Universal Music Group

The role of the administrative, management and supervisory bodies

Reference: pages 113-115 (incorporation-by-reference table), 61, 63-65, 68-71.

UMG N.V. has a one-tier Board of two Executive Directors and nine Non-Executive Directors (page 61). "None of the Non-Executive Directors represents the Company's employees and other workers" (pages 61, 113). Three Board committees prepare Board decision-making: the Audit Committee, the Remuneration Committee and the Nomination Committee (page 68). A separate Market Disclosure Committee exists but "is not a committee of the Board" (page 70).

Allocation of responsibility (page 71): the Board "is responsible for developing a view on sustainable long-term value creation ... which includes overseeing the Company's sustainability impacts, risks and opportunities, as well as the integrity of the Company's sustainability reporting". The Audit Committee supports and advises the Board and "covers environmental, social, and governance (ESG) topics on its agenda". The ESG team, led by the Head of Sustainability, develops the sustainability strategy, measures performance and briefs the Board. Business-unit executive leaders hold day-to-day oversight. A cross-functional SteerCo, formed in 2023 and drawn from senior leaders across the business units, reviewed and approved each phase of the DMA (page 71).

The GOV-1 paragraph 21 (a)-(e) datapoints are incorporated by reference to the Corporate Governance and Non-Executive Directors' Report chapters (pages 113-115). Board gender split at 31 December 2025: 45% female across all Directors, 56% of Non-Executive Directors, 0% of Executive Directors (page 65); independence is stated as 50% (page 115).

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: page 115 (incorporation-by-reference table), page 71.

The paragraph 26 (a)-(c) datapoints are incorporated by reference to "Corporate Governance - The Board, Sustainability management" in the Board report (page 115, pointing to page 71). UMG does not restate them in the sustainability statement.

At page 71 the report states that "The Board and Board committees are also regularly briefed on the Company's material topics, both in writing and during meetings, and have spent significant time discussing several of these topics, including UMG's relationships with its artists, content protection in general, and in particular in the context of risks posed by (generative) artificial intelligence and employee attraction and retention, including through the implementation of the 2022 UMG Global Equity Plan."

The Audit Committee "covers environmental, social, and governance (ESG) topics on its agenda" and supports the Board on the integrity of sustainability reporting (page 71). The ESG team "regularly briefs the SteerCo on relevant sustainability matters, and the SteerCo receives briefings and trainings from external subject matter experts as needed" (page 71). Stakeholder input reaches management or the Board "through various channels, including through our Investor Relations team, as part of our DMA process and through regular internal periodic reporting" (page 123). The final list of material topics and IROs was "presented to the Audit Committee for review" (page 128).

No frequency of sustainability reporting to the Board is stated numerically.

Integration of sustainability-related performance in incentive schemes

Reference: pages 115-116 (incorporation-by-reference table), page 68.

This is a nil return. The additional-information column against paragraph 29 records: "Incentive plans for the Executive Directors do not currently incorporate key performance indicators linked to sustainability matters." (pages 115-116).

The Board report is more explicit (page 68): "The short-term and long-term incentive plans for the Executive Directors ... do not currently incorporate key performance indicators linked to sustainability matters. The Board may explore the inclusion thereof in the short-term and/or long-term incentive plans for the Executive Directors in future years."

Non-Executive Director remuneration "consists of a cash retainer and an annual grant of restricted share units (RSUs), is fixed and not dependent on the Company's results or the attainment of key performance indicators, whether or not linked to sustainability matters" (page 68).

The climate-specific datapoint (E1.GOV-3, "whether and how climate-related considerations are factored into remuneration") carries the same cross-reference and the same statement (page 116). So no proportion of variable remuneration is linked to sustainability or climate performance for either Executive or Non-Executive Directors.

Statement on due diligence

Reference: page 118.

UMG presents the required mapping table of the core elements of due diligence to the paragraphs of the sustainability statement where they are covered:

The table is the whole of the GOV-4 disclosure: no narrative on the due diligence process accompanies it. The mapping reflects UMG's narrow material scope - the only environmental element cited is climate (E1-4, E1-6) under effectiveness tracking, and the only value-chain element is G1-2 (supplier relationships).

Risk management and internal controls over sustainability reporting

Reference: pages 115-116 (incorporation-by-reference table), pages 118-119.

Control environment (page 118). For quantitative disclosures UMG uses "a global data collection and consolidation platform for environmental and social demographics reporting", designed with "mathematical coherency checks for data consistency and to flag any potentially abnormal variation during the data input process". Each reporting entity performs an initial validation; the ESG department performs "a second coherency check and validation during the consolidation process", then conducts trend analysis, validates results with business unit leaders and documents explanations for variances. Qualitative disclosures are gathered in a centralised database.

2025 developments (page 118): "Following the integration of additional controls for CSRD-specific datapoints in 2024, our focus shifted towards enhancing the precision and documentation of existing controls. Key improvements included refining validation procedures, clarifying control ownership across relevant functions, and further formalizing documentation."

Link to risk management (page 118): the DMA "considered the results of our latest annual risk assessment"; in 2025 the SteerCo, "which includes key risk management personnel, reviewed, evaluated, and confirmed the results of our most recent DMA".

Stated limitation (page 119): "the internal control framework for sustainability data is at an earlier stage of maturity than that for financial reporting. This is due to inherent limitations, such as the evolving regulatory landscape, diverse data sources, manual processes, and limited automated controls."

The paragraph 36 (b) risk-prioritisation and 36 (e) periodic-reporting datapoints are incorporated by reference to the Risk and Risk Management chapter (page 115).

Strategy, business model and value chain

Reference: pages 119-122; employee breakdown page 153.

UMG links seven strategic focal points from the Board report to its material sustainability matters (pages 119-121): discovering and breaking new artists; maximising and protecting the catalogue; driving subscription and ad-supported streaming growth; partnerships with tech innovators; advancing data and insights; superfan/D2C and eCommerce; and using music's influence to drive social conversation. Climate sits under the last of these - "we believe that our purpose ... includes supporting action on climate change" - together with a plain statement of the obstacles: "Challenges to reducing our scope 1 and 2 emissions include the availability of renewable energy solutions in markets where we operate; barriers to purchasing renewable energy for small, leased facilities; and potential increased costs for renewable energy solutions" (page 120).

Value chain (page 122): upstream - merchandising suppliers, artists and songwriters; own operations - recorded music, music publishing, merchandising; downstream - physical supply chain and logistics, content publishers, digital supply chain, collection societies, performance rights owners, and fans.

Employee headcount by geographical area (SBM-1 40(a)(iii), page 153): EMEA 4,571; North America 3,733; APAC 1,629; LATAM and Iberia 662; total 10,595.

UMG states plainly that "The current ESRS definitions of industry sectors do not include industry sectors that are applicable to UMG" (page 121). Total revenue for 2025 is EUR 12,507 million (EU Taxonomy turnover denominator, page 135).

Interests and views of stakeholders

Reference: pages 123-124.

UMG identifies six key stakeholder groups: artists, fans, employees, distribution partners, public officials and shareholders (pages 123-124). For each the report tabulates how UMG engages and the purpose and outcome of that engagement.

Examples of the engagement methods disclosed:

• Artists - close direct connections at every label and division through A&R, marketing and merchandising teams; indirect contact through their advisors.
• Fans - direct-to-fan communications by email, SMS and community platforms.
• Employees - written and in-person communications from the People, Inclusion & Culture team; formal and informal feedback channels; lifecycle and pulse surveys; employee forums and resource groups.
• Distribution partners - ongoing dialogue with digital and corporate business development teams; product innovation discussions and deal negotiations.
• Public officials - responses to formal information requests, advocacy meetings, trade organisation membership, office and studio tours for policymakers.
• Shareholders - Investor Relations meetings, quarterly results webcasts with Q&A, annual general meetings, press releases; "Provide updates related to our sustainability targets and progress".

"As applicable, stakeholder input is shared with our management or Board through various channels, including through our Investor Relations team, as part of our DMA process and through regular internal periodic reporting" (page 123). In the DMA, external stakeholders - artists, shareholders and distribution partners - "were consulted, by proxy, through interviews and survey questions tailored to each type of stakeholder" (page 128).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 125-126.

The IRO table covers six material topics and 24 individually typed IRO rows, each with an I(+)/I(-)/R/O marker, an actual-or-potential flag, a value chain position and a time horizon:

The single climate IRO reads: "UMG has GHG emissions which negatively impact the environment" - actual, downstream, medium term (page 125). Three of the six material topics are entity-specific, which is the defining feature of this statement.

UMG adds: "UMG did not identify any material risks or opportunities for which there is a significant risk of a material adjustment within the next annual reporting period" (page 125). Effects on business model, value chain, strategy and decision-making are cross-referred by page: E1 to pages 142-148, S1 to 149-154, artists to 154-165, IP to 157-159, privacy to 159-160, supply chain to 156-157.

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

Reference: pages 127-129.

UMG's first materiality assessment was in 2022, validated in 2023 "with subject matter experts and a cross-functional group of over 100 UMG leaders". The methodology was refreshed for the CSRD. The DMA runs in four steps (pages 127-128): (1) understand activities, value chain and business relationships; (2) identify sustainability matters from ESRS 1 AR 16 plus industry and geographical research; (3) assess impact and financial materiality with internal and external stakeholders; (4) validate material topics through working sessions with senior leadership, the SteerCo and subject matter experts, with the final list "presented to the Audit Committee for review".

No new DMA was run for 2025. "In 2025, UMG assessed whether a new DMA should be performed for the 2025 reporting period ... the Company specifically evaluated the circumstances set forth in EFRAG Implementation Guidance 1 Materiality Assessment, 5.3, FAQ 7, para. 171. The Company concluded that it was not required to complete a new DMA for the 2025 reporting period." The 2024 IROs were reviewed for completeness, accuracy and applicability, producing "select typographical and textual updates to the IROs ... These changes did not result in, and are not reflective of, any changes to the materiality of the associated reportable datapoints" (page 128).

Climate-specific process (pages 128-129): assessment of the GHG footprint under the GHG Protocol across scope 1, scope 2 location- and market-based, and scope 3 categories 1, 2, 3, 4, 5, 6, 7, 9, 12, 14 and 15; plus TCFD-aligned scenario analysis conducted in 2025.

Scope limitation stated (page 129): for pollution, water and marine resources, biodiversity and ecosystems, resource use and circular economy, and business conduct, "we did not perform additional screening of assets or activities, assessment of site locations, or conduct local engagement at site locations with respect to these topics".

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 129-130.

UMG prints a genuine ESRS content index ("The following content index indicates the Disclosure Requirements we have identified to be material as a result of our DMA process"), tabulating topical standard, material topic, ESRS code, disclosure requirement title, an "Derived from other EU legislation" marker and a page reference.

Disclosure requirements listed:

• ESRS 2 - BP-1, BP-2, GOV-1, GOV-2, GOV-3, GOV-4, GOV-5, IRO-1, IRO-2, SBM-1, SBM-2, SBM-3
• ESRS E1 (material topic: GHG emissions) - ESRS 2 IRO-1, ESRS 2 SBM-3, E1-1, E1-2, E1-3, E1-4, E1-6, E1-7, E1-8. E1-5 and E1-9 are absent.
• ESRS S1 (attraction and retention of employees; diversity, inclusion and belonging; gender equality and equal pay) - S1-1, S1-2, S1-3, S1-4, S1-5, S1-6, S1-9, S1-16
• ESRS G1 (supply chain management) - G1-2 only
• Entity-specific - attraction and retention of artists (pages 154-155), intellectual property, piracy and content protection (157-159), privacy and cybersecurity (159-160)

Two footnotes govern everything omitted. Footnote 1: "The table includes all data points that derive from other EU legislation as listed in ESRS 2 Appendix B, which are material for UMG ... Other data points which are not included in the table above, are considered not material." Footnote 2: "Except as expressly stated otherwise, UMG's material impacts on our own workforce are limited to UMG employees."

No E2, E3, E4, E5, S2, S3 or S4 disclosure requirement appears anywhere in the index.

Transition plan for climate change mitigation

Reference: page 141 ("Transition plan, policies, and key actions (E1-1, E1-2, E1-3, E1-7, E1-8)"), page 142.

UMG has no adopted transition plan. "UMG is developing a climate transition plan, which we aim to adopt by 2027" (page 141). The disclosure sets out the initial steps taken "in laying the groundwork":

• The first TCFD-aligned analysis was conducted in 2022 and "a formal update of this analysis in 2025".
• Science-based targets were set and approved by the SBTi in 2023.
• Continued meetings with ESG working groups on material scope 3 categories and supply chain engagement.
• Continued engagement with key stakeholders to evaluate activities affecting actual and potential future GHG emissions.
• "We continued our renewable energy transition analysis and developed strategies for switching more properties to renewable power."
• "We identified key actions we can take to reduce our product-related emissions, including the use of alternative materials and modes of distribution, which will inform our decarbonization strategy."

Decarbonisation levers are not yet quantified: "UMG is developing the decarbonization levers and evaluating their potential quantitative contributions to achieve our science-based targets as part of our climate transition plan. We have not set 2030 emissions reduction targets as our SBTi-approved targets were set in advance of the implementation of the CSRD" (page 142).

"UMG is not excluded from the EU Paris-aligned Benchmarks" (page 141). No CapEx alignment to the plan, no net-zero target year and no discussion of locked-in emissions appear anywhere in the statement.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate DMA subsection, where this content is disclosed in the FY2025 report (pages 128-129 and 139-140). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 139-140; also pages 128-129 and 132-133.

Physical and transition risks are classified explicitly. Table 1 (page 140) lists five climate-related risks under the categories Physical - Acute/Chronic (direct operational disruption from floods, cyclones, wildfires, heat stress, sea level rise; and supply chain disruption), Market (increased cost of transitioning to sustainable materials, including alternatives to vinyl, reground vinyl, sustainable fabrics and recycled materials), Policy & Legal (compliance with disclosure requirements and carbon pricing schemes) and Reputation. Table 2 lists three opportunities: Energy Source, Markets and Resource Efficiency.

Methodology (page 139). Time horizons: short 0-1 years (2025-2026); medium 1-5 years (2026-2030); long 5+ years (2030-2050). Each risk was scored on likelihood of occurrence, severity of impact independent of likelihood, and existing resiliency measures, then rated Low, Moderate, Significant or Major.

Scenarios used (page 139) - three IPCC scenarios, selected "to account for recommendations and requirements by the TCFD and the ESRS":

• SSP1-2.6 - sustainable development, warming kept within ~1.8 degrees C by 2100
• SSP2-4.5 - middle of the road, ~2.7 degrees C by 2100
• SSP5-8.5 - worst case, ~4.4 degrees C by 2100

A high-emission scenario is therefore used for physical risk, and a global average temperature projection is given for each scenario. No 1.5 degrees C-aligned scenario with no or limited overshoot is named for transition risk - the FY2024 report used IEA Net Zero by 2050, and no IEA scenario appears in the FY2025 statement.

Result: "The impact assessment identified only Low and Moderate-level risks. No risks resulting in Significant or Major impacts to UMG's operations were identified ... None of these climate-related risks or opportunities were determined to be material such as to be included as IROs" (page 139).

Resilience in relation to climate change

Back-filled from the E1.SBM-3 climate scenario analysis subsection, where this content is disclosed in the FY2025 report (pages 139-140). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 139-140; also page 132.

UMG presents no resilience analysis as defined by the ESRS. What it presents instead is the resilience conclusion of its 2025 TCFD-aligned scenario analysis.

Results (page 139). "Existing resiliency measures" was one of the three criteria used to score every climate risk, defined as "the current resiliency measures in place including relevant business, strategy, and financial planning". On that basis: "The impact assessment identified only Low and Moderate-level risks. No risks resulting in Significant or Major impacts to UMG's operations were identified." The EU Taxonomy section repeats the finding for the eligibility assessment: "There were no risks resulting in Significant or Major impact to UMG's operations across all scenarios and time horizons" (page 132). None of the identified climate risks or opportunities was material enough to enter the IRO table (page 139).

Uncertainty (page 139). "These scenarios are subject to inherent assumptions and uncertainties, including uncertainties regarding the ways in which these scenarios may develop." No further areas of uncertainty are identified.

Capacity to adjust or adapt. The statement gives no discussion of the flexibility of financial resources, the ability to redeploy, repurpose, upgrade or decommission assets, or the effect of planned investments on resilience over the short, medium and long term. The nearest content is the strategy narrative on the barriers to renewable energy procurement for "small, leased facilities" (page 120) and the transition plan's renewable energy and product-material workstreams (page 141).

Policies related to climate change mitigation and adaptation

Reference: page 141.

A single environmental policy, adopted in the reporting year. "In 2025, UMG adopted an environmental policy that addresses our approach to sustainability in our business, within our value chain, and across our industry."

Its stated scope (page 141): "The policy sets out our approach to minimizing UMG's negative impacts on the environment, including our commitments to managing our GHG emissions; achieving our SBTi-approved targets; engaging and collaborating with our stakeholders, including our suppliers, on our environmental efforts; working to comply with all applicable environmental laws and regulatory requirements; and working to improve and report on our environmental performance on an ongoing basis."

Accountability and availability: "The Head of Sustainability is responsible for implementation of the policy. The policy is available on our website and upon request."

Related policy instruments sit outside E1 but bear on climate: the Supplier Social Responsibility Policy, incorporated into all global manufacturing agreements, and the Environmental Exhibit, a standardised set of environmental terms and conditions being rolled into physical audio and merchandise manufacturing agreements (pages 156-157).

The disclosure does not state whether the policy addresses climate change adaptation as distinct from mitigation, nor does it identify the third-party standards or initiatives the policy respects.

Actions and resources in relation to climate change policies

Reference: page 141 (also pages 142, 156-157 for the supply chain actions cross-referred from E1).

The actions disclosed under E1 are the same bullets that serve as the groundwork for the transition plan (page 141):

• The renewable energy transition analysis was continued and "strategies for switching more properties to renewable power" were developed.
• "We identified key actions we can take to reduce our product-related emissions, including the use of alternative materials and modes of distribution, which will inform our decarbonization strategy."
• ESG working groups continued to meet "to collaborate on initiatives related to our material scope 3 categories and supply chain engagement".
• Engagement with key stakeholders "to evaluate activities that could have an impact on actual and potential future GHG emissions".

The report identifies what actually moved the numbers rather than attributing the movement to a programme: "Key drivers for decreases in our scope 1 and 2 (market-based) emissions since our base year include a decrease in standard electricity consumption, an increased share of renewable electricity, a reduction in the number of vehicles and associated fuel use, and lower refrigerant emissions" (page 142).

The supply chain leg of the climate actions is described in the G1-2 section: the Environmental Exhibit "requires our suppliers to set and validate their own science-based targets within a stated timeline", plus an annual Supplier GHG Survey collecting emissions data including emissions attributable to UMG (pages 156-157).

No financial resources are quantified against any of these actions, and no action carries a completion date or an expected emissions saving.

Targets related to climate change mitigation and adaptation

Reference: pages 141-142.

In 2023 UMG "became the first major standalone music company to announce science-based targets approved by the SBTi" (page 141). Two targets, both to 2032 from a 2019 base year:

• Absolute scope 1 and 2 GHG emissions -58% by 2032, "an ambition which is in line with a 1.5 degrees C trajectory".
• Scope 3 GHG emissions -62% per EUR value added by 2032, covering purchased goods and services, capital goods, fuel- and energy-related activities, upstream transportation and distribution, waste generated in operations, business travel and employee commuting. "Value added" is EBITDA plus all personnel costs.

Progress table (page 142):

Methodology: targets were developed on the GHG Protocol and SBTi Criteria and Recommendations Version 5.0, cover all seven Kyoto gases where relevant, and are aligned with the boundaries of the GHG inventory. "Our science-based targets were not derived using a sectoral decarbonization approach" (page 142). 2019 was chosen as "the most representative year of normal operations prior to the effects of the COVID-19 pandemic".

Two gaps are stated by the company itself: no 2030 target ("our SBTi-approved targets were set in advance of the implementation of the CSRD"), and no absolute scope 3 target - the scope 3 target is an intensity metric, so the E1-6 table carries no scope 3 milestone (page 147, footnote 5). Recalculated 2019 base year figures are outside the scope of the assurance engagement (page 142).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 142-148 (methodology 142-146, tables 147-148).

Headline figures, tCO2e (2019 recalculated base year / 2024 / 2025, page 147):

Scope 3 by category, 2025 (2024 in brackets): 1 purchased goods and services 387,574 (363,629); 2 capital goods 28,695 (32,153); 3 fuel- and energy-related 2,632 (2,789); 4 upstream transport 56,111 (73,305); 5 waste 470 (556); 6 business travel 36,184 (50,967); 7 employee commuting 6,259 (5,823); 9 downstream transport 4,548 (5,797); 12 end-of-life 7,502 (7,227); 14 franchises 2,777 (6,052); 15 investments 16,000 (14,507). Categories 8, 10, 11 and 13 are excluded as not relevant, each with a stated reason (page 145).

Intensity (page 148): total GHG per net revenue 44.7 tCO2e/EUR million location-based (2024: 48.5) and 44.5 market-based (2024: 48.3).

Scope and quality. Scope 1 and 2 reporting covers 58 countries and 189 properties, "which represents 95% of our property portfolio and all properties where there is employee headcount" (page 142). Approximately 16% of total scope 3 emissions were calculated using primary supplier data, up from 13% in 2024 (page 112). Categories 9 and 14 are "screenings" with high measurement uncertainty (page 112). Scope 1 rose because of refrigerants (546 tCO2e in 2025 against 35 in 2024) and domestic fuel oil (249 against 1), page 148.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 141.

A nil return. In the combined "Transition plan, policies, and key actions (E1-1, E1-2, E1-3, E1-7, E1-8)" subsection, UMG states in a single sentence: "UMG does not have internal carbon pricing schemes, GHG removals and storage, or GHG mitigation projects financed through carbon credits."

The same sentence adds: "UMG is not excluded from the EU Paris-aligned Benchmarks."

There is therefore no removals figure in the own operations or upstream and downstream value chain, no carbon credit purchase or retirement volume, no split by removal or reduction project, no reference to any recognised quality standard such as the Verified Carbon Standard or Gold Standard, and no claim of carbon neutrality anywhere in the statement. UMG's targets are absolute and intensity emissions reductions rather than offset-supported claims, and the report contains no net-zero or carbon-neutrality commitment for the group.

The scope 1, 2 and 3 inventory on pages 147-148 is presented gross throughout, with no offset line.

Internal carbon pricing

Reference: page 141.

A nil return, given in the same sentence as the removals disclosure: "UMG does not have internal carbon pricing schemes, GHG removals and storage, or GHG mitigation projects financed through carbon credits" (page 141).

No shadow price, internal carbon fee, implicit price or marginal abatement cost figure appears anywhere in the sustainability statement, and no carbon price is used in the climate scenario analysis. The Policy & Legal risk in Table 1 does refer to carbon pricing as an external phenomenon - "Increased operational costs or decreased efficiencies as it relates to compliance with climate-related laws and regulations (e.g., disclosure requirements, carbon pricing schemes, etc.)" - but that risk is rated Low across the short, medium and long term in every scenario and is not carried into the IRO table (pages 139-140).

Consistently with this, the EU Taxonomy CapEx analysis records that "There are no capital or operating expenditures related to a capital plan or purchase of output from Taxonomy-aligned economic activities" (page 132): UMG applies no internal price to steer capital allocation.

Policies related to own workforce

Reference: page 149 (also pages 63-64 for the D&I Policy).

Two group-level policies carry the own-workforce disclosure:

Code of Conduct, implemented by the Chief Compliance Officer and "applicable to every person conducting business for UMG, including employees, interns, officers, members of the Board, and third parties such as consultants, independent contractors, and company advisors or representatives".

Whistleblowing Policy, a standalone Board-adopted policy, also implemented by the Chief Compliance Officer, whose purpose "is to encourage all employees and other stakeholders (e.g. shareholders, suppliers, and customers) to report genuine concerns or complaints without fear of reprisal should they act in good faith".

Human rights coverage (page 149): "UMG's Code of Conduct prohibits harassment, discrimination, violence, child labor, slavery, human trafficking, and unsafe working conditions. These values are reflected across our operations and we only conduct business with partners, suppliers, and customers who share our commitment to protecting human rights." The Code "is consistent with the United Nations Guiding Principles on Business and Human Rights". It also covers workplace safety, security and health.

Anti-discrimination and inclusion: the Code "encourages an inclusive environment that promotes individual expression, creativity, innovation, and achievement and emphasizes that within UMG diverse backgrounds and skills are valued as well as individual differences in race, ethnicity, gender or gender identity, sexual orientation, disability, religious affiliation, age, experience, and thought."

Separately the Board has adopted a Diversity and Inclusion Policy under articles 2:142b and 2:166 of the Dutch Civil Code and best practice provision 2.1.5 of the Dutch Corporate Governance Code, covering the Board and senior management (pages 149, 63).

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 149-150.

Employee Listening. "UMG maintains a dedicated Employee Listening program. Employee Listening is how we pass the mic to hear thoughts and opinions on the employee experience at UMG. Our strategy consists of a series of surveys that follow the employee lifecycle to measure each employee's individual experience, and company-wide surveys to pulse where we are in meeting our objectives" (page 149).

Accountability. "The Strategy, Insights & Planning Team, within our PIC department under the oversight of our Executive Vice President, Chief People and Inclusion Officer, is responsible for our workforce surveys" (page 149).

Coverage and frequency (pages 149-150). Lifecycle Surveys - first week new hire, 90-day new hire and exit - run continuously "In the U.S., Korea, and Southeast Asia, with a planned global expansion in coming years". Globally, "we run engagement or pulse surveys on an as-needed basis to measure progress on our objectives". Labels also use the Strategy, Insights & Planning team "to gather enterprise and label-specific insights".

Employees were also "directly consult[ed] ... as part of our DMA process and ongoing employee engagement", cross-referred to IRO-1 and SBM-2 (page 150). Internal DMA stakeholders "included a broad array of UMG employees across various business units, internal roles, and geographies ... who were consulted directly through open-ended interviews" (page 128).

No workers' representatives, works council, trade union or collective agreement is mentioned in the engagement disclosure, and the lifecycle survey programme covers only part of the global workforce.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 150.

UMG describes "a global framework overseen by the Compliance and PIC departments using a multi-pronged approach and consistent with local laws: (1) training and guidance to our workforce as to their rights and obligations while working at UMG; (2) multiple channels to raise questions, needs, concerns, or allegations of impropriety; (3) a system to investigate any allegations requiring review; (4) prohibition against retaliation for raising good faith concerns; and (5) periodic assessments to ensure the processes are effective".

Channels (page 150). Direct communication with a supervisor or department leadership; the PIC department; legal counsel, the General Counsel or the Chief Compliance Officer; and the Global Compliance and Ethics hotline, "supported by a third-party provider", which "permits employees to raise concerns 24 hours a day, seven days a week via telephone or the internet. Additionally, such concerns may be made anonymously where permitted by local law."

Handling. "Pursuant to our Code of Conduct, all reports of misconduct must be investigated promptly, thoroughly, and objectively", with the choice of internal or external resources and forensic expertise decided case by case. Complaints reach "select executives in the region where the report originated, the Ethics Committee or the Board" on a need-to-know basis. Where misconduct is found, "UMG administers appropriate discipline to those involved, consistent with local laws". The Whistleblowing Policy "prohibits retaliation against anyone who reports a concern in good faith".

Awareness measures: annual global issuance of the Code and Whistleblowing Policy with acknowledgement confirmed by each employee; reporting methods included in all global training courses; hotline information emailed to all employees; and workforce surveys covering "knowledge of the reporting channels and likelihood of use of the channels" (page 150).

Taking action on material impacts on own workforce

Reference: pages 150-151 (cross-referred to page 65 of the Board report).

The stated rationale: "Cultivating work environments that are welcoming, inclusive, free of discrimination, and that promote a diversity of perspectives and backgrounds can increase our resilience as a company as well as the creativity behind our products and services" (page 150).

Employee Resource Groups (page 151) - open to all employees: BLACK LABEL, CULTURA (Latinx and Hispanic), PRISM (LGBTQ+), UTOPIAA (Asian American and Pacific Islander), WOMEN'S NETWORK and JEWISH HERITAGE.

Talent and development (page 151). Internship programmes "across a variety of institutions"; the "The 6" series of development programmes covering team development, cross-functional collaboration, communication and productivity; in 2025 training was delivered to cohorts of team members, people managers, director-level leaders and senior-level leaders. A global job architecture project, launched in 2023, standardises career levelling and remuneration, "addressing concerns related to compensation disparities, and supporting retention".

Pay practices. UMG "supports equitable pay practices by conducting pay equity studies, and through the implementation of our global job architecture, in which individual pay reflects experience, skillset, performance against goals, and scope of responsibilities, but does not differentiate on the basis of protected characteristics" (page 151).

Benefits. In the United States, medical plans "provide unlimited access to mental health services at no cost when using in-network providers", include comprehensive family programmes and women's health benefits, 12 weeks of paid family leave to care for loved ones, and cover travel for fertility-related medical care (page 151).

No resources or spend are quantified against any of these actions, and no effectiveness measure is reported.

Targets related to own workforce

Reference: page 151; targets themselves at pages 63-65; page 152 for the pay metrics.

UMG's own-workforce targets are the gender diversity aspirations in the Board-adopted D&I Policy, incorporated by reference: "As enshrined in our D&I policy, we are committed to improving the gender diversity among our senior managers and to promoting diversity and inclusion in the boardroom. Our specific aspirations pertaining to these commitments, which were developed with input from our senior management and unanimously approved by our Board, are discussed in further detail in the Corporate Governance section of the Board report" (page 151).

The aspirations (page 64):

• Non-Executive Directors - at least one third female and at least one third male.
• Executive Directors - at least one female and at least one male where there are three or more.
• Senior management - "by December 31, 2026, at least 20% of the senior managers is female, which would reflect a 2.5% increase compared to December 31, 2023", and at least 20% male.

Performance (page 65). The senior management aspiration "was reached one year ahead of schedule": women were 21.9% of the 73 senior managers at 31 December 2025, against 18.8% in 2024 and 17.5% in 2023. The Board aspiration is met for Non-Executive Directors (56% female) but "with women representing 0%, of the Executive Directors, the composition of the Executive Directors as at December 31, 2025 was not in line with the Company's gender diversity aspiration". New aspirations "will be considered and, where necessary, set in the course of 2026".

No other own-workforce target exists. On the remuneration metrics UMG states: "As we are early in our journey of collecting and analyzing this information, we have not developed targets relating to pay gap or the annual total remuneration ratio" (page 152). There is no target for turnover, training, health and safety or engagement.

Characteristics of the undertaking's employees

Reference: pages 151-154.

Total employees at 31 December 2025: 10,595 (2024: 10,346), headcount basis, covering all UMG employees from the global human resource platform (pages 151-153).

Countries are reported "for countries in which UMG has 50 or more employees representing at least 10% of our total number of employees" per S1-6 50(a) (page 153); only the United States and the United Kingdom clear that threshold. Contract type is further broken down by gender (page 153): permanent 5,052 female / 4,697 male; temporary 514 female / 264 male.

Turnover (page 154): all employees 16% in 2025 against 22% in 2024; permanent employees 12% (17%); voluntary 7% (9%). "The total number of departures declined from 2,265 in 2024 to 1,702 in 2025." UMG notes that "Of the above indicators, only turnover of all employees is required by the ESRS."

Definitions: an employee is "an individual who (i) works for UMG and (ii) is in a contractual relationship with UMG"; gender is self-reported, with "prefer not to disclose" shown as other and no selection as not reported (pages 151-152). No breakdown of employees by full-time/part-time is given.

Diversity metrics

Reference: page 154 (age); pages 64-65 and 116 (gender at top management, incorporated by reference).

Age distribution, headcount (page 154):

Gender at top management. The S1-9 datapoint "The undertaking shall disclose the gender distribution in number and percentage at top management level" is incorporated by reference to "Corporate Governance, The Board, Diversity and Inclusion - The senior management" (page 116). That table (page 65) reports 73 senior managers at 31 December 2025: 16 female (21.9%) and 57 male (78.1%), against 18.8% female in 2024 and 17.5% in 2023.

"Top management" is defined for this purpose as "(i) the executive directors of the Board, including the Chairman and CEO, (ii) the Chairman and CEO's direct reports who lead a label or business or with a primary function, (iii) for other key labels or businesses, their leaders and in some instances, certain of their direct reports, and (iv) key large function leaders" (page 152).

The metric is limited to gender and age. No diversity metric is reported for ethnicity, nationality or any other characteristic, despite the D&I Policy naming those dimensions (page 64).

Compensation metrics (pay gap and total compensation)

Reference: page 154; methodology pages 151-152.

Both required ratios are disclosed, and both moved the wrong way (page 154):

UMG's explanation: "In any given year, executives may receive non-standard compensation changes, including changes relating to LTIP maturity payments or other non-recurring payments, resulting in a high degree of variance of these metrics from year to year" (page 154).

Method (page 152). The pay gap is "(Average gross hourly pay level of male employees - average gross hourly pay of female employees) / Average gross hourly pay level of male employees) x 100". The remuneration ratio is "Annual total remuneration of the highest paid individual / Median employee annual total remuneration (excluding the highest paid individual)". Both draw on the global HR platform and local payroll systems, and include base salary, benefits in cash (allowances, bonuses, commissions, cash profit-sharing and other variable cash) and direct remuneration (benefits in cash plus the total fair value of all annual long-term incentives).

A permitted omission is claimed: "The Company's calculation of the annual total remuneration ratio is exclusive of certain component information, in accordance with ESRS 1, section 7.7 as well as the CSRD's permitted omissions of information (CSRD, Article 19a and Article 29a)" (pages 152, 154). The components withheld are not identified.

No target exists for either metric (page 152).

Management of relationships with suppliers

Reference: pages 156-157.

Supply chain management is UMG's only material ESRS G1 topic. "Supplier relationships are managed by business units within UMG. UML manages suppliers for physical audio products - which range from vinyl to CDs and DVDs - and Bravado manages suppliers of merchandise" (page 156).

Supplier Social Responsibility Policy. "Overseen by our Chief Compliance Officer and SVP, Head of Sustainability", it "is incorporated into all global manufacturing agreements and sets out specific principles that we expect every supplier to follow across environmental, social, and ethical impact areas". It is "anchored by internationally recognized frameworks, including the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the UNESCO Convention on the Protection and Promotion of the Diversity of Cultural Expressions, the Children's Rights and Business Principles established by UNICEF, the UN Global Compact, and Save the Children principles", and establishes "a pathway for suppliers to implement corrective action when performance falls below provided criteria" (page 156).

Audits. "Bravado requires certain direct suppliers in the US and UK, based on spend and risk, to undergo the Sedex SMETA 2 Pillar Audit (or equivalent) ... In 2025, Bravado rolled out more comprehensive requirements, the SMETA 4-Pillar Audit, which includes additional environment and business ethics considerations. Subject suppliers are required to upgrade from 2-pillar to 4-pillar audits upon renewal" (page 156). No audit count or non-conformance figure is given.

Environmental Exhibit. Standardised environmental terms integrated into US and UK physical audio and merchandise manufacturing agreements from 2024, with rollout continuing in 2025. It "requires our suppliers to set and validate their own science-based targets within a stated timeline" and to submit two annual surveys - the Supplier GHG Survey and the Supplier Sustainability Survey - whose results feed "an annual supplier benchmarking report" (pages 156-157). Bravado additionally evaluates Tier 1 suppliers quarterly on product, pricing and delivery.

No payment practices data is disclosed (G1-6 is not in the index).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Reference: pages 156-157 (also 159, 160).

UMG discloses no business conduct target, and says so in terms: "In 2025, our efforts continued to center on gathering information from and generating awareness among our suppliers. With this as our focus, we have not set specific targets for this topic. We believe that targets can serve as a useful tool to continue our efforts and may adopt them in future years to help us continue to drive progress" (page 157).

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of a target:

• "To track the effectiveness of our suppliers' alignment with the Supplier Social Responsibility Policy, UMG embeds controls and measures across various stages of the procurement lifecycle" (page 156), including the Sedex SMETA 2-Pillar and, from 2025, 4-Pillar audits.
• Two mandatory annual supplier surveys under the Environmental Exhibit feed "an annual supplier benchmarking report. Based on report findings, we share additional tools and resources with suppliers, as needed" (page 157).
• The Environmental Exhibit "requires our suppliers to set and validate their own science-based targets within a stated timeline" - a target imposed on suppliers rather than on UMG, and the timeline is not stated.
• Bravado evaluates Tier 1 suppliers quarterly on product, pricing and delivery criteria (page 157).

The same "no targets" position is taken for the two entity-specific governance topics: "Content protection is part of our business-as-usual approach and ongoing daily operations. As such, UMG does not have time-bound targets with respect to this topic" (page 159), and the identical formulation for cybersecurity (page 160).