launched in 2023.

Embedding Sustainability into Business Strategy

The Group has introduced a specialised sustainability programme that sets out and adapts strategic priorities. Main sustainability-related multi-year strategic priorities approved by the Board of Directors include:

• Environment [ESRS E1]: Net-zero emissions - Continue along the trajectory for reducing greenhouse gas emissions from the Group's direct activities
• Sopra Steria employees [ESRS S1]: Diversity and equal opportunity - Meet the imperatives of workplace diversity and inclusion

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

Overview of double materiality assessment process

Sopra Steria carried out its first double materiality assessment in 2024 with the aim of identifying and prioritising the sustainability topics that are most relevant to its business. This analysis was undertaken from two perspectives: a first pass focused on impact materiality, i.e. Sopra Steria's impact on its stakeholders and environment, followed by a second pass focused on financial materiality, taking into account the financial and reputational effects of environmental, social and business conduct issues on business performance.

Step-by-step methodology

The double materiality assessment followed a structured four-step process:

Step 0. Integration of the regulatory framework

• Incorporation of mandatory sustainability topics, sub-topics and sub-sub-topics (ESRS 1, AR 16)
• Identification of topics specific to Sopra Steria

Step 1. Identification and assessment of IROs

• Evaluate the company's value chain (including upstream and downstream) against identified sustainability topics
• Determine the real or potential IROs
• Assess their financial materiality and impact materiality (scored from 1 to 4)

Step 2. Determination of material IROs

• Identifying the level of materiality of IROs in relation to the materiality threshold
• Only IROs above the threshold are considered material

Step 3. Grouping Sopra Steria's IROs into sustainability topics

• Grouping IROs into material sustainability matters relevant to Sopra Steria's business activities

Inputs to the assessment

Regulatory framework and standards:

• ESRS 1, AR 16 mandatory sustainability topics, sub-topics and sub-sub-topics
• An optional, complementary industry analysis to identify sustainability topics specific to digital services business activity and sector

Data sources:

• Group CSR documents and reports
• Comparisons relating to other companies in the same industry sector
• Segment analyses
• Scientific papers
• Research by industry groups

Internal expertise:

• Sopra Steria adopted a collective approach involving in-house teams to tap into key skills and knowledge from the Group's various strategic, operational and functional areas

External stakeholder consultation:

• The Group entered into dialogue with key categories of external stakeholders to ensure that their own perspectives on sustainability topics were taken into account
• Consultation with stakeholders included: annual survey of key accounts, the annual Great Place To Work survey of employees, regular meetings with non-financial analysts and periodic reviews with strategic suppliers and technology partners

Oversight and governance:

• Overseen by the Sustainability & Corporate Social Responsibility Department with the support of the Internal Control Department
• A governance structure was put in place to ensure that the double materiality assessment as a whole was consistent and compliant with regulatory requirements

Scoring criteria for impact materiality

Impact materiality takes into account how the Company's business and value chain affect the environment and stakeholders. It is evaluated using a combination of criteria:

• Scale: the severity or intensity of the effects. This is measured in terms of the damage caused or benefits generated.
• Scope: geographical scope and/or number of people affected by the impacts of Sopra Steria's business
• Remediability: the extent to which the original situation can be restored once an impact has materialised
• Likelihood of occurrence (for potential impacts)

The extent to which scoring criteria are taken into account is determined by the nature of the impact and whether it is positive or negative, potential or actual.

Each criterion was assessed on a four-point scale based on the severity of the impact (positive or negative), with "severe" being the highest level. Likelihood of occurrence is also scored on a four-point scale, with "very high" being the highest level. All applicable criteria are combined into an average value.

Scoring criteria for financial materiality

Financial materiality takes into account the financial and reputational impact of environmental, social and governance matters on the Company's performance. This involved Sopra Steria undertaking an analysis of relationships between the Company's positive or negative impacts on its environment and stakeholders and the financial effects of those impacts.

Financial materiality assessment is based on a range of criteria:

• Financial effect: by level of impact on operating profit (loss or gain)
• Operational disruptions/improvements
• Consequences to reputation
• Likelihood of occurrence (for potential risks and opportunities)

Each criterion was assessed on a four-point scale based on the severity of the identified risk or opportunity, with "severe" being the highest level. Likelihood of occurrence is also scored on a four-point scale, with "very high" being the highest level. All applicable criteria are combined into an average value.

Factors taken into account when assessing financial materiality are based, in particular, on the methodology currently used by Sopra Steria to assess risks when producing the Company's overall risk mapping, with similar scoring matrices. Financial materiality assessment is mainly qualitative in nature. The Company aims to reinforce the quantitative analysis of the financial impacts of the risks and opportunities associated with each sustainability matter over a three-year period.

Assessment approach

The impacts, risks and opportunities identified were assessed on a gross basis, i.e. without taking into account any preventive or remedial action taken by the Group. The interdependencies between impacts, risks and opportunities were taken into account when identifying sustainability topics.

Sustainability topics were analysed taking into account, as far as possible, the Company's value chain as a whole, including both upstream and downstream stakeholders. Consequently, impacts, risks and opportunities were analysed in such a way as to cover all businesses, own operations and geographical locations.

Materiality threshold

Only IROs above the materiality threshold were considered material and grouped into material sustainability matters.

Value chain mapping in the process

Sopra Steria's value chain is an operational expression of its strategy, its positioning and the company's business model. The double materiality assessment analysed the entire value chain:

Upstream value chain:

• Suppliers related to the Group by purchases of services (IT subcontracting, training services, etc.), mainly based in Europe
• Suppliers of IT-related products (software, equipment, hosting) or office-related expenditures

Own operations:

• Development of trust-based relationships with stakeholders
• Alignment of employees' skills and expertise with the strategy
• Development of skills and careers of 50,988 employees
• Implementation of projects and operations from more than 2,000 sites

Downstream value chain:

• The Group's clients and end-users of the solutions it develops
• Less than 100 key accounts across the Group operating in main verticals: Financial Services; Public Sector; Aeronautics, Space, Defence & Security; Energy & Utilities; Telecoms, Media & Entertainment; Transport; Insurance; Retail

Material sustainability matters concerning climate change and the circular economy take into account the dependencies and consequences of solution-building, infrastructure maintenance, and the digital equipment required for the Group's service delivery on the environment from resource extraction. Material sustainability matters related to end-users and digital activities conducted for client accounts were assessed throughout their usage and end of life by the Group's clients and their clients.

Documentation and traceability

Each step in the analysis was formally documented and archived to ensure traceability. Documentation includes:

• Methodology
• Data collected
• Minutes and reports
• Findings of key steps
• Reviews carried out by sustainability auditors

Frequency and validation

Initial assessment: 2024 (first double materiality assessment)

Validation:

• The findings of the double materiality assessment were approved by the Executive Committee, Chief Executive Officer and Chairman of the Board of Directors
• Presented to the members of the Audit Committee, the Nomination, Governance & Corporate Responsibility Committee and the Board of Directors
• The results were presented and approved by the Board of Directors

Subsequent revision:

• The double materiality assessment will be reviewed annually to take into account any changes in Sopra Steria's business or value chain that could affect its outcome
• An in-depth update of the analysis will be carried out every three years
• These later revisions will be approved under the same conditions as the initial analysis

Integration with overall risk mapping

In the Group's overall approach to risk, non-financial risks that could limit the Group's ability to achieve its strategic objectives are treated as financial issues. As such, the double materiality assessment of sustainability issues is used in general risk mapping. Special attention is paid to ensuring consistency in results despite the fact that there may be minor variations in the methodological approaches used depending on regulatory frameworks.

Results - Material sustainability matters identified

The double materiality assessment conducted by Sopra Steria identified 13 material matters for the Company in terms of impact materiality and/or financial materiality:

Environment (ESRS E1, ESRS E5):

• Climate change adaptation
• Reducing and mitigating the carbon footprint
• Resource and waste management

Sopra Steria employees (ESRS S1):

• Priority placed on training and skills
• Equal opportunities and diversity
• Employee protection and trust
• Social dialogue

Society:

• Regional presence (ESRS S3)
• Contribution to essential public services (ESRS S4)

Business conduct (ESRS G1):

• Business conduct and compliance

Specific to digital services companies:

• Cybersecurity and digital sovereignty
• Developing responsible digital technology

Transition plan for climate change mitigation

Sopra Steria has implemented a transition plan setting in motion the transformation of its activities, making them more sustainable in a low-carbon world. It contains action plans that must contribute to reducing greenhouse gas emissions on the Company's own operations and on the whole of the value chain, in addition to emissions related to staff commuting and business travel. Through this transition plan, Sopra Steria is committed to supporting the United Nations and European Union goal of limiting global warming to 1.5°C (in accordance with the Paris Agreement) and achieving a net-zero emissions economy by 2050. Sopra Steria's climate transition plan is underpinned by a target of achieving net-zero emissions by 2040, validated by SBTi.

Scope of the plan

The transition plan covers:

• All Group countries and entities
• The entire value chain, including:
  • Scopes 1+2: offices and on-site data centres
  • Scope 3-1: Supply chain (products and services purchased)
  • Scope 3-8: Off-site data centres
  • Scope 3-6: Business travel
  • Scope 3-7: Employee commuting and remote working

Target year(s) for net zero / carbon neutral

Net-zero target: 2040

Starting in 2040, the Group will offset the remaining 10% of GHG emissions from across the entire value chain to achieve the Net-Zero target in 2040.

Transition plan targets validated by scope:

Scope 1, 2, 3 reduction milestones with baseline years

Baseline year: 2019

Milestones:

• 2030: Reduce Scopes 1+2 emissions by 54% vs 2019; Reduce Scope 3 emissions by 37.5% vs 2019
• 2040: Reduce Scopes 1+2 emissions by 90% vs 2019; Reduce Scope 3 emissions by 90% vs 2019

Historical progress (2024 vs 2019):

• Total GHG emissions (market-based) reduced from 389,272 tCO2e (2019) to 294,203 tCO2e (2024)
• Scope 3 emissions reduced by 24% relative to 2019

Alignment with 1.5°C / SBTi validation status

• 1.5°C alignment: The transition plan is aligned with limiting global warming to 1.5°C in accordance with the Paris Agreement
• SBTi validation: Target approved by the Science Based Targets initiative (SBTi) on 16 June 2023 and aligned with the aim of limiting the increase in the average global temperature to 1.5°C
• The Group has been aligned with SBTi since 2017 (initially 2°C trajectory), raised to 1.5°C in 2019, with Net Zero 2040 objective validated in 2023

Key levers / decarbonization pillars

Decarbonisation levers and main actions:

Specific targets by action plan:

Energy efficiency and renewables:

• Maintain the proportion of the Group's electricity consumption (at offices and on-site data centres) from renewables at 95% or more
• Reduce energy consumption by 20% in 2030 compared with 2021
• Renewable energy use for electricity consumption at offices and on-site data centres: 100% (2024)

Sustainable mobility:

• Reduce mobility-related emissions by 65% relative to 2019 (target for 2027)
• Reduce mobility-related emissions by 15% relative to 2024 (target for 2027)
• Reduce mobility-related emissions by 70% relative to 2019 (target for 2030)
• Reduce mobility-related emissions by 90% relative to 2019 (target for 2040)

Environmental management (ISO 14001):

• At least 70% of Group employees to be based at sites that are ISO 14001-certified (or in the process of being certified) by year-end 2026
• At least 80% of employees to be based at such sites by year-end 2028
• At least 95% of employees to be based at such sites by year-end 2030
• 50% of employees working at ISO 14001 sites (2024)

Employee awareness and training:

• Train 7,000 employees on climate-related issues by 2027 (baseline year: 2022)
• 2,520 employees trained on climate-related issues (2024)

CapEx / investment commitments

Financial resources allocated by action lever (in millions of euros):

Note: These figures include both actual data and estimates (for certain Opex), prepared by extrapolating at Group level based on real data coming mostly from France. The Capex is based entirely on actual data.

EU Taxonomy alignment:

• Transition plan capital expenditures (Capex) are related to:
  • "Sustainable mobility" action plan (increasing the number of low- to zero-emission vehicles in the fleet): €27.9 million
  • Energy savings plan (5 buildings BREEAM or HQE-certified): €20.90 million
• Total Taxonomy-aligned Capex: €48.80 million

Locked-in emissions and stranded asset analysis

Locked-in emissions may dampen the pace of progress towards Sopra Steria's targets, especially amid a gradual transition and increasing constraints (regulations, costs, market trends, etc.). Sopra Steria has identified three sources of locked-in emissions:

1. Data centres: Address by using data centres powered by renewables
2. Clients' IT infrastructure: Address by IT sustainable design (e.g. using G4IT tool in projects)
3. Property/travel: Address by low-carbon offices and more sustainable forms of mobility

Use of carbon credits / removals

Beyond Value Chain Mitigation (BVCM):

Starting in 2040, the Group will offset the remaining 10% of GHG emissions from across the entire value chain to achieve the Net-Zero target in 2040. It should be noted that the Group has not yet drafted a policy on compensation, as the current priority is to reduce emissions.

"Taking action beyond our value chain" action plan:

Qualitative targets:

• Investment: Fund projects that address environmental and social impacts by supporting the global transition to a net-zero world that champions equal opportunity
• Carbon credits: Fund carbon offset schemes, notably through afforestation projects, to achieve climate neutrality for direct operations
• Reputation-building: Affirm Sopra Steria's position as a leader on climate action by actively supporting mitigation strategies that go beyond the value chain (BVCM)

Main actions:

• Develop sustainability-linked loans and boost funding for innovation. In 2024, two innovative projects were selected to receive financing of €100k each in the form of donations
• Since 2020, Sopra Steria has invested in carbon capture projects via afforestation under the banner of the UN Climate Neutral Now programme. By using carbon offsets from these projects, the Company was able to meet its target of achieving Climate Neutral Now certification across all direct activities in 2021
• GHG emissions sequestered under these projects are checked by the Verified Carbon Standard (VCS) and have obtained Compliance Certification Board (CCB) certification

Shadow internal carbon pricing:

The Group has introduced shadow internal carbon pricing to raise awareness and elicit changes in behaviour:

• Rolled out in France and the UK, to be expanded to all countries from 2025 onwards
• Shadow carbon price set at €85/tCO₂, covering emissions generated by air, rail and road (car and taxi) travel and hotel stays
• Gross greenhouse gas emissions – Scope 3 covered by internal shadow carbon pricing: 4.17% (2024)

Integration with overall strategy

The climate transition plan is an integral part of a set of policies, plans and initiatives aimed at making environmental sustainability a reality within the Group. This set of policies, plans and initiatives is designed to be consistent with the Group's business strategy, operations, and financial, control and reporting processes.

The transition plan is fully embedded in the sustainability governance framework:

• Overseen by the Board of Directors and the Audit Committee
• The Chief Executive Officer and Head of the Sustainability & Corporate Social Responsibility Department (member of the Executive Committee) is responsible for implementation
• In 2024, the transition plan was integrated with application of the Corporate Sustainability Reporting Directive, which involved all the Group's departments and entities, as well as influencing the Group's overall strategy
• Sopra Steria submitted its sustainability report to the Board of Directors, including the transition plan

Key milestones achieved:

• 2013: First digital services company in France to gain a climate change score of 100A from the CDP (now on "A List" for eight consecutive years)
• 2014: Offset all emissions from direct activities (offices, data centres and business travel)
• 2017: First digital services company to adopt a long-term emissions reduction target, aligned with an SBTi-approved 2°C trajectory
• 2019: Emissions reduction target raised to align with a 1.5°C trajectory
• 2023: Validation of a new SBTi Net Zero 2040-aligned objective

The Group publishes data annually on its GHG Protocol Scope 1, 2 and 3 emissions, showing how they have changed each year and thereby tracking progress against its fixed climate targets. Data are audited externally.

Policies related to climate change mitigation and adaptation

Sopra Steria has implemented a comprehensive climate policy that provides an overall framework covering both climate change mitigation and adaptation.

Climate Policy

Scope: The climate policy extends to all of Sopra Steria's operations and covers all countries, relevant stakeholders and the entire value chain, from offices and data centres to suppliers, partners and clients.

Governance: Responsibility for governing and implementing climate policy lies with the Group's top management and involves the Chief Executive Officer and Head of the Sustainability & Corporate Social Responsibility Department and a member of the Executive Committee. The policy is updated annually by the Group's Human Resources Department, with support from the Sustainability and Corporate Social Responsibility Department, in keeping with the strategic priorities set by Executive Management.

Key content and principles: The policy has three key objectives:

• Supporting the transition to a low-carbon economy, with a target of achieving net-zero emissions by 2040
• Ensuring effective adaptation to climate change
• Developing low-carbon solutions to support clients and the community

The Group's strategy is structured around five priority areas of action:

1. Decarbonising the Group's entire value chain by reducing emissions from suppliers and partners, from offices, data centres, business travel and commuting, and from services the Group provides to its clients
2. Continuously assessing the Group's exposure to climate risk and bolstering its adaptability to climate change by ensuring that buildings, data centres, infrastructure and supply chains are resilient
3. Incorporating environment-related concerns (including climate-related concerns) into the value proposition by developing and providing solutions that support the sustainability strategies of the Group's clients
4. Raising awareness throughout the value chain (suppliers, employees and clients), training employees in climate-related issues and involving them in addressing such issues
5. Strengthening the Group's impact beyond its value chain by financing projects dedicated to combating and adapting to climate change

Alignment with international standards: The policy is based on recognised norms and standards such as:

• Science Based Targets initiative (SBTi)
• Sustainable Development Goals defined by the United Nations (SDG 13: "Climate action"; SDG 7: "Affordable and clean energy"; and SDG 9: "Industry, innovation and infrastructure")
• ISO 14001
• Verified Carbon Standard (VCS) for carbon offsetting

Stakeholder engagement: Sopra Steria's climate policy takes into account the interests of its stakeholders, including employees, clients, suppliers, technology partners, investors and public authorities thanks to regular consultations, in particular through the independent experts Group. It encourages shared environmental responsibility throughout the value chain to ensure that stakeholders are aligned with the Group's climate- and sustainability-related goals.

Public availability: The policy is communicated to all relevant stakeholders to ensure that it is consistently understood and implemented. It is shared with those in charge of deploying it and accessible to all employees via the intranet.

Implementation monitoring: The Group has implemented a transition plan setting in motion the transformation of its activities. The climate policy is embedded in the sustainability governance framework and involves the Board of Directors and its specialised committees (particularly the Audit Committee and the Nominations and CSR Committee). The Group publishes data annually on its GHG Protocol Scope 1, 2 and 3 emissions, showing how they have changed each year and thereby tracking progress against its fixed climate targets. Data are audited externally.

The policy is supported by seven specific action plans:

• Sustainable procurement action plan
• Energy efficiency and renewables action plan
• Sustainable mobility action plan
• Environmental management (ISO 14001) action plan
• Employee awareness and training action plan
• Climate change adaptation action plan
• Taking action beyond our value chain action plan

Each action plan relies on a dedicated monitoring system, built around objectives/targets, actions, allocated resources and associated metrics.

Actions and resources in relation to climate change policies

Sopra Steria has implemented seven distinct action plans aligned with its climate policy and net-zero 2040 target validated by SBTi. Each action plan includes defined scope, time horizons, allocated resources, and key performance indicators.

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a. Sustainable procurement action plan

Scope: All Group countries and entities (upstream value chain)

Time horizon: Short and medium term (launched 2021, covering period to 2030)

Key actions (carried out and planned for short term):

• Promoting purchasing products and services with a lower environmental impact
• Optimising PC life cycles: purchasing environmentally certified equipment, extending manufacturer warranties, recycling equipment (France)
• Rationalising servers: centralising servers in data centres, pooling resources, decommissioning underutilised platforms
• Launching programme to evaluate equipment: life cycle analysis of equipment (LCA screening) based on internal inventories
• Helping suppliers reduce their GHG emissions:
  • At identification, selection and contracting stage: signing of Code of conduct for suppliers and partners, integrating environmental criteria in invitations to tender
  • Throughout partner relationship: extensive conversations with main suppliers to boost reuse and publication of their GHG emissions; EcoVadis assessment of main suppliers
• In 2024, over €900 million of supplier expenditure was assessed via the EcoVadis platform

Actions planned (medium term):

• Drafting an (internal) IT impact reduction plan for 2025-2027 period based on lifespan screenings conducted in 2024
• Require suppliers to be transparent about their environmental impacts
• Obtain projected improvement plans for their impacts
• Increase scope of impact analysis using physical approach (LCA screening) to digital technologies dedicated to clients

Financial resources:

• Human resources: estimated at 40% of one FTE in 2024 at Group level
• Operating expenses (Opex): EcoVadis platform subscriptions, internal training costs
• Costs consolidated in table showing financial resources allocated to transition plan under "Responsible purchasing" heading

Key advances: Prolong equipment lifespan, implement bimonthly meetings with Purchasing Department and IT Department

Expected outcomes/KPIs:

• In 2024, 85% of Scope 3 emissions related to purchases
• Group succeeded in reducing Scope 3 GHG emissions by 24% relative to 2019, and by 16% over previous year
• Reduction mainly due to improved data quality and increased precision in methodology

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b. Energy efficiency and renewables action plan

Scope: All Group countries and entities (own operations - offices and on-site data centres)

Time horizon: Short term (launched 2022)

Targets:

• Maintain proportion of Group's electricity consumption (at offices and on-site data centres) from renewables at 95% or more
• Reduce energy consumption by 20% in 2030 compared with 2021 (baseline year)

Key actions structured around three priorities:

1. Heating and cooling:

• Limiting temperatures and operating times of heating systems in winter and cooling systems in summer
• Optimising air conditioning systems, notably in India, to reduce energy consumption while ensuring adequate comfort levels
• Targeting low PUE (Power Usage Effectiveness) by optimising air conditioning systems in data centres

2. Lighting:

• Limiting lighting to what is strictly necessary and adapting it to activity levels
• Replacing traditional bulbs with LED bulbs in most countries

3. Using IT tools:

• Applying strict rules for digital tool use and data storage to minimise energy impact

Additional country-level initiatives:

• Monitoring electricity consumption in real time in United Kingdom
• Automating water pumps in India to optimise operation

Renewable energy actions:

• High proportion of electricity consumption from renewable sources under green power purchase agreements
• Using Guarantee of Origin certificates (GOs and REGOs) in Austria, Belgium, Bulgaria, Denmark, France, French Polynesia, Germany, Italy, Luxembourg, Netherlands, Norway, Poland, Romania, Spain, Sweden, Switzerland and United Kingdom

Governance:

• Specific governance structure consisting of Energy Savings Officers and Chief Sustainability Officers (CSOs), managed by central SCSR team

Financial resources:

• Operating expenses (Opex): costs related to energy improvements and maintenance (converting to LED lighting, optimising air conditioning systems), purchasing Energy Attribute Certificates (EACs)
• Human resources: estimated at 15% FTE at Group and local level for each of 10 relevant countries or entities
• Capital expenditures (Capex): rent increases in 5 BREEAM or HQE-certified buildings, installation costs for solar panels in India
• Costs consolidated in table of financial resources allocated to transition plan under "Energy savings plan" and "Renewables" headings

Key advances: Quarterly follow-up of energy consumption and actions implemented to reach objectives

Expected outcomes/KPIs:

• Energy consumption in offices and miscellaneous areas
• Share of renewables in electricity consumption
• Energy consumption at offices covers electricity, fuel (fuel oil, diesel and natural gas) and district heating

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c. Sustainable mobility action plan

Scope: All Group countries and entities

Time horizon: Short and medium term

Key actions (carried out and planned):

Business travel:

• Introduce shadow internal carbon pricing to raise awareness and elicit changes in behaviour. Already rolled out in France and UK, to be expanded to all countries from 2025 onwards. Shadow carbon price set at €85/tCO₂, covers emissions from air, rail and road (car and taxi) travel and hotel stays
• Promote sustainable modes of transport and set policies that prioritise low-emission modes
• Incorporate sustainable mobility policy into Group's processes and systems

Commuting:

• Explore potential financial incentives to support/encourage sustainable mobility (cycling, public transport and electric vehicles)

Financial resources:

• Human resources: estimated at 35% of one FTE in 2024 at Group level, plus 25% FTE for Energy Savings Officers in countries
• Operating expenses (Opex): costs related to initiatives for decarbonising business travel and commuting
• Capital expenditures (Capex): purchasing or leasing low-emission vehicles for company vehicle fleet (98% of total Capex), specific facilities such as changing rooms, bicycle parking and charging points for electric bicycles and cars
• Costs consolidated in table of financial resources allocated to transition plan under "Sustainable mobility" heading

Key advances: Implement network of Group sustainable mobility officers with workshops and regular discussions

Expected outcomes/KPIs:

• Business travel both at Group level and by entity/country (Scope 3-6)
• Employee commuting and remote working both at Group level and by entity/country (Scope 3-7)
• Through action plans, more refined methodology and enhanced collection of actual datapoints, Group succeeded in reducing emissions from business travel by 33% and those from commuting and remote working by 30% relative to 2023

Shadow internal carbon pricing coverage:

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d. Environmental management (ISO 14001) action plan

Scope: All Group entities and geographies

Time horizon: Short and medium term

Status: 19% of Sopra Steria's sites representing 45% of Group's workforce have secured ISO 14001 certification

Targets:

• Year-end 2026: at least 70% of Group employees based at sites that are ISO 14001-certified (or in process)
• Year-end 2028: at least 80% of employees at such sites
• Year-end 2030: at least 95% of employees at such sites
• Baseline year: reporting year; monitoring trends from 2025

Key actions (carried out and planned for short term):

• In France, achieved certification for new sites in Roanne and Aix in 2024
• Starting 2025: centralisation process overseen by Environmental Management Officer – France
• Aim to secure certification for Annecy head office and other sites in France and Germany by early 2026
• Plan to secure certification for additional sites in India and France between 2028 and 2030

Financial resources:

• Operating expenses (Opex) only
• Human resources: estimated at one FTE per certified site, and 40% FTE at Group level
• Costs related to audits and certification, monitoring of regulations, ISO 14001 training expenses
• Costs consolidated in table of financial resources allocated to transition plan under "ISO 14001" heading

Key advances: Certification of Latitude (major site for Group) and of all CS Group sites in France

Expected outcomes/KPIs:

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e. Employee awareness and training action plan

Scope: All Group countries and entities

Time horizon: Short term (launched 2022)

Target:

• By 2027: train 7,000 employees on climate-related issues
• Baseline year: 2022

Key actions (carried out and planned for short term):

Climate Fresk rollout (France 2022, Group-wide 2024):

• Training sessions for Climate Fresk workshop trainers
• Coaching sessions run by expert Climate Fresk workshop trainers at country level
• Local events ("Freskathon") to promote workshops
• Gathering initiatives from employees at end of each Climate Fresk workshop
• Deployment in 2023 of 2tonnes workshops in France and follow-up

Governance:

• Specific governance structure: Climate Fresk workshop trainers, Chief Sustainability Officers (CSOs) and local Academy coordinators, managed by central SCSR team

Financial resources:

• Operating expenses (OpEx) only
• Usage fees for Climate Fresk and 2tonnes licences
• Coaching expenses for countries
• Costs relating to Train the Trainers programmes
• Expenses relating to travel by workshop trainers
• Costs consolidated in table of financial resources allocated to transition plan under "Awareness and training" heading

Key advances: International roll-out of Climate Fresk, scaling up of sustainable design training

Expected outcomes/KPIs:

Additional training: Digital Collage, sustainable design training, ISO 14001 e-learning course, and other in-house training in entities and countries

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f. Climate change adaptation action plan

Scope: All Group countries and entities

Time horizon: Short and medium term

Targets (qualitative only to date):

• Ensure Group adapts robustly to climate change by boosting resilience and reducing vulnerability of critical assets (buildings, data centres, infrastructure, supply chains)
• Address and mitigate physical risks (flooding, extreme heat waves, drought, hurricanes and cyclones)
• Commit to continuously improve working conditions to increase safety and well-being of all employees
• Develop adaptation solutions for clients

Key actions (carried out and planned for short term):

• Continuously assess climate- and weather-related risks liable to adversely affect productivity, employees and assets, paying particular attention to vulnerable regions (Spain, southern France, India)
• Prioritise modern, resilient buildings that comply with most recent climate change adaptation standards
• Audit sites and ensure equipped with robust services (efficient air conditioning), in keeping with extension of ISO 14001 certification
• Maintain comprehensive insurance programme covering property damage and operating loss should climate risks materialise
• Work with partners to design digital solutions to help clients better adapt to climate change

Actions planned (medium term):

• Assess feasibility and relevance of quantitative targets and KPIs to monitor and assess impact and relevance of Group's actions under adaptation plan

Key advances: Discussions in-progress to define new adaptation strategy

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g. Taking action beyond our value chain action plan

Scope: All Group countries and entities

Time horizon: Short term

Targets (qualitative only to date):

• Investment: Fund projects that address environmental and social impacts by supporting global transition to net-zero world
• Carbon credits: Fund carbon offset schemes, notably through afforestation projects, to achieve climate neutrality for direct operations
• Reputation-building: Affirm Sopra Steria's position as leader on climate action by actively supporting mitigation strategies beyond value chain (BVCM)

Key actions (carried out and planned for short term):

• Develop sustainability-linked loans and boost funding for innovation by leveraging digital expertise to support innovative startups and companies offering solutions for climate change mitigation and adaptation. In 2024, two innovative projects selected to receive financing of €100k each in form of donations
• Explore and continue to work with partners at cutting edge of carbon offsetting. Since 2020, invested in carbon capture projects via afforestation under UN Climate Neutral Now programme. GHG emissions sequestered under these projects checked by Verified Carbon Standard (VCS) and obtained Compliance Certification Board (CCB) certification
• Innovate, influence and shape climate policy by continuing to proactively work with public and institutional decision-makers and think tanks

Key advances: Project financing through Sustainability-Linked Loan

Expected outcomes/KPIs:

• Amount of GHG emission reductions or removals in relation to direct activities (offices, data centres, business travel) resulting from climate change mitigation projects outside value chain
• Company met target of achieving Climate Neutral Now certification across all direct activities in 2021

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Link to transition plan targets

All action plans support Sopra Steria's transition plan targets validated by SBTi:

Starting in 2040, Group will offset remaining 10% of GHG emissions from across entire value chain to achieve Net-Zero target.

Targets related to climate change mitigation and adaptation

Climate targets approved by SBTi (Net-Zero 2040)

Sopra Steria has set ambitious climate targets validated by the Science Based Targets initiative (SBTi), aligned with limiting global warming to 1.5°C and achieving net-zero emissions by 2040.

Baseline values (2019):

• Scopes 1 & 2: 6,576 tCO2e
• Scope 3: 382,696 tCO2e
• Total: 389,272 tCO2e

Progress to date (2024):

• Scopes 1 & 2: -52.7% vs 2019 (2024: 3,112 tCO2e)
• Scope 3: -23.9% vs 2019 (2024: 291,090 tCO2e)

Annual reduction trajectory required:

• Scopes 1 & 2: -3.4% per year
• Scope 3: -4.9% per year

Additional operational targets

Energy efficiency and renewables:

• Maintain the proportion of electricity consumption from renewables at ≥95%
• Reduce energy consumption by -20% by 2030 (vs 2021 baseline)

Responsible purchasing:

• Continue rollout of EcoVadis CSR assessments aiming to cover 85% of expenditure (suppliers with expenditure ≥€150k)

Sustainable mobility:

• By 2027: Reduce mobility-related emissions by -65% vs 2019 and -15% vs 2024
• By 2030: Reduce mobility-related emissions by -70% vs 2019
• By 2040: Reduce mobility-related emissions by -90% vs 2019

Waste management:

• By 2030: Recover material or heat from 100% of WEEE (through reuse, resale, donation, recycling or heat recovery)
• By 2030: Recover material or heat from 100% of paper and cardboard waste

ISO 14001 certification:

• Ensure at least 95% of employees are linked to an ISO 14001 certified site by 2030

Employee training:

• Train 7,000 employees in climate-related issues by 2027

Net-Zero approach

Starting in 2040, the Group will offset the remaining 10% of GHG emissions from across the entire value chain to achieve the Net-Zero target. The Group has not yet drafted a compensation policy, as the current priority is emissions reduction.

Energy consumption and mix

Total energy consumption by source and scope (MWh)

Proportion of electricity from renewable sources

Scope and methodology: Energy consumption at offices covers electricity, fuel (fuel oil, diesel and natural gas) and district heating. The scope includes all Group countries and entities. In 2024, the baseline year for the energy efficiency plan was 2021. Renewable electricity is procured through green power purchase agreements sealed directly with suppliers or using Guarantee of Origin certificates (GOs and REGOs in multiple European countries) or International Renewable Energy Certificates (I-RECs in Brazil, Cameroon, Canada, China, Côte d'Ivoire, India, Lebanon, Morocco, Senegal, Singapore, UAE, USA and Tunisia).

Note: The company reports total energy consumption by operational category (offices, on-site data centres, off-site data centres) and the proportion of renewable electricity, but does not provide a full disaggregation by fossil fuel types (coal, oil, natural gas), nuclear sources, or renewable subtypes (biomass, solar, wind, etc.) as required under ESRS E1-5 (E1-7 under 2024 numbering). No energy intensity metrics (per revenue or per employee) were disclosed in the excerpts provided.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope and methodology

Scope 1, 2 and 3 emissions calculations include the scope of subsidiaries as soon as the Group takes control of them. This calculation includes the scope of subsidiary Sopra Banking Software up to the finalisation of its sale on 31 August 2024. As of 1 September 2024, the SBS subsidiary had been removed from Sopra Steria Group and consequently environmental indicators no longer include the scope of this former entity.

The methodology used is compliant with the GHG Protocol. 68% of the figure for Scope 1 and 2 emissions is based on real data. Under Scope 3, the amount under Category 1 is an estimate based on financial data; the amounts under the other Categories are mostly based on direct measurements of activity.

In 2024, Sopra Steria held an 11.07% stake in 74Software (formerly Axway Software). Scope 3, Category 15: Emissions arising from investments correspond to the emissions of 74Software as a tenant of office space belonging to Sopra Steria, and Sopra Steria's share of the other emissions of 74Software.

Breakdown of GHG emissions by scope

GHG emissions intensity

• Emissions intensity per employee (global direct activities: offices, data centres and business travel): 0.30 tCO₂e per employee in 2024
• Emissions intensity per employee (all activities): 5.77 tCO₂e per employee in 2024
• Emissions intensity per revenue: 50.93 tCO₂e per million euros of revenue in 2024

Shadow internal carbon pricing coverage

Note: Shadow carbon price set at €85/tCO₂ covers emissions generated by air, rail and road (car and taxi) travel and hotel stays. The price, set in 2023, was maintained in 2024.

Biogenic emissions

Not separately disclosed in this report.

Regulated emissions (EU ETS)

Percentage of Scope 1 GHG emissions from regulated emission trading schemes: 0% (2024, 2023, baseline year).

Policies related to resource use and circular economy

Resource use and circular economy policy

Scope:

• Encompasses all of Sopra Steria's value chain
• Covers key stakeholders including suppliers, clients, partners, investors and employees
• No major exclusions

Governance and oversight:

• Responsibility for governing and implementing resource and waste management policy lies with the Group's top management
• Involves the Group Chief Executive Officer and Head of the Sustainability & Corporate Social Responsibility Department
• Involves a member of the Executive Committee

Key content and principles:

The policy aims at reducing the Group's environmental impact by optimising resource use, managing the life cycle of equipment and solutions and responsibly managing waste. It is structured around four priority areas of action:

1. Optimising resource consumption across the value chain through choice of suppliers (responsible purchasing), efficient energy management and the development of tools for measuring resource consumption (G4IT)
2. Managing the life cycle of equipment, notably by extending its life and encouraging the purchase of reconditioned equipment
3. Managing waste, in particular waste electrical and electronic equipment (WEEE), by encouraging reuse and recycling
4. Raising awareness throughout the value chain and training employees and involving them in addressing issues related to the circular economy and resource use

Alignment with international standards and frameworks:

• EU-wide objectives on waste management and sustainability
• RoHS Directive (Restriction of Hazardous Substances Directive)
• REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals)
• WEEE Directive (Directive 2012/19/EU on waste electrical and electronic equipment)
• United Nations Sustainable Development Goals:
  • SDG 12: Responsible consumption and production
  • SDG 6: Clean water and sanitation
  • SDG 11: Sustainable cities and communities

Public availability: Not disclosed

Monitoring and implementation:

The policy has been designed to address as a priority the elements with the greatest impact according to the results of the double materiality assessment. Sopra Steria commits to working with internal and external stakeholders to incorporate circular economy best practice as the digital industry develops over the coming years.

The Group monitors implementation through key indicators including:

• Volume of waste electrical and electronic equipment
• Volume of paper and cardboard waste

Targets set for monitoring progress by 2030:

• Recover material or heat from 100% of WEEE (reuse through resale and donation, raw materials recovery for recycling or heat)
• Recover material or heat from 100% of paper and cardboard waste (raw materials recovery for recycling or heat)

Actions and resources related to circular economy

Overview

Sopra Steria has launched a programme aimed at reducing its environmental impact in keeping with EU-wide objectives (Directive 2012/19/EU) on waste management and sustainability. The action plan covers all Group countries and entities.

Governance: A specific governance structure has been put in place, managed since 2020 by the Sustainability & Corporate Social Responsibility (SCSR) Department.

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Main actions (carried out and planned for short term)

Managing upstream resources

• Selecting equipment and data centre operators who optimise water and electricity consumption, including via a constantly declining PUE (Power Usage Effectiveness)

  • Scope: Upstream value chain
  • Time horizon: Short term (ongoing)

• Selecting suppliers of electronic equipment (a significant proportion of the Group's purchases) that meet Sopra Steria's specific requirements and are committed to reducing their impact on the environment and environmental resources (in particular, mineral resources) by signing on to Sopra Steria's suppliers' charter

  • Scope: Upstream value chain
  • Time horizon: Short term (ongoing)

• Increasing the proportion of FSC-certified paper

  • Scope: Upstream value chain
  • Time horizon: Short term (ongoing)

Managing electronic, paper and cardboard waste

• Selecting suppliers that meet clearly defined waste management requirements

  • Scope: Upstream value chain
  • Time horizon: Short term (ongoing)

• Optimising equipment use by extending its lifespan and encouraging the purchase of reconditioned equipment

  • Scope: Own operations
  • Time horizon: Short term (ongoing)

• Waste management, in particular waste electrical and electronic equipment (WEEE), by encouraging reuse and recycling

  • Scope: Own operations / Downstream value chain
  • Time horizon: Short term (ongoing)

• Introduction of awareness campaigns encouraging people to cut down on printing documents and extend the life of WEEE

  • Scope: Own operations
  • Time horizon: Short term (ongoing)

Digital solutions developed

• Sustainable IT platform (G4IT), which serves to assess and reduce the environmental impact of information systems through automated evaluation, drawing on the reference framework built by ADEME and an expert consortium including Sopra Steria

  • Scope: Own operations / Clients (downstream)
  • Time horizon: Ongoing

• Introduction of an IOT system to improve preventive maintenance of equipment, extending its useful life and cutting down on travel by technicians, who would then be able to perform full diagnostics remotely

  • Scope: Own operations / Clients
  • Time horizon: Ongoing

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Main actions (medium term)

Managing upstream resources

• Reduction plan – IT and Infrastructure Department (2025-2027) drafted in Q1 2025

  • Scope: Own operations
  • Time horizon: Medium term (2025-2027)

• Reduction plan – IT Department (2025-2027) drafted in Q3 2025

  • Scope: Own operations
  • Time horizon: Medium term (2025-2027)

• Reduction plan – Group (2026-2028) drafted in early 2026

  • Scope: Entire Group
  • Time horizon: Medium term (2026-2028)

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Policy framework

The policy is structured around four priority areas of action:

1. Optimising resource consumption across the value chain through choice of suppliers (responsible purchasing), efficient energy management and the development of tools for measuring resource consumption (G4IT)
2. Managing the life cycle of equipment, notably by extending its life and encouraging the purchase of reconditioned equipment
3. Managing waste, in particular waste electrical and electronic equipment (WEEE), by encouraging reuse and recycling
4. [Fourth priority not fully specified in excerpts]

Link to targets: Targets were set in 2020 with input from the Purchasing Department. Work will be required from 2025 in order to update these targets in accordance with the results of the double materiality assessment.

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EU Taxonomy-eligible activities (Circular Economy)

CE 4.1: Provision of IT/OT data-driven solutions

The circular economy projects eligible for this objective include:

• Focus on production chain optimisation, helping reduce waste from raw materials and maintenance processes and extend the life of equipment
• Implementing software to identify, monitor and trace materials, products and assets throughout their respective value chains
• Projects aim to support the circularity of material and product flows and the introduction of digital product passports
• Ensure that all data – from the supply and extraction of materials used in manufacturing through to end-of-life product recycling – is traceable

Scope: All key vertical markets in which the Group operates have been analysed

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Resources allocated

Non-financial resources:

• Specific governance structure managed by the Sustainability & Corporate Social Responsibility (SCSR) Department (since 2020)
• Purchasing Department involved in target-setting and supplier selection

Financial resources: No specific capex or opex amounts are disclosed for circular economy actions. The document notes that "Due to its particular business model, only a very small proportion of the Group's revenue is Taxonomy-eligible."

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Monitoring

KPIs tracked (E5-4 and E5-5):

• Waste volumes generated
• Proportion of waste recovered
• Volume of certified paper purchased
• Data are collected every quarter to monitor the situation throughout the year

Targets related to circular economy

Target 1: Waste Electrical and Electronic Equipment (WEEE) Recovery

• Target metric: Material or heat recovery from WEEE (through reuse via resale and donation, raw materials recovery for recycling or heat)
• Target value: 100%
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Group-wide (all Group countries and entities)
• Target type: Absolute
• Science-based/validation: Not disclosed. Targets were set in 2020 with input from the Purchasing Department
• Progress to date: Not disclosed

Target 2: Paper and Cardboard Waste Recovery

• Target metric: Material or heat recovery from paper and cardboard waste (raw materials recovery for recycling or heat)
• Target value: 100%
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Group-wide (all Group countries and entities)
• Target type: Absolute
• Science-based/validation: Not disclosed. Targets were set in 2020 with input from the Purchasing Department
• Progress to date: Not disclosed

Additional information

The document notes that "work will be required from 2025 in order to update these targets in accordance with the results of the double materiality assessment."

Waste

Waste management policy and approach

Sopra Steria's resource and waste management policy aims to reduce environmental impact by optimizing resource use, managing equipment lifecycle, and responsibly managing waste. The policy is structured around four priority areas:

1. Optimising resource consumption across the value chain through supplier choice, efficient energy management, and measurement tools
2. Managing equipment lifecycle by extending life and encouraging purchase of reconditioned equipment
3. Managing waste, particularly WEEE, by encouraging reuse and recycling
4. Raising awareness throughout the value chain and training employees

Waste management targets

By 2030, the Group aims to:

• Recover material or heat from 100% of WEEE (reuse through resale and donation, raw materials recovery for recycling or heat)
• Recover material or heat from 100% of paper and cardboard waste (raw materials recovery for recycling or heat)

Waste generation and recovery performance

Waste classification

Hazardous waste: Sopra Steria does not produce any hazardous waste according to RoHS and REACH definitions. The Group produces WEEE classified as hazardous under Commission Decision 2000/532/EC and Directive 75/442/EEC on waste. In 2024, the portion of hazardous WEEE not given a second life stood at 0.08% of the total amount of WEEE and paper, cardboard, plastic and metal waste.

Data collection and monitoring

All consolidated data for monitoring and publishing waste indicators come from the Group's suppliers. Data are collected quarterly to monitor the situation throughout the year. To maximize recovery, the Group brings in specialist service providers to collect and dispose of WEEE and paper and cardboard waste. By improving supplier relations, the Group recorded better results in 2024.

Future monitoring

Monitoring indicators may be reworked from 2025, concurrently with targets, particularly indicators related to:

• Total waste
• Total recovered or refurbished waste
• Total incinerated waste

Additional indicators relating to waste are available on Sopra Steria's website.

Policies related to own workforce

Sopra Steria has established several policies governing its own workforce, as part of its general Human Resources policy framework. These policies are updated annually by the Group's Human Resources Department, with support from the Sustainability and Corporate Social Responsibility Department, in alignment with strategic priorities set by Executive Management.

General Human Resources Policy

Scope: All business areas, entities and countries where the Group operates.

Governance and oversight: The policy is updated annually by the Group's Human Resources Department, with support from the Sustainability and Corporate Social Responsibility Department, in keeping with strategic priorities set by Executive Management. The Group Human Resources Director is supported by a network of country and/or subsidiary Human Resources Directors for implementation.

Key content:

• Core Competency Reference Guide and Compensation Reference Guide provide a shared framework for understanding professions, appraising employees and supporting career development
• Recruitment based on principles of equal opportunity and non-discrimination
• Career management through structured processes and regular appraisals
• Skills management and training to anticipate changes and guarantee employability
• Specific development plans for "High-Potential employees" and senior executives
• Developing employee engagement and satisfaction

Public availability: Communicated to relevant stakeholders and accessible to all employees via the intranet.

Links to international standards: Aligned with UN Global Compact's Sustainable Development Goals (SDGs) 4 ("Quality education") and 8 ("Decent work and economic growth").

Code of Ethics

Scope: All Sopra Steria employees.

Governance and oversight: Led by management, which ensures compliance with its rules. The Chairman of the Board of Directors provides a foreword. Managers on the Group Management Committee and entity-level management committees sign an annual digital declaration renewing their commitment.

Key content:

• Based on the Group's core values
• Ensures compliance with international treaties, laws and regulations in countries where Sopra Steria operates
• Reaffirms ethical principles
• Combat child labour and exploitation, forced labour and any other form of compulsory labour and human trafficking
• Comply with labour law, applicable international occupational health and safety standards and regulations, and collective bargaining agreements
• Create a safe, healthy and supportive working environment and combat all forms of discrimination and harassment
• Uphold freedom of expression and association and exercise of trade union rights

Public availability: Available on the Ethics and Compliance page of the Group's website at www.soprasteria.com.

Links to international standards: Based on the Universal Declaration of Human Rights of the United Nations. Sopra Steria has been a signatory to the United Nations Global Compact since 2004. Aligned with ILO conventions.

Implementation monitoring: Regular awareness-raising campaigns and training courses through induction seminars, professional development sessions and events organized by Sopra Steria Academy.

Skills Maintenance and Development Policy and Career Management Policy

Scope: All employees across the Group.

Governance and oversight: Under the responsibility of the Group Human Resources Director, who relies on a network of Human Resources Directors as well as country and/or subsidiary experts for deployment. Managers are responsible for managing career development on a day-to-day basis.

Key content:

• Anticipating skills required to meet business transformation needs and clients' expectations
• Maintaining employability and supporting employees' career development
• Promoting continuous training for technological and methodological excellence
• Developing individuals' skills based on motivations and potential
• Structured appraisal and career development framework with regular monitoring
• Identifying and supporting High Potential employees
• Transmission of company culture through induction and training programmes
• Development of specific and cross-functional skills
• Access to self-training resources on digital platforms
• Knowledge-sharing through internal community of trainers

Links to international standards: Aligned with UN Global Compact's Sustainable Development Goals (SDGs) 4 ("Quality education") and 8 ("Decent work and economic growth").

Implementation monitoring: Guided by strategic priorities set annually by Executive Management. Relies on annual training plans designed by entity management teams. Sopra Steria Academy plays a key role in training delivery.

Equal Opportunities and Diversity Policy

Scope: All employees, recruitment and employee experience across the Group.

Governance and oversight: Under the responsibility of the Human Resources Director, the Director of Sustainability & Corporate Social Responsibility, and each member of the Executive Committee reporting to the Group's Chief Executive Officer. Implementation through a network of country and/or subsidiary Human Resources Directors, CSOs (Chief Sustainability Officers), local contacts and experts.

Key content: Structured around five goals with specific action plans:

• Workplace gender equality to prevent gender-based discrimination and increase proportion of women at all organizational levels
• Equitable access to promotions and professional development opportunities
• Inclusion of people with disabilities
• Intergenerational balance
• Inclusion of LGBTQIA+ people
• Ensuring pay equity and equal access to promotions based on objective criteria
• Promoting diversity and equal opportunity as talent attraction and retention driver

Links to international standards: Aligned with UN Global Compact's SDGs 4, 5, 8, and 10. Commitments through memberships including:

• Diversity Charter (Germany, France, Norway, Belgium, United Kingdom)
• International partnership with UN Women since 2021
• Partnership with Femmes@Numérique in France since 2018
• GEEIS (Gender Equality European & International Standard) accreditation obtained in 2022 and renewed in 2024
• UNI/PdR 125 gender equality certification in Italy (2023 and 2024)
• Member of the ILO Global Business and Disability Network since 2021

Implementation monitoring: Compliance with local regulations and legal frameworks regarding employment of people with disabilities. Regular assessment through various network partnerships and charter renewals.

Employee Protection and Trust Policy

Scope: All employees across all activities, entities and countries where the Group operates.

Governance and oversight: Oversight under responsibility of Executive Management involving all functional and operational departments. Human Resources Department, Sustainability and Corporate Responsibility Department and Internal Control Department work together to define policies, deploy them and track effectiveness.

Key content:

• Foster working conditions promoting employee fulfillment, healthy work pace and work-life balance
• Prevent any type of discrimination, harassment and violence at work
• Prevent psychological risks
• Ensure appropriate management of incidents
• Create a safe, healthy and supportive working environment
• Safeguard health, safety and work-life balance
• Ensure everyone is treated with dignity and respect at work

Links to international standards: Aligned with UN Global Compact's SDGs 3 ("Good health and well-being") and 8 ("Decent work and economic growth"). Based on international occupational health and safety standards.

Implementation monitoring: Through hybrid work measures (at least 2 days remote working per week in all geographies), collective bargaining agreements on remote working in France, Right to Disconnect Charter, Great Place To Work survey for tracking employee engagement and satisfaction, and well-being at work initiatives.

Social Dialogue Policy

Scope: All Group entities and geographies.

Governance and oversight: Responsibility for labour relations lies with the Chief Executive Officer and Human Resources Directors in each country. Local representatives are responsible for holding regular updates with employee representatives and establishing required bodies.

Key content:

• Uphold freedom of association and exercise trade union rights
• Recognize right of collective bargaining and protect employee representatives
• Strengthen collaboration with employee representatives
• Establish regular and constructive dialogue with employee representative bodies at Group level
• Cover matters relating to company strategy, business, financial and employee policy

Links to international standards: Based on ILO conventions. Aligned with UN Global Compact and SDG 8 ("Decent work and economic growth"). Member of UN Global Compact since 2004.

Public availability: Embedded in the Group's Code of Ethics, available on the Ethics and Compliance page of the Group's website at www.soprasteria.com.

Implementation monitoring: Regular discussions between stakeholders, feedback from employees and their representatives. European Works Council established in 2023 met twice in 2024. 55.1% of employees covered by company-wide agreements in 2024.

Taking action on material impacts on own workforce

1. Cybersecurity and IT Security (Own operations)

Actions:

• Continual investment in security awareness and training programmes for employees (e-learning modules, phishing simulation campaigns, videos, on-site and remote training)
• Constant improvement of protection, surveillance and detection systems
• Expansion of teams involved in security areas
• Regular review of procedures: cyber threat monitoring, around-the-clock security event management, vulnerability management, CERT report follow-up, system obsolescence management, compartmentalisation and hardening of systems, rapid network disconnection capabilities
• Preventive control plans for existing systems reliability
• Regular penetration tests for new systems
• Annual audit programme and certification audits (ISO 27001, ISAE 34-02)
• Annual review of policies, procedures, organisation and investments

Scope: Own operations (Group IT Department, SOC, CERT, CISOs within entities)

Resources: Not quantified (described as "continual investment")

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2. Skills and Training Actions

Priority to training and skills [S1-4 including MDR-A]

Objectives and Actions (2024 Achievements):

1) Identify far-reaching changes affecting the Group's businesses over 1-3 years

• Deployed in 100% of geographies
• All business areas covered by professional development programmes
• Academy introduces new programmes and updates existing ones
• Project-based approach with dedicated structure (sponsor, project owner, business specialists)
• Digital platforms for additional training material
• People Dynamics approach incorporated into training content

Key achievements:

• Design and deployment of new AI training courses: 79,242 hours, 23,096 employees trained (45.3% of workforce)
• "Generative AI and prompt engineering" modules for all employees (39.1% France)
• NextGen certifications (AWS, Google Cloud, OVHcloud, Microsoft): 2,000 certifications awarded

2) Draw up HR action plans for acquiring, maintaining and developing required skills

• Career development support: 4,146 employees promoted (34.7% women) = 8.6% of permanent workforce
• 40 international transfers to 10 destinations
• "My Skills" skills management system designed
• Skills development courses for High Potential employees in all countries
• France: 91.39% employees eligible for annual performance appraisal

3) Deploy Management & Leadership programme to all Group managers

• Motivational management training deployed in France, India, Spain, Poland, Norway
• Middle managers course on fulfilling managerial roles

Training volumes (2024):

• Total training hours: 1,466,587
• Average hours per employee: 28.8
• Women: 513,135 hours (30.9 avg)
• Men: 953,452 hours (27.7 avg)

Resources: Financial resources allocated to "Training and Skills Development" considered material but not yet fully quantified (in-depth analysis planned)

Scope: Group-wide (100% for most initiatives; specific percentages noted for regional deployments)

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3. Equal Opportunities and Diversity

Gender Equality Action Plan

1) Engage community and share best practices

• Over 4,500 members in Employee Resource Groups (ERGs) (83.4% scope)
• Passer'Elles network in France: 350+ members (10th anniversary 2025)
• Switzerland: new ERG ~30 employees
• Together For Greater Balance internal platform overhaul

2) Launch Group awareness campaigns

• Annual "Together for Greater Balance" campaign
• International Women's Rights Day panel: ~2,000 attendees
• "Free in my job" employer branding campaign targeting women
• Spain: 4th edition #Mujeresqueinspiran campaign
• Italy: STEAMiamoci project partnership

3) Train employees on gender equality

• 6,188 participants in workplace gender equality training (97.7% scope)
• 4,026 employees in sexual harassment prevention training (82.4% scope)

4) Align with international standards

• UN Women partnership renewal (France, 100% scope)
• Partnerships with external organizations (75.9% Europe)

5) Achieve pay equity

• Shared methodology for gender pay gap analysis
• Corrective actions at HR Committee meetings
• Awareness-raising for managers and HR staff
• Local measures: periodic gap analysis, promotion/compensation adjustments
• France Gender Equality Index 2024: 89/100

Target: 23% of Level 5-6 positions held by women by 31/12/2025 (currently 21.4%)

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Disability Action Plan

1) Monitor disability indicators

• 1,370 employees with disabilities (89.2% scope)
• France: 738 employees with disabilities (283 women = 38.35%)
• 3.94% of new recruits with disabilities

2) Train recruiters

• 100% of recruiters trained in disability accommodation (39.1% France)

Target: France - 3.3% employees with disabilities (2021 target)

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LGBTQIA+ Inclusion Actions

1) Engage community

• 2,900+ members in LGBTQIA+ ERGs (71.3% scope)

2) Train and raise awareness

• 2,309 participants in LGBTQIA+ training (82.1% scope)

3) Support employees

• Guide to Transidentity (UK)
• Italy: year-round webinars with Parks partnership

Target: 100% employees access to non-discrimination training

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Intergenerational Balance Actions

1) Maintain generational balance

• 27.5% workforce under 30 years
• 19.6% workforce over 50 years

2) Attract young talent

• 1,447 interns during 2024 (68.5% scope)
• 1,189 work-linked training students (86.7% scope)
• Happy Trainees France: 6th place, 88% would recommend Sopra Steria
• International Student Challenge: 5,000+ enrolments, 850 projects shortlisted, 3 awarded (78.5% scope)

3) Support retraining

• 156 young people supported (140 France, 16 Tunisia), 33% women (40.3% scope)

4) Facilitate retirement transition

• Phased retirement system
• Retirement information sessions: 1,107 participants (47.6% scope)

Targets:

• Increase women in Executive Committee
• Increase women in 3% most senior positions (Level 5+)
• Increase women in 10% most senior positions (Level 4+)
• Increase women managers (Level 3+)

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4. Employee Protection and Trust

Work-Life Balance Actions

1) Hybrid working

• At least 2 days remote working per week (100% Group)
• France: Collective bargaining agreement + Best Practices Guide (39.1%)

2) Right to disconnect

• "Right to Disconnect" Charter signatory (69.9% scope: Austria, Belgium, Canada, France, Germany, Hong Kong, Italy, Luxembourg, Spain, Sweden, UK)

3) Track employee engagement

• Great Place To Work survey (rescheduled to Q2 2025)
• 2023 results: 82% participation, 77% consider GPTW
• Rankings: 16th Best Workplaces in Europe 2023

4) Support parenthood

• France: Gender equality collective agreement (Jan 2025, 3 years)
• National Corporate Parenthood Charter signatory (2022)
• Childcare support scheme (49.5% France/India)

5) Flexible work organization

• Flexible working hours
• Voluntary part-time: 5.9% workforce
• Leave donation scheme for caregivers (39.1% France)

6) Social protection

• Various measures: parental leave compensation, invalidity, unemployment, retirement (100% Group)

Targets:

• 100% employees access to well-being programme
• Keep Sopra Steria in GPTW rankings
• Exceed 75% satisfaction on 5 criteria (respect, fairness, pride, confidence, empowerment)

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Prevention of Discrimination, Harassment, Psychological Risks

1) Train and raise awareness

• Sexual harassment and sexist behaviour prevention guide (39.1% France)
• TechCare Programme: multimodal training (virtual classes, e-learning, webinars, guides)
• Topics: fire safety, accident response, screen work, psychological risks prevention
• France: "Prevention passport" - 5 e-learning courses (road safety, screen work, fire safety, risk prevention, psychological risks)
• Mental health protection guide available on intranet

2) Address health and well-being

• Network of professionals: social workers, nurses, occupational health staff, ergonomics specialists
• Training and tools for managers (hybrid working, guides, coaching) (39.1% France)

3) Whistleblowing mechanism

• Group whistleblowing procedure covers discrimination, harassment, human rights violations (100% Group)
• Systematic investigation of each alert
• Local alert mechanisms per country regulation (39.1% France)
• No fines/penalties/damages paid in 2024
• No complaints filed with OECD National Contact Points

Target: 100% employees access to well-being programme

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5. Pre-Sales and Delivery Quality

Risk Management Actions (Own operations):

Delivery Rule Book:

• Mandatory rules for full operations lifecycle: pre-sales, initialization, renewals, project management, delivery cycle, closing
• Project directors/supervisors selected based on risk level and complexity criteria
• Specific training for project managers, regularly updated

Review and monitoring:

• Industrial managers monitor all projects and application of production rules
• Proposal and contract review by line management, Industrial Department, Legal, Finance
• Pre-sales KPIs track milestone achievement
• Regular project reviews at key production lifecycle phases
• Compliance reviews via checklists
• Monthly steering meetings for quality overview and action plans

Resources: Not quantified

Scope: Group-wide (>2/3 of consolidated revenue from fixed-price projects and managed/operated services)

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6. Social Dialogue

Actions:

• European Works Council (EWC) established 2023, met twice in 2024
• Regular updates with employee representatives
• Collective bargaining agreements: 55.1% employees covered in 2024
• France: 80-100% collective bargaining coverage
• Support and development mechanisms during reorganization: internal mobility, training

Scope: 55.1% Group employees; France (80-100% coverage)

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Resources Summary

While numerous actions are described across all material workforce topics, financial resources are rarely quantified. The company notes that:

• Financial resources for "Training and Skills Development" are considered material
• In-depth analysis needed in coming years to better quantify expenses per topic (CSRD Section 1.3.2.1 reference)
• Cybersecurity described as "continual investment" without amounts
• Most actions report participation numbers, coverage percentages, or qualitative outcomes rather than budget allocations

Targets related to own workforce

Sopra Steria has set targets for 2025 (established in 2021) at Group level across four material matters:

Overview of 2025 Targets

Target Modifications

In 2024, marginal changes were made:

• The target on the proportion of women in Level 5 and 6 positions was raised from 20% (initially set by the Board of Directors in 2021) to 23% at 31 December 2025
• Targets relating to the Great Place To Work survey for employee protection and trust were set in 2023 for the period 2023-2030

Target characteristics

• Target year: 2025 (for most targets); 2030 (for Great Place To Work targets)
• Baseline year: 2021 (for most targets); 2023 (for Great Place To Work targets)
• Scope: Group level; some targets specific to France (disabilities target, Management & Leadership programme initial scope)
• Type: Mix of absolute targets (percentages, 100% coverage) and directional targets (increase proportion)
• Validation: Internal targets set by Executive Management, Human Resources Department, Sustainability & CSR Department and employee representatives

Characteristics of the undertaking's employees

Total headcount and FTE

As at 31 December 2024:

• Total net headcount: 50,988 employees (excluding interns)
• Total headcount including interns: 51,237 employees

As at 31 December 2023:

• Total net headcount: 51,768 employees (excluding interns)
• Total headcount including interns: 52,041 employees

Note: Workforce figures excluding interns are reported in accordance with the requirements of the CSRD.

Headcount by geographic region

2024 regional breakdown by revenue:

• France: 42% of Group revenue (€2,437.9 million)
• United Kingdom: 17% of Group revenue (€962.1 million)
• Europe (other): 35% of Group revenue (€2,049.0 million)
• Solutions: 6% of Group revenue (€327.8 million)

Approximately 7,900 staff were employed at international service centres (unchanged at constant scope from 2023).

Employee turnover

Workforce attrition rate:

• 2024: 14.1%
• 2023: 15.7%

Note: Attrition rate includes top performers who left less than six months after they were recruited, in accordance with the requirements of the CSRD.

Gender diversity in leadership

Proportion of women in senior positions (2024):

• In the 3% most senior positions: 21.4% (increase of 1.3 percentage points from 2023)
• In the 10% most senior positions: 22.3% (increase of 0.8 percentage points from 2023)

Training

Training hours (2024):

• Total training hours provided: 1,466,587 hours
• Average training per employee: 29 hours
• 2023 comparison: 29 hours per employee (same level)

Board of Directors diversity

Gender composition (appointments made at General Meeting):

• Women: 6 out of 14 appointments (43%)
• Total Board members: 17 Directors

Age:

• Average age of Board members: 65 years (as at 31/12/2024)
• Directors over 75 years: 3 out of 17

Nationality:

• Directors holding citizenship from a country other than France: 5 out of 17

Methodological notes

Workforce data is reported in accordance with CSRD requirements. The net headcount excludes interns for CSRD compliance purposes. The attrition rate calculation includes top performers who departed within six months of recruitment, as required by CSRD. Regional breakdowns are presented as percentage of Group revenue rather than headcount splits.

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

Overview of non-employee workforce

The Group's workforce mainly consists of employees on permanent contracts with at least a master's degree or equivalent. A minority of employees are on temporary, work-linked training contracts or standing in for other employees (see Section 9, "Workforce and environmental indicators" of the present chapter).

Non-employees represent a minority of the Group's workforce, mainly self-employed workers and external providers.

Methodology

No specific headcount figures, FTE conversion methodology, or multi-year comparative data for non-employee workers are disclosed in the available excerpts.

Collective bargaining coverage and social dialogue

Collective bargaining coverage rate

Scope covered by a company-wide agreement: 55.1% of employees covered in 2024

Coverage by geography and representation type

The following social dialogue indicators cover countries with more than 50 employees and representing more than 10% of the total workforce. Countries that fit these criteria are France, India and the United Kingdom.

European Works Council

In Europe, an agreement was signed in 2022 to create a European Works Council (EWC) for the Group. Established in 2023, the EWC is the European body of employee representation. The council met twice in 2024 to ensure the right to information regarding cross-border subjects for employees in the European Union and European Economic Area.

Directors representing employees

• One Director representing the employees was appointed on 27 June 2024 by the trade union that won the most votes in the first round of elections to the Works Council of the Company (Hélène Badosa)
• One Director representing the employees was designated on 11 July 2024 by the European Works Council (William Beaumond)
• A Director representing employee shareholders (Astrid Anciaux) was elected at the General Meeting of Shareholders held on 26 May 2021

Methodology note

Data used to calculate collective bargaining coverage indicators are collected in accordance with local legislation. The scope coverage represents 55.1% of the Group workforce. The coverage breakdown by geography focuses on countries representing more than 10% of total employees and having more than 50 employees.

Diversity metrics

Gender split at top management level

Proportion by gender (2024 vs 2023)

Notes:

• 3% most senior positions corresponds to "top management level" as stated in ESRS S1-9 (Level 5 and 6 positions)
• 10% most senior positions corresponds to Level 4, 5 and 6 positions
• Managers corresponds to Level 3, 4, 5 and 6 positions

Gender split - Recruitment and total workforce

Age band distribution of total workforce

Workforce by age (2024 vs 2023)

Average age: 39.4 in 2024, compared to 38.9 in 2023.

Age pyramid breakdown (Women vs Men) - multi-year comparison

Note: The calculation method includes employees hired in financial year 2024.

Additional age distribution detail (Group and key geographies)

Selected country breakdowns:

Methodology notes:

• The method for calculating these figures did not incorporate employees hired in financial year 2024 (except where specifically noted)
• 2023 figures include interns
• Acquisitions included where specified

Adequate wages

Sopra Steria states that employee compensation is compliant with local regulations and exceeds the minimum wage (where one exists) in the countries where the Group operates.

The Group carries out compensation surveys to ensure that compensation is appropriate (referenced as "adequate wage").

Depending on the country, employees benefit from certain benefits and social protection measures such as healthcare, incapacity and invalidity cover, parental leave and supplementary pension provision.

Compensation principles are implemented in each entity and country in accordance with the local context and legal obligations, and taking into account changes prompted by social dialogue.

Benchmark used

No living wage benchmark is disclosed. The company references only:

• Compliance with local regulations
• Exceeding minimum wage (where it exists)
• Compensation surveys (unspecified methodology)

Coverage

Not disclosed.

Geographic scope

All countries where the Group operates (specific countries not enumerated for wage benchmarking purposes).

Targets

No targets or commitments disclosed regarding adequate or living wages.

Methodology

No methodology details provided regarding how "adequate wage" is calculated or assessed. The company mentions that data collection challenges exist, particularly regarding variable compensation, and that an action plan has been initiated to standardize practices and harmonize data quality to meet CSRD requirements.

Social protection

Coverage overview

Employee compensation is compliant with local regulations and exceeds the minimum wage (where one exists) in the countries where the Group operates. The Group also carries out compensation surveys to ensure that the compensation is appropriate (see "adequate wage"). Additionally, depending on the country, employees benefit from certain benefits and social protection measures such as healthcare, incapacity and invalidity cover, parental leave and supplementary pension provision. Compensation principles are implemented in each entities and countries in accordance with the local context and legal obligations, and taking into account changes prompted by social dialogue.

Social protection measures

As part of the "Equal opportunities and diversity" policy, the Group takes into account employees' specific situations by allowing flexibility in the way work is organized, and offers employees a social protection scheme. Social protection measures vary between entities and include:

• Compensation continuance during parental leave or invalidity
• Unemployment benefits
• Retirement plan

Scope: 100% of scope: Group

Specific social protection elements

France:

• Company car
• Contribution to the GSC unemployment insurance for executives

Leave and flexibility:

• Part-time working rate among employees on permanent contracts: 5.9% (vs 5.9% in 2023). Part-time working is never mandatory.
• Leave donation scheme for employees who are caregivers or in the event of a death in the family (child or dependent spouse)
• Scope: 39.1% of scope: France

Post-employment benefits

Post-employment benefits mainly concern the Group's obligations and defined-benefit pension plan towards its employees to provide retirement bonuses in France (10.6% of the Group's total obligations) and defined-benefit pension plans in the United Kingdom (85.2% of the Group's total obligations excluding plan assets) and in Germany (3.2%). For marginal amounts, they also include retirement bonuses in some other countries, as well as defined-benefit plans in the Netherlands and Belgium.

At 31 December 2024, Post-employment benefits represented a net liability of €135.9 million (€167.8 million at 31 December 2023).

Data collection note

To ensure that indicators published are of qualitative, reliable and representative, meet all the requirements of the CSRD and enable an effective comparison between one year and the next, the Group has started putting in place a specific action plan to facilitate future data collection for these indicators. As part of this approach, a first identification exercise covering the various types of variables and advantages existing within the Group was carried out across all countries in 2024. This process was essential to structure the data in a consistent and reliable way at the international level, while providing transparency and a standard of accuracy in line with the requirements of the CSRD and expectations of stakeholders.

Persons with disabilities

Overall metrics

Total employees with disabilities: 1,370 employees

Scope: 89.2% of scope (Europe and India)

Methodology

Data used to calculate this indicator are collected in accordance with local legislation. In countries where data collection is prohibited by legal standards, data is obtained on a voluntary self-reporting basis guaranteeing respondents' anonymity, as part of the Great Place To Work satisfaction surveys for example.

France-specific metrics

Total employees with disabilities in France: 738 employees (including 283 women, representing 38.35%)

Scope: 39.1% of scope (France)

New recruits with disabilities: 3.94% of new recruits were women (vs 3.60% in 2023)

Scope: 39.1% of scope (France)

Training and awareness

Recruiters trained: 100% of recruiters trained in taking disability into account during the recruitment process

Scope: 39.1% of scope (France)

Disability-related training participants: 9,771 participants to trainings on disability-related topics

Scope: 94.8% of scope (Europe, Asia, Africa)

Support measures

Compensatory measures in France: More than 2,317 ongoing compensatory measures to mitigate the impact of a disability. Over 560 employees with disabilities received support from Mission Handicap in 2024.

Disability officers: 65 disability officers acted as local representatives of Mission Handicap

Scope: 39.1% of scope (France)

Grants and education support

Grants awarded: 25 grants awarded to students with disabilities through the annual programme, 80% of grant applications were approved. More than 580 students have received support since 2013 through tutoring programme.

Scope: 39.1% of scope (France)

Employee Resource Groups

ERG membership: Employee Resource Groups (ERG) focusing on disability have more than 900 members

Scope: 65.0% of scope (Europe)

Country-specific exclusions

In countries where data collection is prohibited by legal standards, data is obtained on a voluntary self-reporting basis guaranteeing respondents' anonymity.

Training and skills development metrics

Average training hours per employee

Overall average training hours:

Average training hours by gender:

Average training hours by region (2024):

Performance and career development reviews

France (39.1% of scope):

• 91.39% of employees are eligible for an annual performance appraisal (eligibility depends on contract type - permanent contract - and contract start date before 01/07/2024)
• 100% of eligible employees were assessed
• Target: 100% of eligible employees

Promotions

Training coverage

• AI training (2024): 23,096 Group employees (45.3% of workforce) received AI training for a total of 79,242 hours
• In-house trainers: Over 1,500 in-house trainers
• Professional business training: 177,463 hours
• NextGen certifications: 2,000 certifications awarded (AWS, Google Cloud, OVHcloud, Microsoft)

International mobility

Scope: Europe, Africa, North America

Training hours by type (2024)

Average mandatory training per employee:

Methodological notes

• 2024 data incorporates year-on-year changes in Group scope
• 2023 indicators were recalculated excluding SBS (Sopra Banking Software) to allow comparison
• Social indicators are based on the Group's workforce at 1 January 2024, excluding the SBS workforce who remained with the company until 2 September 2024
• Training data includes both mandatory and non-mandatory training unless otherwise specified

Health and safety metrics

Health and safety indicators – France

Scope: 39.1% of Group scope (France only).

Coverage: No explicit coverage percentage for the health and safety management system was disclosed in the document.

Methodology notes:

• Frequency rate of workplace accidents in France: Calculated in business days, using the following formula: (Number of workplace accidents with medical leave × 1,000,000) / Total number of hours worked by total workforce in the year.
• Severity rate of workplace accidents in France: (Number of working days lost due to workplace accidents × 1,000) / Total number of hours worked by total workforce in the year.
• Absenteeism rate: Calculated in business days and on the basis of the average full-time equivalent workforce. It takes into account absences for illness, workplace accidents and accidents while travelling. It corresponds to the ratio of the number of actual calendar days' absence and the number of work days theoretically available.
• Medical leaves continuing on as a result of workplace accidents that occurred the previous year are not counted.
• The scope of 2024 reporting does not include Sopra Banking Software.

Disclosure limitation: To guarantee the publication of reliable and accurate information, Sopra Steria has chosen not to publish indicators relating to health and safety on a Group scope in this first year of CSRD reporting. In the interest of transparency, the Group has nevertheless chosen to publish this data on France's scope, which accounted for 39.1% of the Group's workforce in 2024.

Work-life balance metrics

Employees entitled to family leave

Scope: 100% of Group

Employees who have taken family leave in France

Scope: 31% of Group scope (Sopra Steria Group SA, Sopra Solutions, Sopra Steria I2S, Galitt and 2MoRO - France only)

Methodology note

To guarantee the publication of reliable and accurate information, Sopra Steria has chosen not to publish indicators relating to the proportion of employees who have taken family leave on a Group scope in this first year of CSRD reporting. This reflects the Group's commitment to standardizing reporting practices in order to ensure the reliability of data relating to this indicator across all the countries where it operates. In the interest of transparency on this first year of CSRD reporting, the Group has nevertheless chosen to publish this data on a partial French scope, which accounted for 31% of the Group's workforce in 2024. The Group is currently implementing an action plan to collect information throughout the rest of the countries where it operates, with the aim of publishing consolidated data in the coming years.

Work-life balance policy actions

The Group implements the following measures to support work-life balance:

• Remote working: At least 2 days' remote working per week in all geographies, depending on the context (100% of Group scope). Collective bargaining agreement on remote working in France (39.1% of scope)
• Right to disconnect: Signatory of the "Right to Disconnect" Charter (69.9% of scope: Austria, Belgium, Canada, France, Germany, Hong Kong, Italy, Luxembourg, Spain, Sweden, United Kingdom)
• Parental support: Collective bargaining agreement in favour of gender equality signed in January 2025 in France for three years. Signatory to the National Corporate Parenthood Charter (since 2022). Childcare support scheme (49.5% of scope: France and India)
• Flexible working: Flexible working hours and mandatory attendance times. Voluntary part-time working for employees on permanent contracts: 5.9% in 2024 (vs 5.9% in 2023). Part-time working is never mandatory. Leave donation scheme for employees who are caregivers or in the event of a death in the family (39.1% of scope: France)
• Social protection: Social protection measures vary between entities including compensation continuance during parental leave or invalidity, unemployment benefits, retirement plan (100% of Group scope)

Compensation metrics (ESRS S1-16)

Pay gap

Sopra Steria has not disclosed gender pay gap figures in accordance with ESRS S1-16 requirements in this report.

The company has committed to implementing a methodology for analyzing gender pay gaps. According to the 2024 disclosure:

"To ensure that data published is consistent and reliable, Sopra Steria has decided not to publish, for this first year of CSRD reporting, indicators regarding gender pay gap and total compensation ratio. Groundwork carried out with the various subsidiaries and countries while preparing data collection and publication highlighted several issues, especially the need to standardise practices between the different entities and harmonise the quality of the data reported by the countries to match definitions given in the CSRD, particularly regarding variable compensation."

The company has started an action plan to facilitate future data collection for these indicators, including an identification exercise covering various types of variables and advantages across all countries in 2024.

France-specific index: The company reports a workplace gender equality index score of 89/100 for France, which includes a pillar dedicated to the gender pay gap.

Remuneration ratio

Sopra Steria has disclosed detailed remuneration ratios for both the Chairman of the Board of Directors and the Chief Executive Officer.

Chairman of the Board of Directors - Pay Ratios

Chief Executive Officer - Pay Ratios

Methodology

Scope: The ratios are calculated using an extended scope covering on average 88% of the workforce in France over the period (81% for Chairman ratios). Employees of the SBS subsidiary sold on 2 September 2024 have been excluded from the scope for the whole of 2024.

Numerators:

• Chairman's and CEO's compensation corresponds to amounts awarded as shown in AFEP-MEDEF tables
• For CEO: Performance shares effectively delivered or deliverable are redistributed over each financial year covered by the plan

Denominators:

• For employees, compensation includes fixed and variable compensation, bonuses, incentives and profit-sharing
• Does NOT include performance share plans or shares granted as matching employer contributions under employee share ownership plans

Additional ratios (Sopra Steria Group SA scope): The company also provides ratios calculated on a narrower scope (Sopra Steria Group SA entity), showing similar trends.

Incidents, complaints and severe human rights impacts

Incidents and Complaints (France)

Scope: France only (39.1% of Group workforce in 2024)

In France, alert monitoring and the data collection process are under the responsibility of the Social Legal Department, through a regularly updated follow-up file.

Alerts relating to human rights violations are handled by the Internal Control Department.

Fines, Penalties and Compensation

No fine, penalty or compensation for damages relating to an incident of discrimination or harassment or due to a complaint was paid during 2024.

Severe Human Rights Impacts

No serious human rights violations or non-compliance with any of the United Nations or OECD guidelines in connection with Sopra Steria employees, end-users or local communities were identified or reported through the Group's whistleblowing channel.

No complaints were filed against Sopra Steria with the various National Contact Points for OECD Multinational Enterprises during financial year 2024 or previous financial years.

Grievance Mechanisms

The Group provides employees with a whistleblowing system in all Group entities. If the investigation proves conclusive, punitive measures can range from disciplinary action up to dismissal.

Additionally to the Group procedure, local alert mechanisms are in place, as required by each country regulation.

Methodology Note

Sopra Steria has chosen not to publish indicators relating to registered alerts and investigations on a Group scope in this first year of CSRD reporting, reflecting the Group's commitment to standardizing reporting practices. The Group is currently implementing an action plan to collect information throughout the rest of the countries where it operates, with the aim of publishing consolidated data in the coming years.

Policies related to affected communities

Regional presence policy

Sopra Steria has maintained a regional presence policy since its creation in 1968, demonstrated by maintaining its registered office in Annecy. The policy emphasizes proximity with stakeholders, particularly employees and clients, as a core value.

Key principles:

• Maintain significant presence in main geographic areas of operations
• Optimize positive impact on regions where the Group operates
• Provide in-depth knowledge, ongoing support, development and resilience of the regions
• Adapt approach based on country size and local economy specificities

Scope:

• Applied across all regions where the Group operates: France, UK, Benelux, and Scandinavia
• 57 sites in mainland France across 44 towns and 12 regions divided between eight regional departments
• 16 towns in the United Kingdom
• 14 towns in Germany
• Specific subsidiaries (CIMPA and CS Group) have developed specific ties with their respective regions

Governance and implementation:

• Group's Executive Committee includes representatives of the four main regions (France, UK, Benelux, Scandinavia)
• Country managers are autonomous when choosing their action plans
• Implementation adapted for each country depending on business size and local economy specificities

Public availability: Not disclosed

International standards alignment: Not disclosed

Monitoring: Not disclosed

Taking action on material impacts on affected communities

Sopra Steria implements its community engagement policy through decentralized, locally-adapted initiatives across its geographic footprint. Actions focus on digital inclusion, education, and regional presence.

1. Solidarity and Volunteering Initiatives

Scope: Own operations and local communities
Time horizon: Ongoing (2024 and beyond)

France initiatives (2024):

• Robot challenges at primary schools partnering with La main à la pâte Foundation (supported since 2021)
• Training in generative AI for young people (NEETs) receiving access-to-work and social integration support from the Falret Foundation (supported since 2023)
• Continued backing for roll-out of Adiléos solutions to social organisations combating general exclusion (supported since 2014)
• Revamping of the FNSF website (French national federation for solidarity with women), including security improvements (third project since 2019)
• Development of the Clic&Moi academy helping seniors embrace digital technology

Sopra Steria India Foundation Educational Programme:

Beneficiaries: 47,375 disadvantaged children and young people in 2024
Beneficiaries (awareness campaigns): Over 6,000 pupils in 2024

Four-pillar approach:

• Access to high-quality education (shared libraries, educational equipment, school fees coverage, higher education grants over 3-5 years)
• Access to digital learning resources (computer labs, smart interactive LED whiteboards, STEM labs)
• Awareness-raising about health and hygiene for adolescent girls (sanitary towel distributions, toilet construction/renovation, information sessions)
• Environmental responsibility (solar panel installation, tree planting, e-waste recycling, composting facilities, awareness workshops)

Resources: €12,000 financed by Germany for two Foundation projects; 4 German staff members provided voluntary IT knowledge sharing to 700+ students

Spain:

• Employees spoke at secondary schools in "Territorio Joven" programme
• Beneficiaries: 83 young people at risk (aged 13-17)
• Outcome: Academic failure protection and social skills development

2. Regional Presence Actions

Scope: Own operations and local communities
Time horizon: 2024 with continuation planned for 2025+

Germany:

• Active involvement in regional and national professional organisations (BITKOM, BDU, VDR)
• Creation of professional opportunities (remote job offers in less populated areas)
• Support for local cultural initiatives (exhibitions, premises loans)
• Outcome: Contribution to revitalising employment pools and culture
• 2025+ projection: Continuation of local commitments

Benelux and Italy:

• Partnership with Trees for All to maintain local forests and crops (agroforestry)
• Employee and local community involvement
• Outcome: Raising awareness for improvement of local surroundings and cementing local connections
• 2025+ projection: Extension to further regions

Spain:

• Creation and roll-out of the INCV application in partnership with Fundación Randstad
• Purpose: Facilitate access to employment for people with disabilities and refugees
• Outcome: Improved social inclusion by building connections between marginalised job applicants and local businesses
• 2025+ projection: Extension to further regions of Spain and first stage of international roll-out, beginning with Germany

India:

• Solar panel installation projects for schools
• Water conservation actions
• Awareness-raising actions
• Energy consumption reduction
• Solar power use and tree planting on campus
• Outcome: Local regions made more environmentally resilient and reduced impact of sites on local ecosystems
• 2025+ projection: Extension of local solidarity initiatives

3. Community Engagement Implementation Process

Approach: Decentralised implementation at country/subsidiary level
Selection criteria: Annual evaluation of partner school needs; initiatives chosen based on local priorities and contexts
Collaboration model: Support for non-profits with specialised expertise, regular voluntary employee support, cross-country collaboration

Targets related to affected communities

Section 3.2.3.2. Targets related to regional presence [S3-5 including MDR-T]

Sopra Steria has not established any overall targets or unified monitoring systems focused on the optimisation of the Group's positive impact on the regions where it operates.

Rationale for absence of quantified targets:

• The quantitative measure was not used at this stage, partly due to the challenges of identifying and measuring regional presence quantitatively and accurately, taking into account the interests of the local communities and the diversity of regions and their social and economic contexts
• The social nature of the impact necessitates balanced measurement that takes into account the contexts, needs and priorities defined by the regions

Planned assessment:

• The year 2025 will be an opportunity to assess the monitoring of regional presence, looking in particular at the first year of operation for the regional management structure within the France reporting unit and this first year of reporting on the Group's regional presence

Impact criteria under development: In the context of the double materiality assessment and in connection with the creation of regional management within the France reporting unit, Sopra Steria has begun work to ascertain impact "criteria" for its regional presence. At a later date, this may lead to monitoring of the implementation and effectiveness of the Group's regional approach, in respect of:

• Support for training and the local education system
• Development of knowledge and appropriate solutions for the economic and social challenges faced by local authorities
• Development of local centres of expertise
• Development of local partnerships
• Jobs created directly and indirectly
• Support for local non-profits
• Support for essential services in the region

Policies related to consumers and end-users

Sopra Steria does not disclose a general policy specifically dedicated to consumers and end-users under ESRS S4-1. However, the company addresses end-users through two main thematic policies:

Policy related to contribution to essential public services

Scope: The policy applies to the whole Group and covers major clients in the essential public services sector across multiple verticals including Public Services and Health, Defence, Security and Space, Transport, and Energy & Utilities.

Key content and principles:

• Ensuring continuity and quality of essential public services by designing, maintaining and improving digital services
• Developing the skills needed to design and use digital products and services useful to essential public services
• Using new technologies and data analysis to multiply the benefits of digital technology for all essential services
• Taking into account the sensitivity of projects based on clients' legal characteristics, industry criticality, and impact on human living conditions
• Incorporating safety precautions and sector-specific features into the organization through specialized verticals

Governance: The approach integrates the Group's operating model through decision cycles and usual management bodies, particularly in each vertical. An Institutional Relations team was established in 2024 and extended in 2025 to improve dialogue with public-sector operators and contribute to the Group's visibility.

Implementation: Each vertical implements and monitors its projects and initiatives independently, taking into account the challenges of each essential service. The Group also rolls out cross-functional actions and resources for training and market visibility.

Link to international standards: The Group's approach to human rights regarding end-users is described in the introductory section on Social information and in the due diligence section. In application of the Group's due diligence and human rights commitments, Sopra Steria continuously ensures that its actions do not have a severe negative impact on end-users.

Related thematic policies mentioned

Sopra Steria references the following policies as related to end-user concerns:

• Information security and protection policy (related to cyberprotection and digital sovereignty)
• Personal data protection policy (related to cyberprotection and digital sovereignty)
• Responsible digital technology roadmap (related to developing responsible digital technology)

These policies address material matters including cyberprotection and digital sovereignty, and developing responsible digital technology, which impact end-users. However, detailed policy content for these is not fully disclosed in the S4-1 section.

Note: The Group has not formalized a general policy on essential public services, and the approach is primarily geared towards qualitative targets ensuring services run without interruption and meet the needs of customers, end-users and partners.

Targets related to consumers

Section 3.3.2.2. Targets related to the contribution to essential public services [S4-5 including MDR-T]

The Group's policy is geared towards its qualitative targets with the aim of ensuring that these services run without interruption and meet the needs of customers, end-users and partners. This approach and, by extension its monitoring, applies to the whole Group and is based, as a minimum, on comparing the satisfaction level of the clients, end-users and partners involved in the projects.

Sopra Steria has not defined quantitative targets in relation to the contribution to essential public services. Quantitative measurement has not been adopted at this stage due to the difficulty of quantifying the positive impacts in a uniform and faithful manner, taking into account the portion attributable to Sopra Steria, the interests of all parties affected and the different types of projects.

Incidents of corruption or bribery

Confirmed incidents

To the best of the Company's knowledge at the time of writing this sustainability statement, neither Sopra Steria, nor its subsidiaries nor any member of an administrative or management body have been found guilty of or been fined for corruption or influence peddling at any time in the last five years. Furthermore, no confirmed corruption incidents were recorded via the Group's whistleblowing procedure in 2024.

Convictions and fines

No convictions or fines for corruption or bribery were reported during the 2024 financial year or the preceding five years.

Disciplinary actions and contracts terminated

The disclosure does not provide specific quantitative information on employees dismissed or disciplined, or contracts with business partners terminated or not renewed due to corruption or bribery incidents in 2024.

Investigation and speak-up mechanisms

Sopra Steria has implemented a comprehensive whistleblowing procedure accessible to all Group entities and geographies. This procedure is open at all times to employees and external stakeholders (including clients, suppliers, subcontractors and business partners). The procedure covers corruption and influence peddling, fraud, financial offences, breaches of competition law, and risks relating to human rights and fundamental freedoms, health and safety, and environmental damage.

Key features of the whistleblowing mechanism:

• Reports can be submitted to line managers, Compliance Officers at entity level, functional division Compliance Officers, or the Group Compliance Officer
• An email address (ethics@soprasteria.com) is available for direct reporting to the Internal Control Department
• Anonymous reporting is permitted if events are described in detail and deemed serious
• Receipt is acknowledged within 7 working days
• Validity is confirmed within a reasonable timeframe
• Initial feedback is provided within 3 months of acknowledgment
• Whistleblower identity and confidentiality are protected
• Protection against reprisals, discrimination and disciplinary sanctions

Based on investigation findings, the Company may commence disciplinary, legal or administrative proceedings. The Internal Control Department manages the whistleblowing procedure and coordinates compliance programmes including mandatory e-learning on anti-corruption for all employees (93% completion rate as of end-December 2024).

Payment practices

Trade payables maturity schedule (Company level)

The Trade payables and related accounts item came to €169,919 thousand. It comprised accrued expenses for €90,375 thousand, invoices not past due for €76,472 thousand and past due invoices for €3,072 thousand.

Past due invoices received and not yet paid (Article D. 441-4 I. 1° of the French Commercial Code)

Invoices excluded relating to disputed payables and receivables or not recorded in the accounts:

• Number of invoices excluded: 0
• Total amount of invoices excluded (€k, incl. VAT): 0

Payment terms used as reference:

• Contractual deadline: 30 to 45 days
• Legal deadline: 45 days

Trade receivables maturity schedule (Company level)

The Trade receivables and related accounts item came to €427,062 thousand. It comprised accrued income for €112,270 thousand, invoices not past due for €277,718 thousand and past due invoices for €37,074 thousand.

Past due invoices issued and not yet paid (Article D. 441-4 I. 2° of the French Commercial Code)

Invoices excluded relating to disputed payables and receivables or not recorded in the accounts:

• Number of invoices excluded: 0
• Total amount of invoices excluded (€k, incl. VAT): 0

Payment terms used as reference:

• Contractual deadline: 45 days
• Legal deadline: 45 days