Veolia

The role of the administrative, management and supervisory bodies

Board composition and structure

As of December 31, 2024, Veolia's Board of Directors consisted of:

• Total members: 14 Directors and 1 non-voting member (censeur)
• Executive vs non-executive: 2 executive members (Antoine Frérot, Chairman; Estelle Brachlianoff, Chief Executive Officer) and 12 non-executive members
• Independence rate: 64% (7 independent directors out of 11, excluding Directors representing employees and Director representing employee shareholders)
• Gender split: 54.5% female Directors (excluding Directors representing employees and Director representing employee shareholders, in accordance with Articles L. 225-27 and L. 22-10-7 of the French Commercial Code)
• Average age: 62 years
• Non-French Directors: 5 (36% of total)
• Average length of service: 6 years
• Average attendance rate: 96%
• Directors representing employees: 2 (Franck Le Roux, Pavel Páša)
• Director representing employee shareholders: 1 (Agata Mazurek-Bąk)

Meeting frequency: The Board met 10 times in 2024, with an average duration of approximately two hours and forty minutes per meeting. Electronic communication means were used eight times.

Term of office: Four-year term for directors, with renewal of one quarter of Board members, in accordance with Article 11 of the Company's Articles of Association and the AFEP-MEDEF Code.

Board skills matrix

Number of directors having specific expertise areas:

Board committees with sustainability oversight

The Board operates through five specialized committees:

1. Purpose Committee

• Members: 7
• Independence rate: 80%
• Attendance rate: 100%
• Chairman: Antoine Frérot (Chairman of the Board of Directors)
• Members: Pierre-André de Chalendar, Olivier Andriès, Maryse Aulagnon, Isabelle Courville, Franck Le Roux, Guillaume Texier

Mission: The Purpose Committee monitors progress achieved by the Group and directs choices relating to the Purpose and multifaceted performance. It is supported by the Board of Directors which controls the proper implementation of the GreenUp strategic program.

2. Research, Innovation and Sustainable Development Committee

• Members: 5
• Independence rate: 50%
• Attendance rate: 100%
• Chairwoman: Isabelle Courville
• Members: Olivier Andriès, Marion Guillou, Julia Marton-Lefèvre, Pavel Páša, Guillaume Texier
• Permanent guest: Enric Xavier Amiguet i Rovira (non-voting member)

3. Accounts and Audit Committee

• Members: 5
• Independence rate: 100%
• Attendance rate: 95%
• Chairman: Guillaume Texier
• Members: Olivier Andriès, Véronique Bédague, Franck Le Roux, Agata Mazurek-Bąk

Sustainability responsibilities: The Accounts and Audit Committee monitors the efficiency of the Company's risk management and internal control systems, in accordance with Article L.823-19 of the French Commercial Code.

4. Nominations Committee

• Members: 4
• Independence rate: 50%
• Attendance rate: 100%
• Chairman: Pierre-André de Chalendar
• Members: Antoine Frérot, Maryse Aulagnon, Isabelle Courville

5. Compensation Committee

• Members: 6
• Independence rate: 60%
• Attendance rate: 79%
• Chairman: Olivier Andriès
• Members: Pierre-André de Chalendar, Maryse Aulagnon, Marion Guillou, Franck Le Roux, Francisco Reynés

Frequency of sustainability discussions at board level

In 2024, the Board of Directors examined sustainability-related matters including:

• Review of the risk mapping and the materiality matrix of CSR issues
• Review of the Group's non-financial ratings and the extent of roll-out of its sustainable development commitments
• Implementation of the new EU Corporate Sustainability Reporting Directive (CSRD)
• Follow-up on the GreenUp 2024-2027 strategic program
• Examination of metrics monitoring the implementation of Veolia's Purpose (multifaceted performance indicators)
• Review of summaries and reports issued by the Research, Innovation and Sustainable Development Committee

The Board also held a two-day seminar on December 12-13, 2024 dedicated to the Group's strategy, focusing on the GreenUp 2024-2027 program.

Specific roles assigned

Chief Executive Officer: Estelle Brachlianoff has been Chief Executive Officer since July 1, 2022, responsible for implementing the Group's strategic direction and ensuring the roll-out of risk management and internal control systems.

Chairman of the Board of Directors: Antoine Frérot became Chairman of the Board of Directors on July 1, 2022, following the separation of duties of Chairman and Chief Executive Officer.

Senior Independent Director: Pierre-André de Chalendar holds the position of Senior Independent Director.

Purpose Committee sponsorship: The implementation of Veolia's Purpose and multifaceted performance commitments is supported by "a two-person team comprising an Executive Committee sponsor and a Group 'Objective Officer', responsible for steering each multifaceted performance objective."

Purpose Officers network: A network of Purpose Officers in the Business Units supports managers and accelerates the roll-out of Veolia's Purpose and multifaceted performance in their entities.

Governance arrangements and independence

Governance Code: The Company follows the AFEP-MEDEF Corporate Governance Code of listed corporations. In fiscal year 2024, no recommendations of this Code were disregarded (full "comply or explain" compliance).

Independence criteria: The Board applies eight independence criteria from the AFEP-MEDEF Code, covering:

1. Employee or Executive Officer status (previous five years)
2. Cross directorships
3. Significant business relationships
4. Family ties
5. Statutory Auditor status
6. Directorship of more than 12 years
7. Status of non-executive corporate officer
8. Status of major shareholder

Independence assessment: The Board of Directors' Meeting of March 11, 2025 carried out its annual review of the independence of directors after hearing the opinion of the Nominations Committee. The Board "strictly applies the independence criteria set out in the AFEP-MEDEF Code and particularly the criterion concerning the length of time a director has been on the Board of Directors."

Conflicts of interest: "To the best of the Company's knowledge, no member of the Board of Directors has an actual or potential conflict of interest with Veolia Environnement." Directors must inform the Board of any existing or potential conflicts of interest and abstain from voting in any situation where such a conflict exists.

Diversity policy: The Board strives to diversify profiles based on criteria including:

• Management skills acquired in major French and non-French international corporations
• Familiarity with the Group and its industry
• Professional experience
• Financial and accounting expertise
• CSR, R&D and digital skills
• Sufficient availability
• Specific expertise identified during annual Board assessment

Training and integration

New director training: The Company organizes training for new directors on the specific aspects of the Group's businesses, including site visits and meetings with the Group's key executive officers.

Director training programs: Internal and external training programs are provided, including:

• Training program designed by the French Institute of Directors (IFA) and Sciences Po leading to a Corporate Director's Certificate (provided to Directors representing employees in 2014-2015 and 2019, and to the Director representing employee shareholders in 2022)
• Annual visits to operating sites with exchanges with Group operating teams (in Czech Republic, United Kingdom, China, Hungary, United States, Spain and Chile)
• Regular agenda items at Board meetings presenting detailed analysis of Group businesses and CSR issues
• A three-year sustainable development training program for directors entitled "The sustainable company" created in June 2023

Board effectiveness and evaluation

Annual assessment: The Board conducts an annual assessment of its organization and activities, and those of its committees. This assessment is used to identify needs for Board renewal, including "internationalization of the Board of Directors, knowledge of Veolia's businesses and the global sustainable development ecosystem including climate issues."

Share ownership requirement: Excluding Directors representing employees and the Director representing employee shareholders, each director must hold at least 750 registered shares in the Company.

Remuneration alignment: A bonus policy aligned with objectives applies to 16,000 Group managers, incorporating multifaceted performance indicators.

Powers and responsibilities

Board powers: In accordance with law, the Board of Directors:

• Establishes policies concerning the Company's business and supervises their implementation
• Has authority to consider all matters concerning the proper operation of the Company within the limits of the corporate purpose
• Approves certain major decisions of the Chief Executive Officer (internal limits on powers)

Executive Management organization: Separation of the functions of Chairman of the Board of Directors and Chief Executive Officer has been in place since July 1, 2022. The Board regularly assesses and monitors this governance structure.

Risk management governance: The Board, assisted by the Accounts and Audit Committee, ensures that structures and processes are in place to provide reasonable assurance that the Group's objectives will be attained and risks controlled. The Executive Committee supervises the overall risk management system.

Performance indicators linked to sustainability

The Board monitors the Group's multifaceted performance through 15 metrics covering:

• Environmental objectives (e.g., GHG emissions reduction, freshwater saved, decarbonization investments)
• Social objectives (e.g., lost time injury frequency rate, employee engagement, diversity)
• Economic objectives (financial performance indicators)

These metrics are integrated into the remuneration of at least 16,000 Group managers to unite employees around Veolia's Purpose and multifaceted performance ambition.

Integration of sustainability-related performance in incentive schemes

This section meets Disclosure Requirement GOV-3 of ESRS 2.

Overview

Two incentive schemes are in place:

1. Annual variable compensation mechanism – applies to the Executive Resourcers, with extension to all managerial staff recommended. A description of how this scheme works is provided in the bonus policy, which is updated annually.

2. Long-term incentive scheme – takes the form of a performance share plan which, for 2024, benefited 550 Group managers and executives. A description of how this scheme works is provided each year in the rules of the plan set up. The performance shares awarded are subject to performance conditions that apply over three years and to the condition that the beneficiaries are employed during that same period.

Integration of sustainability criteria

Each of these two schemes incorporates sustainability criteria, selected from among the multifaceted performance objectives set in the GreenUp plan (see section 4.1.1.5.1). These objectives, together with the measurement metrics, are thus integrated into the remuneration policies:

Annual variable component (Short-term incentive)

Weighting: Sustainability targets (non-financial quantitative targets) represent 30% of all criteria.

Of these 30%:

• A criterion associated with the "Health, safety and well-being" multifaceted performance objective is mandatory and may represent up to 10% of all criteria.
• The remainder is divided between 2 and 5 criteria chosen from among the other multifaceted performance objectives (the objectives selected and their weighting are adapted to the business line and the challenges of the executive concerned).

Roles covered: Executive Resourcers, with recommended extension to all managerial staff.

Long-term incentive (LTI)

Weighting: Sustainability targets (non-financial quantitative targets) represent 50% of all performance conditions.

Performance period: Three years

KPIs for 2024 plan:

• Diversity and inclusion: 10% of performance shares granted
• Support to local communities: 5%
• Saved freshwater and resource regeneration: 10%
• Customer and consumer satisfaction: 5%
• Decarbonization of our customers: 10%
• Reduction of GHG emissions: 10%

Roles covered: 550 Group managers and executives in 2024.

Governance and validation

With regard to the Chief Executive Officer, who benefits from these schemes, the remuneration policy is approved by the Board of Directors and submitted to the shareholders' vote at the General Meeting.

The Compensation Committee makes proposals to the Board on the overall pay of executive corporate officers and on the terms and conditions of the performance shares grant plan. As such, it relies in particular on the Group's multifaceted performance to define quantitative financial and non-financial sustainability criteria.

Strategy, business model and value chain

Veolia is a world leader in environmental services and offers a complete range of solutions for managing Water, Waste and Energy on five continents. In 2024, the Group operated in 56 countries, generated revenue of €44,692 million and employed 215,041 people.

Business Model

Veolia's organization is divided into seven geographic zones (France and Special Waste Europe, Central and Eastern Europe, North America, Asia Pacific, Iberia and Latin America, North America, Italy-Africa-Middle East) and an additional worldwide zone (Water technologies).

The Group operates in two key markets:

• Municipal market (44% of client base): Essential services for cities and communities
• Industrial market (56% of client base): Services for companies and service sector

Value Chain and Business Lines

Water Management (40.3% of revenue, €18,033 million)

• 111 million people supplied with drinking water
• 98 million people connected to sanitation systems
• 3,879 drinking water production plants managed
• 3,198 wastewater treatment plants managed

Water value chain activities:

• Sustainable management of water resources from abstraction to discharge
• Collection and transport of water
• Water treatment for drinking water, industrial process water, and wastewater
• Customer service through multichannel management tools
• Water treatment equipment and technologies (over 550 proprietary technologies)

Waste Management (35.0% of revenue, €15,662 million)

• 43 million people provided with collection services
• 65 million metric tons of treated waste
• 861 waste processing facilities operated
• 572,834 business customers

Waste value chain activities:

• Waste collection across all categories (household, industrial, hazardous)
• Recycling and material recovery with focus on circular economy
• Recovery of organic waste through composting and anaerobic digestion
• Waste-to-energy recovery producing steam and electricity
• Treatment of hazardous liquid waste and decontamination
• Urban and industrial cleaning services

Energy Management (24.6% of revenue, €10,997 million)

• 42 million MWh produced
• 49,037 thermal installations managed
• 604 heating and cooling networks managed
• Over 2,043 industrial sites managed

Energy value chain activities:

• Heating and cooling networks as European leader
• Bioenergy and flexibility solutions for local energy production
• Energy services for buildings and industry to reduce consumption and CO2 emissions
• Multi-business integrated offerings for industrial customers

Strategic Direction: GreenUp 2024-2027

Veolia's strategic program focuses on ecological transformation through solutions that decarbonize, depollute and regenerate resources. The strategy combines:

Three Strongholds (70% of activity):

• Municipal water
• Solid waste
• District heating

Three Growth Boosters (30% of revenue, 70% of growth):

• Water technologies and new solutions
• Hazardous waste treatment
• Bioenergy, flexibility and energy efficiency

Key Strategic Commitments for 2027:

• 30% increase in erased CO2 emissions (scope 4)
• 1.5 billion m³ freshwater saved
• 9 million metric tons of hazardous waste and pollutants treated
• Revenue growth in priority segments
• EBITDA ≥ €8 billion
• Net income growth of ~10% per year (2023-2027)

Geographic Presence and Value Creation

Revenue by geography:

• France and Special Waste Europe: 20.5%
• Europe excluding France: 41.7%
• Rest of the world: 37.8%

The Group's global presence enables replication of proven solutions across 56 countries while maintaining strong local relationships with municipalities and industrial customers.

Interests and views of stakeholders

Identified key stakeholder groups

Veolia has identified five key stakeholder categories:

• Customers
• Planet
• Employees
• Society
• Shareholders

These stakeholder groups are referenced throughout the document in various risk management and operational contexts. The Board of Directors and its committees engage with these stakeholders as part of governance processes.

Stakeholder engagement channels and frequency

Veolia has strengthened its listening system for stakeholders through different channels:

Critical Friends Committee

A group made up of representatives of civil society from the associative, institutional, academic or corporate worlds, specialists in environmental, social or governance issues, whose complementary experiences provide valuable insights from the perspective of stakeholders. Discussions are held regularly on important topics with this committee.

Employees

Contribute through:

• Annual "Voice of Resourcers" surveys: main theme is employee engagement
• "Inspire 24-27" collaborative approach: devoted during its upstream phase to the co-construction of the draft strategic program 2024-2027
• Staff representation bodies: informed in 2024 within the Group's central structures (Group French Work Council, Group European Work Council, holding company Work Council). Information and consultation will occur in 2025 according to procedures defined within each of these bodies, on sustainability information from the time of its publication, focusing on integration in the context of information/consultation on strategic priorities.

Collective "+1"

Consisting of voluntary partners representing the views of the five types of stakeholders, with a diverse collective experience to share in order to get to know each other better and collaborate to imagine a common path toward ecological transformation. This collective, driven by an innovative methodology for dialogue, aims to broaden the Group's capacity to listen and exchange with stakeholders close to its geographical areas and the regions in which the Group operates.

Financial players

Specific analyses to gather expectations for ESG publications from:

• Investors, funds, banks
• Rating agencies

Analysis of main controversies

Carefully monitored and managed controversies involving Veolia.

Integration into strategy and business model

The feedback collected from stakeholders was taken into account both in:

• The development of GreenUp strategic program 2024-2027
• The CSRD's double materiality analysis process

The Board of Directors receives information on stakeholder views through various committees:

• Purpose Committee (created in 2021)
• Ethics Committee
• Accounts and Audit Committee
• Research, Innovation and Sustainable Development Committee

External stakeholders contribute through:

• Critical Friends Committee
• Terra Academia and the "+1" collective
• Prospects, customers, economic partners, suppliers, public institutions, non-financial rating agencies and investors, NGOs and local opinion leaders, local communities, academic experts

Key concerns and views raised during the reporting period

Stakeholders were consulted upstream to develop the Group's social performance objectives. In 2024, specific themes were addressed:

• Discussions on important topics with Critical Friends Committee
• Biodiversity discussions: the topic was discussed with the Critical Friends Committee in 2024, addressing the contractual model for water services
• Stakeholder engagement in the Purpose Committee

The link of material IROs with the main stakeholders involved is mentioned in the topical standards.

Affected stakeholders vs users of sustainability information

Veolia distinguishes between:

Affected stakeholders (those impacted by the business):

• Residents: live close to sites operated by Veolia (water treatment or sanitation plants, incinerators, energy installations, etc.). Represented in local associations and residents' groups, and at public authority level through local and regional elected representatives. Dialogue organized within the contractual framework.

• Local communities: include residents of the region, schools and universities, and the general public who frequent the region. Represented in local associations, residents' groups, and at public authority level through local and regional elected representatives.

• Local undertakings: representatives of the region's economic ecosystem directly concerned by the economic impact of Veolia's activities.

• Vulnerable populations: characterized by economic uncertainty, limited resources, and chronic financial instability.

• Indigenous peoples: in Australia, represented by local or national associations. Dialogue organized within the framework of Veolia Australia's Reconciliation Action Plan.

Users of sustainability information:

• Investors: through the Recognition of the positive impact of their investment on nature
• Financial players (investors, funds, banks): specific analyses conducted to gather expectations for ESG publications
• Non-financial rating agencies: analysis of expectations for ESG publications

Local community engagement approach

Veolia structured its stakeholder relations approach under the banner "Resourcing together", which focuses on three areas:

• Listening and exchanging
• Co-construction and seeking solutions
• Commitment and sincerity with regard to the impacts created

An in-house methodology guide "Understanding, talking and acting with local stakeholders" enables each Group entity to embrace this commitment to dialogue and cooperation with its stakeholders, proposing methodological tools and case studies.

Whistleblowing system

Local communities can benefit from the multilingual whistleblowing system, set up at the Group level, open to third parties and making it possible to ensure the reporting of situations that fall under the duty of care. Whistleblowers have the opportunity to remain anonymous if they wish.

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

List of material IROs (impacts, risks and opportunities)

Veolia conducted a double materiality study in compliance with CSRD principles, identifying 41 material IROs for 2024. The process integrated internal sources (existing impact assessments, risk analyses, expert work) and external sources (stakeholder contributions, industry studies, international standards, main controversies).

The materiality assessment used a scale from 1 (minimum) to 5 (maximum) based on:

• Positive impacts: scale, probability over next five years, geographical extent, anticipation of strengthening beyond five years
• Negative impacts: same criteria plus remediation assessment
• Financial risks and opportunities: financial impact on net income (five-level scale) and probability within and beyond five years

The materiality threshold was set at 3. IROs were reviewed with internal contacts and external CSRD experts, with verification that no potentially material IROs were excluded.

Full list of material IROs by theme

The 41 material IROs are organized around six strategic themes:

1. Decarbonization to limit climate change

2. Depollution and nature preservation

3. Resource sparing use and regeneration

4. Safe and resilient essential services for territories

5. Stakeholders engagement in ecological transformation

6. Attractiveness, safety, and fairness of the company

Entity-specific topics

Some IROs correspond to disclosures outside those predefined in the CSRD. These are recognizable by the letters "ES" (for "entity specific") in their code, while standard IROs contain "ST". This reflects the nature of Veolia's activities as an environmental services undertaking.

Interaction with strategy and business model

The identification of material IROs was fully consistent with:

• The GreenUp strategic program (2024-2027) and its 15 priority multifaceted performance objectives
• The risk mapping approach
• Translation in financial statements (provisions, impairment, etc.)

Veolia does not expect any significant adjustments to its financial statements in relation to material IROs.

Value chain involvement: The majority of material IROs involve Veolia's value chain:

• Upstream: suppliers, subcontractors, regulatory authorities, administrative authorities
• Operations: modification of production tools, operational processes
• Downstream: provision of less carbon-intensive products and services, customer decarbonization support

Business model connections: Each IRO is explicitly linked to one or more aspects of Veolia's business model:

• Environmental performance (e.g., pollution reduction, resource conservation)
• Commercial performance (e.g., contract renewals, market differentiation)
• Financial performance (e.g., OpEx reduction, margins)
• Social/societal performance (e.g., local employment, essential services)

Linkage to GreenUp strategic program

The material IROs directly support GreenUp's three operational pillars:

1. Decarbonization: IROs E1-ST-1 through E1-ES-7 align with targets to reduce scopes 1 and 2 emissions by 18% vs. 2021 by 2027, and increase erased emissions for the value chain

2. Depollution: IROs E2-ES-2, E2-ST-1, E2-ES-3 support development of hazardous waste treatment capacity and emerging pollutant treatment

3. Regeneration: IROs E3-ES-2, E3-ES-3, E5-ES-2 align with the target of ≥1.5 billion m³ of saved freshwater by 2027

The GreenUp program identifies "boosters" (strategic activities for accelerated growth) that directly correspond to material financial opportunities:

• Water technologies and solutions (E3-ES-2, E3-ES-3)
• Hazardous waste treatment (E2-ES-3, E5-ST-3)
• Bioenergy and decarbonization solutions (E1-ES-6, E1-ES-7)

These boosters already account for 30% of revenue and will generate 70% of growth.

Resilience analysis

Veolia's resilience to identified IROs is built on:

Diversification:

• Geographic diversification across all major regions (44,308 employees in France, 84,483 in Europe excl. France, 13,939 in North America, 25,608 in Latin America, 14,149 in Africa/Middle East, 32,554 in Asia-Oceania)
• Business model diversification (municipal, industrial, service sectors)
• Contractual model diversification to reduce exposure to political and regulatory instability

Climate change adaptation:

• Physical risk assessments conducted on priority sites (more than 20 on-site studies since 2022, including 10 in 2024)
• Crisis management and continuity plans for essential services
• Local adaptation plans (e.g., Chile: US$300 million climate adaptation investment plan; Spain: multi-risk assessment and warning system)

Transition plan credibility:

• SBTi approval in July 2024 of short-term emissions reduction targets (-50% for scopes 1 and 2, -30% for at least 67% of scope 3 by 2032 vs. 2021)
• Net Zero by 2050 commitment recorded by SBTi
• Moody's Net Zero Assessment (NZA) NZ2 score
• €1.6 billion accumulated by 2030 for coal phase-out plan
• €85 million by 2027 for landfill methane capture plan

Operational excellence:

• Environmental & Industrial Management System (EIMS) deployed across operations
• Global network of experts and business communities
• Business Support and Performance Department providing Group-wide expertise
• Continuous monitoring via Global Report system

Financial resilience:

• Revenue of €44.692 billion in 2024
• Investment capacity demonstrated through GreenUp CapEx commitments
• Diversified revenue streams across water, waste, and energy sectors

Time horizons

Veolia considered the five-year time-frame as predictable with good assurance, corresponding to:

• Short-term: within GreenUp 2024-2027 plan
• Medium-term: 2027-2032 (SBTi intermediate milestone)
• Long-term: beyond 2032, up to Net Zero 2050 commitment

Specific time horizons for each IRO are defined based on:

• GreenUp strategic program objectives (to 2027)
• Climate commitments (carbon neutrality by 2050)
• Contract durations and infrastructure lifetimes
• Regulatory evolution timelines
• Market transformation speed

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

Overview

The double materiality study was conducted in compliance with the principles defined by the CSRD by an internal team having a thorough knowledge of Veolia available, in terms of:

• diversity of activities;
• risk factors;
• environmental, social, societal and governance issues;
• financial aspects;
• views of different types of stakeholders.

The methodological support was provided by an external firm.

Because of its activities and contracts, Veolia considered the five-year time-frame – corresponding to the short and medium terms according to the definition of the CSRD – to be predictable with a good level of assurance.

Inputs to the assessment

The identification and assessment of impacts, risks and opportunities was based on:

Internal sources:

• existing impact assessments and risk analyses,
• work by experts in the various businesses and CSR aspects;

External sources:

• contributions from stakeholders mentioned in section 4.1.1.6 above,
• industry studies and references, international standards and benchmarks,
• main controversies involving Veolia.

Integration with risk management

Veolia's Risk Department has for many years deployed a process of reviewing all events that could prevent the Group from meeting its commitments. As part of the CSRD deployment, this process has been identified as one of the key processes for identifying material IRO:

• the risk universe managed by Veolia, which is broader than the areas covered by the sustainability statement, clearly encompasses all the topics to be addressed in this report;
• the double materiality study was conducted by integrating the results of the last annual risk assessment campaign. The same will apply to the annual updates that will be made thereafter.

Step-by-step methodology

The identification of the material IRO has been conducted as follows:

1. Establishment of a list of the main issues for Veolia regarding ESG aspects by integrating both internal aspects and the perspective of stakeholders;

2. Identification of corresponding IRO for each of these issues, concerning Veolia and its value chain:

   • positive or negative external impacts,
   • financial risks or financial opportunities from external sources affecting Veolia

3. Materiality assessment of each of these IRO on a scale from 1 (minimum score) to 5 (maximum score), based on the following criteria:

   • positive impacts: scale, and probability over the next five years, geographical extent, anticipation or otherwise of a strengthening of the scale beyond the five-year time-frame.
   • negative impacts: same criteria as positive impacts, plus an assessment of remediation,
   • financial risks and opportunities: financial impact on the Group's net income (loss) according to a five orders of magnitude scale and probability of occurrence within and beyond a five-year time-frame respectively;

4. Verification of the consistency of the list of IRO with the themes and the 15 priority objectives of GreenUp multifaceted performance;

5. Verification of the consistency of the identification and evaluation result described above, in relation to a materiality threshold set at three:

   • review of the list of material IRO with an extended circle of internal contacts,
   • review of the IRO' labelling in terms of impacts, risks or opportunities

Scoring criteria

Impact materiality:

• Positive impacts: scale, probability over the next five years, geographical extent, anticipation or otherwise of a strengthening of the scale beyond the five-year time-frame
• Negative impacts: scale, probability over the next five years, geographical extent, anticipation or otherwise of a strengthening of the scale beyond the five-year time-frame, plus assessment of remediation

Financial materiality:

• Financial impact on the Group's net income (loss) according to a five orders of magnitude scale
• Probability of occurrence within and beyond a five-year time-frame respectively

Scoring scale: 1 (minimum score) to 5 (maximum score)

Threshold for materiality

Materiality threshold set at three.

Stakeholder engagement

Veolia has identified five key stakeholder categories:

• customers;
• planet;
• employees;
• society;
• shareholders.

Their point of view has been integrated into the process through different channels:

• Critical Friends Committee: A group made up of representatives of civil society from the associative, institutional, academic or corporate worlds, specialists in environmental, social or governance issues;
• Veolia employees who contribute through:
  • Annual "Voice of Resourcers" surveys, whose main theme is employees engagement
  • the collaborative approach "Inspire 24-27", devoted during its upstream phase to the co-construction of the draft strategic program 2024-2027
  • the staff representation bodies, which were informed in 2024 within the Group's central structures (Group French Work Council, Group European Work Council, holding company Work Council)
• Collective "+1": consisting of voluntary partners representing the views of the five types of stakeholders, driven by an innovative methodology for dialog
• Specific analyses to gather expectations for ESG publications from financial players (investors, funds, banks) and rating agencies;
• Analysis of the main controversies involving Veolia, which are carefully monitored and managed.

Veolia-specific topics

Some IRO correspond to disclosures outside those predefined in the CSRD. For example, the CSRD covers GHG emissions in ESRS E1, and pollution emitted in ESRS E2, but these same ESRS do not address decarbonization or decontamination as economic activities for third parties. This is due to the very nature of Veolia's activities as an environmental services undertaking and Veolia has therefore chosen to include in its sustainability statement specific publications in addition to the basic information predefined in the ESRS, as provided for in point 11 of paragraph 1.1 of ESRS 1.

For a clear reading of the list of IRO, those that fall under this type of situation are recognizable by an outline in the table and their code includes the words "ES" (for specific topics).

List of material IRO

The approach led to a list of 41 material IRO presented in table form for 2024, linked to the Group's strategy according to six themes:

• decarbonization to limit climate change;
• depollution and preservation of nature;
• economical use and regeneration of resources;
• safe and resilient essential services for regions;
• stakeholder engagement in ecological transformation;
• attractiveness, safety and equity of the undertaking.

The time-frames of each of the material IRO are specified in the corresponding topical standards.

Validation at the highest level

Sustainability statements are reviewed by the Group's Executive Management and the Accounts and Audit Committee, and validated by the Board of Directors.

Transition plan for climate change mitigation

Scope of the plan

The transition plan covers the entire Veolia Group. As of December 31, 2024, the Group operates in 56 countries where it has a permanent establishment, employees and capital employed in excess of €5 million.

The plan impacts the value chain both upstream (purchases, etc.), in operations (modification of production tools, etc.), and downstream (provision of less carbon-intensive products: energy, drinking water, etc.).

Target year(s) for net zero / carbon neutral

Net Zero by 2050 (-90% reduction vs. 2021 for scopes 1, 2 and 3 combined)

The Group has set the following milestones:

• -18% by 2027 (end of GreenUp plan) for scopes 1 and 2 vs. 2021
• -33% by 2030 (estimated) for scopes 1 and 2 vs. 2021
• -50% by 2032 for scopes 1 and 2 vs. 2021 (intermediate milestone toward Net Zero)
• -30% by 2032 for at least 67% of scope 3 vs. 2021

Scope 1, 2, 3 reduction milestones with baseline years

Baseline year: 2021 (pro forma combining Veolia and Suez emissions)

Scopes 1 & 2:

• 2021 baseline: 24.4 million metric tons CO2 eq (pro forma)
• 2027 target: -18% vs. 2021
• 2032 target: -50% (12.2 million metric tons CO2 eq) vs. 2021

Scope 3:

• 2032 target: -30% for at least 67% of scope 3 vs. 2021

2024 results:

• Scope 1: 18,708 ktCO2eq
• Scope 2 (market-based): 2,143 ktCO2eq
• Scope 3 (total): 45,834 ktCO2eq
• Reduction achieved by end of 2024: -14.5% compared to 2021 baseline (for scopes 1 & 2)

Alignment with 1.5°C / SBTi validation status

SBTi validated in July 2024:

• Short-term emissions reduction targets for 2032 approved: -50% for scopes 1 and 2, and -30% for at least 67% of scope 3 by 2032 compared to 2021
• Long-term Net Zero by 2050 commitment recorded
• Commitment aligned with the ambition of the 2015 Paris Climate Agreement to limit global warming to 1.5°C (IPCC SSP1-1.9 scenario)

Moody's Net Zero Assessment: NZ2 score obtained in 2024

Note: Following methodological changes in emissions accounting introduced in 2024, the Group will submit its new trajectory to the SBTi in the first half of 2025. The Group's commitments in terms of the percentage reduction of scopes 1, 2 and 3 by 2032 and 2050 remain unchanged.

Key levers / decarbonization pillars

Main decarbonization levers (in order of importance to reach the 2032 target):

1. Energy – Fuel switching and coal phase-out:

   • Conversion of coal-fired power stations to lower-emission energy sources (gas, biomass, SRF, waste heat, geothermal)
   • Cogeneration using alternative fuels with increased efficiencies

2. Energy – Energy efficiency:

   • Improved energy efficiency to reduce fuel, heat and electricity consumption
   • Transformation of installations and improvement of production processes

3. Waste – Methane capture:

   • Increased methane capture rate in non-recyclable waste landfills

4. Waste – Removal of plastics:

   • Increase in sorting and removal of plastic before incineration

5. Energy mix decarbonization:

   • Decarbonization of the energy mix of heating networks
   • Decarbonization of electricity supplying the installations

6. Water – Electricity mix:

   • Decarbonization of the electricity mix for water treatment plants

7. Vehicles:

   • Use of vehicles with lower greenhouse gas emissions (electric or hybrid engines, less carbon-intensive fuels)

8. CO2 capture (future lever)

Scope 3 reduction approach:

• Supplier engagement program to refine calculation of supplier emissions
• Focus on purchased goods and services (Category 1) and capital goods (Category 2)

CapEx / investment commitments

GreenUp 2024-2027 plan financing:

• €1.6 billion accumulated by 2030 for the coal phase-out plan
• €85 million by 2027 for the landfill methane capture plan
• €133.5 million invested in 2024 for decarbonization (target: €110 million), primarily:
  • €126.7 million for coal phase-out, primarily in Poland (Łódź facilities)

Additional 2024 projects:

• €120 million approved for additional coal phase-out and methane capture projects

Innovation investment:

• Doubling of investments in innovation with an additional €200 million

Total growth investments 2024-2027:

• €4 billion, of which €2 billion prioritized for three strategic "booster" activities:
  • Bioenergy, flexibility & energy efficiency
  • Water technologies
  • Hazardous waste treatment

Locked-in emissions and stranded asset analysis

Coal phase-out commitment: Veolia committed at COP 28 in Dubai to invest €1.6 billion by 2030 to phase out coal in Europe. At the end of 2024, €656 million had been invested.

Assets covered by EU ETS:

• 40% of scope 1 GHG emissions come from regulated emission trading schemes
• The Group manages greenhouse gas allowances through a dedicated structure and special-purpose legal entity

Climate risk integration in financial statements:

• The Group investment validation process includes a review of consistency with Purpose objectives
• Long-term plans used in goodwill impairment testing incorporate the coal phase-out commitment and decarbonization plans validated by governance bodies
• "Veolia considers the assessment of climate risks to be consistent with the commitments given by the Group. The inclusion of climate risks did not have a material impact on the financial statements of the Group in 2024."

Methodology change impact: In 2024, Veolia reallocated scope 1 and 2 emissions from non-operationally controlled assets representing 11.9 million metric tons (35% of scopes 1 & 2) to Scope 3. The 2021 baseline was updated with a reallocation of 10.9 million metric tons. This does not change the Group's reduction commitments.

Use of carbon credits / removals

No offset mechanisms: The Net Zero by 2050 plan is based on reducing direct and indirect emissions without the use of offset mechanisms (i.e. -90% direct and indirect emissions reduction in 2050 vs. 2021).

GHG removals: According to ESRS E1-7, information on GHG removals and carbon credits is disclosed separately. The plan does not rely on carbon credits to achieve targets.

Avoided/erased emissions (Scope 4): Veolia tracks "erased emissions" (Scope 4) separately from scopes 1, 2, and 3. These represent GHG emission reductions of third parties thanks to Veolia's decarbonizing solutions:

• 2027 target: +30% CO2 avoided (scope 4) vs 2023 (18 million metric tons)
• Scope 4 may under no circumstances be subtracted from scopes 1, 2 and 3 emissions

Governance

Board of Directors:

• Approves the Group's strategy and transition plan
• Monitors performance through "Combating climate change" multifaceted performance indicators
• Validated the Net Zero plan with intermediate milestones in December 2023

Executive Committee:

• Two sponsors appointed:
  • Emmanuelle Menning (Deputy CEO, Finance and Purchasing): sponsor of Climate Change Mitigation
  • Sébastien Daziano (Director of Strategy, Innovation and Development): sponsor of Climate Change Adaptation

Finance Department:

• Coordinates actions linked to climate change mitigation commitments
• Environmental performance metrics included in Group's Environmental and Industrial Management System

Risk management:

• Climate change coordination by Sustainable Development Department with Risk and Insurance Department
• Progress presented and validated by the avoidance committee (includes two Executive Committee members)
• Climate risk identified as one of the Group's main risks

Incentive mechanisms:

• CEO variable pay indexed to climate performance (9.5% of total remuneration for 2024)
• Performance shares for executives awarded based on climate performance
• Climate performance criteria:
  • Reduction of scopes 1 and 2 emissions
  • Achievement of erased emissions targets
  • Progress rate of investments planned to reduce GHG emissions

Key policies and commitments

Emissions Trading Scheme (EU ETS): Active strategy to manage GHG emissions and allowances since 2005, with appropriate structure and dedicated legal entity.

Investment validation: Process includes review of consistency with Purpose objectives and climate commitments.

Synergies: €435 million in synergies achieved by end of 2024 from Suez integration (target raised to €530 million by end of 2025).

Progress and monitoring

2024 performance vs. targets:

• On track to achieve GreenUp 2027 target: -14.5% reduction achieved compared to 2021 baseline (target: -18% by 2027)
• Decarbonization investments 2024: €133.5 million (exceeded target of €110 million)
• Coal phase-out progress: €656 million invested to date (€1.6 billion target by 2030)

Trajectory non-linearity: The trajectory for reducing scopes 1 and 2 emissions is expected to be non-linear, with acceleration of decarbonization levers foreseeable within the framework of future strategic plans beyond 2027.

Policies related to climate change mitigation and adaptation

Climate Change Policy (Transition Plan)

Scope: The policy covers the entire Veolia Group, encompassing all businesses and regions. It addresses:

• Direct and indirect emissions (scopes 1, 2 and 3)
• Own operations and value chain (upstream purchases, operations, downstream provision of products)
• High-emitting activities including: district heating networks, waste-to-energy recovery, landfill sites, and wastewater treatment

Governance:

• The Board of Directors approves the Group's strategy and decisions that commit the Group, including the transition plan
• The Board monitors performance through "Combating climate change" multifaceted performance indicators
• The emissions reduction plan targeting Net Zero with the intermediate milestone of -50% for scopes 1&2 emissions and -30% for 67% of scope 3 by 2032 was validated by the Board of Directors in December 2023
• The Research, Innovation and Sustainable Development Committee receives annual presentations of climate commitment results and is regularly informed of climate change adaptation initiatives
• The Accounts and Audit Committee annually reviews the Group's risk map incorporating climate risks
• Two Executive Committee sponsors are appointed:
  • Emmanuelle Menning, Deputy Chief Executive Officer in charge of Finance and Purchasing, sponsor of the Climate Change Mitigation commitment
  • Sébastien Daziano, Director of Strategy, Innovation and Development, sponsor of the Climate Change Adaptation approach
• The Finance Department coordinates actions linked to Group commitments to climate change mitigation
• The Research, Innovation and Sustainable Development Department coordinates work related to climate change adaptation and climate risk management with the Risk and Insurance Department
• Progress is presented and validated by the avoidance committee, comprising two Executive Committee members, the Deputy Chief Executive Officer Finance and Procurement, the General Counsel, the Chief Risk and Insurance Officer, the Director of the Business Support & Performance department, and the manager of Health and Safety Prevention
• Each Business Unit Director is responsible for breaking down the Group strategy into business opportunities and risks inherent to their business lines and region

Key content and principles:

• Commitment to achieve Net Zero by 2050 (-90% direct and indirect emissions reduction vs. 2021) without the use of offset mechanisms
• Alignment with the 2015 Paris Climate Agreement to limit global warming to 1.5°C by the end of the century (IPCC SSP1-1.9 scenario)
• SBTi-approved short-term targets: -50% for scopes 1 and 2 and -30% for at least 67% of scope 3 by 2032 compared to 2021
• Non-linear trajectory with milestones: -18% in 2027, -33% (estimated) in 2030, -50% in 2032
• Transition plan obtained NZ2 score according to Moody's Net Zero Assessment (NZA)
• The commitment is fully in line with Veolia's Purpose: acting to reconcile human progress and environmental protection
• Plan integrated into the GreenUp 2024-2027 strategic program

Decarbonization levers (in order of importance to 2032):

• Conversion of coal-fired power stations to lower-emissions energy sources (gas, biomass, SRF, waste heat and geothermal)
• Increased methane capture rate in non-recyclable waste landfills
• Improved energy efficiency to reduce fuel, heat and electricity consumption
• Decarbonization of the energy mix of heating networks and electricity supplying installations
• Increase in sorting and removal of plastic before incineration for the Waste business
• Use of vehicles with lower greenhouse gas emissions (electric or hybrid engines and less carbon-intensive fuels)

Financial commitments:

• €1.6 billion accumulated by 2030 for the coal phase-out plan
• €85 million by 2027 for the landfill methane capture plan
• Dedicated annual budget lines for other decarbonization levers

Links to international standards:

• Alignment with the 2015 Paris Climate Agreement
• SBTi (Science Based Targets initiative) validation and commitment
• IPCC SSP1-1.9 scenario
• Moody's Net Zero Assessment (NZA) framework

Monitoring and implementation:

• Environmental performance metrics included in the Group's Environmental and Industrial Management System
• Finance Department coordinates actions and monitors corresponding environmental performance metrics
• Climate performance integrated into executive incentive mechanisms:
  • Chief Executive Officer's variable pay indexed to climate performance (9.5% of total remuneration for 2024)
  • Performance shares for executives and key contributors awarded based on climate performance
  • Climate performance criteria include: reduction of scopes 1 and 2 emissions, achievement of erased emissions targets, progress rate of emissions reduction investments, and speed of coal exit plan implementation
• Results presented annually to the Board's Research, Innovation and Sustainable Development Committee
• The order of deployment of levers and associated CapEx validated by Executive Management and monitored by the Finance Department
• Group will submit new trajectory to SBTi in first half of 2025 following methodological changes in emissions accounting

Public availability: The transition plan is published in the Universal Registration Document 2024. Additional information available at: https://www.veolia.com/en/veolia-group/who-are-we/compliance-and-vigilance

Climate Change Adaptation Policy

The company addresses climate change adaptation through:

• Coordination by the Research, Innovation and Sustainable Development Department with the Risk and Insurance Department
• Presentation and validation by the avoidance committee
• Executive sponsor: Sébastien Daziano, Director of Strategy, Innovation and Development
• Management of physical climate risks (natural disasters, extreme weather events, chronic water stress) through:
  • Choice of site location to limit exposure
  • Implementation of tailored prevention plans
  • Development of business continuity plans
  • Transfer of residual risk to insurance companies via damage programs
• Climate risk identified as one of the Group's main risks in the Non-Financial Performance Statement

Actions and resources in relation to climate change policies

GreenUp Strategic Program 2024-2027

Veolia's GreenUp strategic program aims to accelerate ecological transformation through decarbonization, depollution and resource regeneration, supported by €2 billion in investment.

Key objectives:

• Erased GHG emissions (Scope 4): +30% vs 2023 baseline (13.45 Mt in 2023; +13% achieved in 2024)
• Scopes 1 and 2 GHG emissions reduction: -18% vs 2021 baseline by 2027 (24.4 Mt CO2 eq in 2021; -14.5% achieved in 2024)
• Decarbonization Capex including phase-out of coal and methane capture: €600 million cumulative 2024-2027 (€133.5 million achieved in 2024)
• Revenue growth in priority business segments (Energy, Water Technology, Hazardous Waste): CAGR ≥5% at constant energy prices and exchange rates

Specific Decarbonization Actions

1. District heating network in London (Southwark)

• Scope: Customer operations / downstream
• Description: Constructing new district heating network delivering heat from Energy Recovery Facility in partnership with Southwark Council
• Resources: 75 GWh per year of low-carbon heat from non-recyclable household waste
• Outcomes: Supply nearly 5,000 homes across 11 social housing units and schools
• Time horizon: Operational (project in construction phase)

2. Urban cold recovery network from LNG terminal (Barcelona)

• Scope: Customer operations / downstream
• Description: Pioneering innovation and energy efficiency project in collaboration with Enagás and Barcelona City Council
• Resources: 131 GWh per year of local, decarbonized and affordable energy
• Outcomes:
  • Equivalent to annual consumption of a city like Reus (>100,000 inhabitants)
  • 32,000 tons of CO2 emissions avoided annually
  • Equivalent to 110 round-trip long-haul flights between Barcelona and New York
• Time horizon: Inaugurated in 2024
• Links to: Decarbonization policy pillar

3. Solar panel deployment on waste storage sites (France)

• Scope: Own operations
• Description: Installation of solar panels at post-operation waste storage sites to make services energy self-sufficient
• Resources:
  • Development of more than 40 solar projects on non-hazardous waste landfill sites
  • Installed capacity of 300 MW of renewable energy
  • Equivalent to 400 hectares of solar panels
• Outcomes: Energy equivalent to consumption of 130,000 inhabitants
• Time horizon: First plants operational by 2027
• Links to: Energy self-sufficiency ambition

4. Power plant acquisition in Hungary

• Scope: Own operations
• Description: Agreement with Uniper for acquisition of power plant through Hungarian subsidiary
• Resources: Installed capacity of around 430 MW
• Outcomes: Complement Veolia's flexible energy portfolio to meet needs of resilient power systems
• Time horizon: Subject to obtaining necessary authorizations

5. Heat highway network (Lille and Roubaix, France)

• Scope: Customer operations
• Description: Heating network extended by 20km to energy recovery unit
• Outcomes: Waste recovered as heat and electricity
• Links to: Decarbonization of local energy

Scope 4 Decarbonization Solutions

Veolia's scope 4 strategy (erased emissions) focuses on five key levers:

• Biogas capture and recovery
• Waste recycling and sorting
• Renewable energies production
• Energy efficiency
• Energy recovery from waste

Target trajectory: From 13.45 million metric tons CO2 (2023) to 17.6 million metric tons (+30%) by 2027

Supporting Actions

• #Team 66 initiative: Launched on World Environment Day (June 5, 2024) to build sustainable future, based on survey showing 66% of world population prefers environmental action to inaction
• Terra Academia: Inaugural campus in Arras, France to accelerate training for professions linked to ecological transformation
• Strategic Deep Dives: Series of stakeholder engagement sessions on decarbonizing local energy (London, January 2024), strategy and PFAS (New York, April 2024), and new water solutions (Oroszlány, Hungary, October 2024)

Targets related to climate change mitigation and adaptation

Climate Change Mitigation Targets

Scopes 1 & 2 Emissions Reduction

Intermediate milestones:

• 2027 (GreenUp plan end): -18% vs. 2021
• 2030: -33% (estimated) vs. 2021

Note: The Group is committed to achieving these targets "excluding significant acquisitions."

Scope 3 Emissions Reduction

Long-term Net Zero Commitment

GreenUp Strategic Program Target (2024-2027)

Specific Decarbonization Investment Targets

Coal Phase-out Investment

Methane Capture Target

Decarbonization Investment (GreenUp)

Customer Decarbonization (Scope 4*)

Note: Scope 4 represents avoided emissions by third parties thanks to Veolia's decarbonizing solutions. It is measured separately and cannot be subtracted from scopes 1, 2, and 3.

Climate Change Adaptation

Veolia has conducted climate resilience studies using the RCP 8.5 scenario (+4°C by 2100) with time horizons extending to 2030 and 2050. The company has:

• Analyzed exposure of 2,000+ operational sites to physical climate risks
• Identified priority geographical areas for adaptation efforts
• Deployed vulnerability studies on high-risk sites
• Established biodiversity action plans on sensitive sites

Biodiversity action plan deployment target:

• Metric: Average progress of action plans on sensitive sites
• 2024 result: 73% (158 sensitive sites)
• 2027 target: 63% (target already exceeded)

Methodology Note

In 2024, Veolia updated its GHG accounting methodology to better reflect operational control over emissions. This resulted in reallocation of 11.9 million metric tons from scopes 1&2 to scope 3. The 2021 baseline was restated accordingly. The Group plans to resubmit its trajectory to SBTi in 2025 following this methodological change, though percentage reduction commitments remain unchanged.

Energy consumption and mix

Total energy consumption

Total energy consumption (2024): 42 million MWh produced (across heating, cooling, electricity). This figure represents energy produced by Veolia's installations (thermal and renewable) rather than total primary energy consumption by the Group.

The Universal Registration Document provides limited disaggregated energy mix data for Veolia's own consumption following ESRS E1-7 requirements. Most energy metrics presented relate to energy produced and sold by Veolia to customers (42 million MWh produced in 2024, page 7), rather than the Group's internal consumption broken down by source.

Partial disclosures

The document notes that the detailed energy mix calculation will be automated and directly integrated into the reporting platform to allow publication in sustainability disclosures from fiscal year 2025 onwards (page 175). This represents an action plan to address unavailability of data in the first CSRD sustainability statement.

Metrics published elsewhere in the report

Some energy-related metrics are disclosed but not in the standard E1-7 format:

• Renewable energy as % of total energy produced: Veolia aims for 8 GW of bioenergy production capacity by 2030 (page 22)
• Energy efficiency of drinking water production (2027 guide value): 220 Wh/m³ for plants exceeding 60,000 m³/day (page 183)
• Energy efficiency of wastewater treatment (2027 guide value): 790 Wh/kg COD removed for WWTP with population equivalent capacity over 100,000 (page 183)
• Energy performance of heat production and cogeneration plants (2027 guide value): 75% for thermal plants selling more than 100 GWh/year (page 183)

Scope 1 & 2 emissions context

While not a direct energy mix table, the report discloses GHG emissions that reflect energy sources:

• Veolia committed to reduce Scope 1 and 2 emissions by 50% by 2032 (page 23), implying significant transformation of the energy mix, particularly phasing out coal in Europe by 2030 (€1.6 billion investment plan 2018-2030, page 23)
• Coal phase-out in Europe: explicitly mentioned as a key decarbonization lever (page 23)
• Biogas capture: reducing emissions in Waste activities through biogas recovery at landfills (page 23)

The report emphasizes Veolia's role as an energy producer (42 million MWh produced, 604 heating and cooling networks managed, 49,037 thermal installations managed as of 2024, page 7) rather than detailing the Group's own operational energy consumption by source category required under ESRS E1-7.

Energy intensity

No energy intensity per million EUR revenue is disclosed in the 2024 report.

Gross Scopes 1, 2, 3 and Total GHG emissions

Overview

Veolia reports greenhouse gas emissions across Scopes 1, 2, and 3 in accordance with the GHG Protocol. The Group has implemented a new methodology for allocating emissions across scopes in 2024, aligning with CSRD requirements. The baseline year for emission reduction targets is 2021.

Scope 1 – Direct GHG emissions

Scope 1 emissions include direct greenhouse gas emissions from sources owned or controlled by Veolia.

Sub-breakdown by source (where disclosed):

• Stationary combustion: Not separately disclosed in extracts
• Mobile combustion: Not separately disclosed in extracts
• Process emissions: Not separately disclosed in extracts
• Fugitive emissions: Biogas capture and methane management referenced but not quantified separately in extracts

2024 performance: The Group reports a -14.5% reduction vs. 2021 baseline (calculated using the new allocation methodology). The 2027 target is -18% vs. 2021.

Regulated emissions: The Group participates in the EU Emissions Trading System (EU ETS). In 2024, CO₂ allowance prices averaged €65.24/metric ton. The Group manages greenhouse gas allowances through a dedicated legal entity.

Biogenic CO₂ emissions: The Group produces bioenergy from non-recyclable waste and wastewater. Biogenic CO₂ from biomass combustion is tracked separately but specific tonnage not disclosed in extracts.

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Scope 2 – Indirect GHG emissions from purchased energy

Scope 2 emissions arise from the consumption of purchased electricity, heat, steam, and cooling.

Note: The extracts reference that Scopes 1 and 2 combined are measured against a 2021 baseline of 24.4 Mt CO₂eq. A breakdown into separate Scope 1 and Scope 2 figures, or into location-based vs. market-based Scope 2, is not provided in the excerpts. The Group targets a -50% reduction in Scopes 1+2 by 2032 (vs. 2021), validated by the Science Based Targets initiative (SBTi).

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Scope 3 – Indirect GHG emissions from value chain

Scope 3 emissions cover indirect emissions from the value chain, both upstream and downstream.

Disclosure level: The extracts do not provide a full Scope 3 inventory broken down by the 15 GHG Protocol categories. The Group acknowledges Scope 3 emissions and references methodology updates associated with CSRD, but detailed category-level data (e.g. purchased goods, capital goods, upstream transportation, business travel, etc.) are not disclosed in the excerpts.

Scope 3 categories covered: Not disclosed in detail in the excerpts.

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Total GHG emissions (Scopes 1 + 2 + 3)

Note: The extracts do not provide a consolidated total for Scopes 1+2+3. The 2021 baseline of 24.4 Mt CO₂eq explicitly covers Scopes 1 and 2. The Group's decarbonisation trajectory includes a Net Zero by 2050 target (-90% vs. 2021).

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GHG intensity

Metric: The Group tracks emissions intensity relative to revenue.

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Scope 4 – Avoided emissions (not part of ESRS E1-8 but disclosed by Veolia)

Veolia tracks 'erased emissions' or 'avoided emissions' (Scope 4), representing GHG reductions achieved by third parties thanks to Veolia's decarbonising solutions. This is not an ESRS requirement and is reported separately from Scopes 1, 2, and 3.

Methodology note: Scope 4 is a Veolia-specific concept and is reported distinctly from Scopes 1, 2, and 3. It measures emission reductions by customers and third parties resulting from Veolia's services (e.g. waste recycling, energy recovery, renewable energy production). Scope 4 may not be subtracted from Scopes 1, 2, or 3.

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Methodology and scope notes

• Baseline year: 2021 for Scopes 1 and 2 reduction targets.
• Reporting standard: GHG Protocol Corporate Standard; alignment with CSRD and ESRS E1.
• Scope changes: In 2024, Veolia updated the methodology for allocating emissions across Scopes 1, 2, and 3 in line with CSRD requirements. The 2021 baseline has been restated accordingly.
• Consolidation approach: Operational control (implied by references to 'facilities operated by Veolia').
• Coverage: The extracts note that significant acquisitions may be excluded from target calculations during integration periods. The disposal of certain assets (e.g. RGS in the United States) is also noted.
• External assurance: The Group's multifaceted performance indicators, including GHG metrics, are verified by an independent third party.
• SBTi validation: The Group's decarbonisation targets have been validated by the Science Based Targets initiative, including the interim milestone of -50% Scopes 1+2 by 2032 and the long-term goal of Net Zero by 2050.
• EU ETS: Veolia's combustion facilities participate in the EU Emissions Trading System. Free allowances for district heating networks and other installations are subject to phase-out schedules.
• PFAS and emerging pollutants: The Group is developing solutions for PFAS treatment and monitoring, which may influence future Scope 3 emissions from waste and water treatment processes.

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Data availability and limitations

The excerpts provided do not include:

• Detailed Scope 1 sub-breakdown by combustion type, process emissions, or fugitive emissions.
• Separate Scope 2 location-based and market-based figures.
• Category-by-category Scope 3 inventory (GHG Protocol categories 1–15).
• Total Scope 3 tonnage.
• Multi-year time series for Scope 1, Scope 2, and Scope 3 in tabular form.
• GHG intensity metric (tCO₂eq / M€ revenue) for 2024 or 2023.

The Group indicates that these metrics exist and are managed internally, and are aligned with ESRS E1-6 / E1-8 requirements, but the full quantitative disclosure is not reproduced in the excerpts provided.

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Summary table (best-effort synthesis from extracts)

Note: Scope 4 is not part of ESRS E1-8 and is reported separately. It may not be netted against Scopes 1, 2, or 3.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

The document cross-references ESRS E1-9 to section 4.1.2.1.5 Climate change adaptation.

However, the provided excerpts do not contain the actual content from section 4.1.2.1.5. The excerpts only show:

• A table of contents mapping that indicates E1-9 is addressed in section 4.1.2.1.5
• Regulatory cross-reference tables showing E1-9 relates to Pillar 3 requirements under Article 449a Regulation (EU) No 575/2013 and Commission Implementing Regulation (EU) 2022/2453
• Specific technical requirements including:
  • Exposure of the benchmark portfolio to climate-related physical risks (paragraph 66)
  • Disaggregation of monetary amounts by acute and chronic physical risk (paragraph 66(a))
  • Location of significant assets at material physical risk (paragraph 66(c))
  • Breakdown of carrying value of real estate assets by energy-efficiency classes (paragraph 67(c))
  • Degree of exposure of the portfolio to climate-related opportunities (paragraph 69)

The substantive disclosure content for E1-9 is not included in the provided excerpts.

Policies related to pollution

Veolia does not disclose a single named policy specifically dedicated to pollution. Instead, the company describes an operational environmental policy that integrates pollution management alongside other environmental topics (climate change, water resources, biodiversity, circular economy).

Environmental Policy (Operational Policy)

Scope:

• Applies to all Business Units across the Group's three business lines (water, waste, energy)
• Covers operational sites under Veolia's management and operational control
• Addresses both direct operations and, to some extent, the value chain

Key content and principles:

• The policy provides guide values and standard targets for 2027 across multiple environmental themes, including:
  • Depollution targets for wastewater treatment (BOD5 efficiency >96%, COD efficiency >92%)
  • Air emissions limits for waste incineration (NOx <110 mg/Nm³, SOx <20 mg/Nm³, dust <3 mg/Nm³)
  • Thermal plant emissions (NOx <190 g/MWh, SOx <120 g/MWh, dust <10 g/MWh, Hg <5 mg/MWh)
  • Recovery rates for combustion residues and wastewater treatment sludge
• Each Business Unit adapts the policy to its local context through the Environmental and Industrial Management System (EIMS)
• Business Units review environmental and industrial risks annually and analyze performance against guide values

Governance and oversight:

• The Business Support and Performance Department (also called Business Support and Performance Division) provides documentary corpus, operational standards, good practices, and technical support to all Business Units
• The Purpose Committee of the Board of Directors performs annual review of environmental performance, including pollution-related objectives and metrics
• The Accounts and Audit Committee reviews financial and non-financial risk mapping, including environmental and industrial risks related to pollution
• An Executive Committee member and Senior Executive Vice President for Strategy, Innovation and Development acts as sponsor for environmental protection objectives
• Progress on environmental objectives is evaluated by an independent third-party organization and affects variable compensation of Executive Resources

Implementation and monitoring:

• The EIMS allows each Business Unit to define priorities and action plans adapted to local contexts while aligning with Group-level standard targets
• Business Units conduct annual critical analysis of business performance against guide values
• The policy is supported by operational standards developed and maintained by Group business experts
• Consolidated reporting tracks performance indicators related to pollution emissions

Linkage to regulations: The excerpts reference extensive compliance with French and European environmental regulations (French Environmental Code, Public Health Code, Energy Code, etc.) and monitoring by administrative authorities (DREAL), but do not explicitly link the environmental policy to international frameworks such as UNGPs, OECD Guidelines, or UNGC in relation to pollution specifically.

Public availability: No specific URL or document location is provided for the environmental policy in the excerpts.

Pollution of air, water and soil

Emissions to Air

Waste Incineration Plants

Power Plants (>100 GWh/year energy sold)

Note: For mercury emitted from power plants, data are estimated by excess for almost half of the sites, based on regulatory maximum values, in a conservative approach. For all other mercury emitting sites, data are estimated on the basis of monthly or annual sampling.

Sites Exceeding E-PRTR Thresholds (2024)

Note: This information must be interpreted with caution, as sites with a very high level of activity automatically exceed the thresholds set in absolute terms by the E-PRTR regulation, while respecting the regulatory limits imposed on them by the local authorities. For example, for NOx emissions from incinerators, the 7,197 metric tons represent 74% of the Group's total NOx emissions, emitted by 25% of incinerators belonging to those with the largest capacity.

Multi-Year Performance Indicators (Air)

Emissions to Water

Wastewater Treatment Plants (>100,000 population equivalent capacity)

Multi-Year Performance Indicators (Water)

Note: Treatment efficiency metrics apply to wastewater treatment plants (WWTP) with a population equivalent capacity of over 100,000.

2027 Guide Values (Target Standards)

Air Pollution Targets

Waste Incineration:

• NOx: < 110 mg/Nm³
• SOx: < 20 mg/Nm³
• Dust: < 3 mg/Nm³

Power Plants (>100 GWh/year):

• NOx: < 190 g/MWh of fuel consumed
• SOx: < 120 g/MWh of fuel consumed
• Dust: < 10 g/MWh of fuel consumed
• Mercury: < 5 mg/MWh of fuel consumed

Water Pollution Targets

Wastewater Treatment Plants (>100,000 population equivalent):

• BOD5 treatment efficiency: > 96%
• COD treatment efficiency: > 92%

E-PRTR Disclosure Limitations

Consolidated reporting on exceeded thresholds set by the European E-PRTR regulation (166/2006:EU) covering all 91 listed substances is difficult to implement. Veolia can disclose data for 6 substances corresponding to usual business metrics deployed in all regions. Outside the European Union, implementation is not applicable in practice, with local regulations defining substances and thresholds differently. The 2024 E-PRTR data for Member States was not yet available at the time of writing.

Substances of Concern and Very High Concern

Veolia is not concerned with the production or marketing of substances of concern and very high concern (SVHC), with one exception where a substance of potential concern has been identified at one site. As a precaution, steps are being taken to replace this substance, and the process is designed not to discharge it into the environment. These substances may be involved in waste treatment activities with the objective of eliminating them.

Substances of concern and substances of very high concern

Analysis and prevention approach

In the field of chemical risk, the Group conducted an analysis on the issue of substances of concern and very high concern, through a prevention group dedicated to this subject, involving the main concerned departments (scientific and technical studies, business support, health and safety risks, procurement). After examining whether Veolia is affected by such substances, it appears to date that:

• With one exception detailed below, Veolia is not concerned with the production or marketing of these substances, and to our knowledge Veolia does not use them as input substances in technical processes;
• These substances may be involved in Veolia's operations in the form of input materials in the context of waste treatment activities, with the objective of eliminating them.

Regular investigations conducted by the chemical risk prevention group have identified the use of a substance of potential concern at one site. In order to preserve manufacturing secrets, Veolia wishes to keep precise information confidential.

As a precaution, Veolia is taking steps to replace this substance as soon as possible. Lastly, the process is designed not to discharge this substance and its residues into the site's environment.

Regulatory context

Veolia's activities are subject to comprehensive regulatory frameworks governing hazardous substances:

• REACH Regulation (EC) 1907/2006: Concerning the Registration, Evaluation, Authorization and Restriction of Chemicals. This regulation seeks to reduce the health and environmental risks associated with the manufacture and use of chemical substances and improve the management of these risks throughout the life cycle of chemical products. For the Group, as a user and producer of such substances, this involves greater cooperation and a better exchange of information with suppliers and customers.
• CLP Regulation (EC) 1272/2008: On Classification, Labeling and Packaging, harmonized the existing provisions and criteria concerning the classification, packaging and labeling of hazardous substances taking account of the adoption of the United Nations' Globally Harmonized System (GHS). As part of the Commission's strategy on sustainability in the area of chemical products, the CLP Regulation was amended by Regulation (EU) 2024/2865 of the European Parliament and of the Council of 23 October 2024.
• POPs Regulations: Regulation (EU) 2019/1021 of 20 June 2019 on persistent organic pollutants (Stockholm Convention) also has an impact on the Group's activities. Some PFAS are regulated under the REACH and POP regulations.

The relevant legal entities are in compliance with the schedule set by the REACH Regulation for chemicals requiring registration within the Group. After the systematic pre-registration of all substances that may be concerned, various deadlines are being monitored along with changes to the regulation and updates to its annexes.

Operational approach

Veolia's primary interaction with substances of very high concern occurs in the context of hazardous waste treatment activities, where the objective is to eliminate these substances. Veolia is the world leader in hazardous waste treatment, with extensive experience of all available techniques and the ability to operate them in a fully controlled manner.

No quantitative data on total amounts of substances of concern or substances of very high concern generated, used or procured has been disclosed in this report.

Anticipated financial effects from pollution-related impacts, risks and opportunities

According to the disclosure reference table, E2-6 is addressed in section 4.1.2.2.2 'Pollution emitted by Veolia / Financial assessment of pollution risk'. However, the specific content of this section was not included in the provided excerpts.

Policies related to water and marine resources

The excerpts provided do not contain substantive disclosure of Veolia's policies related to water and marine resources under ESRS E3-1.

The document includes:

• References to European legislative frameworks (Water Framework Directive 2000/60/EC, Directive 2006/118/EC on groundwater protection, Directive 2008/105/EC on environmental quality standards, and Directive 91/271 on urban wastewater treatment)
• A cross-reference table indicating that E3-1 disclosures can be found in section 4.1.2.3.2 "Optimizing water resource management"
• A mapping table showing E3-1 paragraph 9 corresponds to "Indicator number 7" and paragraphs 13-14 relate to dedicated policy and sustainable oceans/seas

However, the actual policy content, policy names, governance structures, approval processes, scope, monitoring mechanisms, and links to international standards are not included in the provided excerpts. The excerpts appear to be from regulatory context sections and cross-reference tables rather than the substantive policy disclosure sections themselves.

Actions and resources related to water

The document references section 4.1.2.3.2 Optimizing water resource management as the location for E3-2 disclosure on actions and resources related to water and marine resources.

However, the provided excerpts contain only the index/table of contents mapping ESRS requirements to document sections. The actual content of section 4.1.2.3.2 describing the specific actions, programmes, resources allocated, time horizons, expected outcomes, and linkages to policies or targets is not included in the excerpts provided.

Additional context sections referenced for water-related disclosures include:

• 4.1.2.3.3 Measuring our impact on water resources (E3-3, E3-4)
• 4.1.2.3.4 Supporting the efforts of municipal customers (E3-5)
• 4.1.2.3.5 Supporting the efforts of industrial customers (E3-5)
• 4.1.2.3.6 A Historical contractual model that needs to evolve (E3-5)

Without access to the actual content of these sections, specific actions and resources related to water and marine resources cannot be extracted.

Water consumption

Water withdrawal and consumption overview

Veolia reports the following water-related operational scale metrics:

Water operations scale (2024):

• 3,879 drinking water production plants managed
• 111 million people supplied with drinking water
• 3,198 wastewater treatment plants managed
• 98 million people connected to wastewater systems

Water savings and resource regeneration

As part of the GreenUp strategic program, Veolia has committed to preserve and regenerate resources:

2027 target: Reduce footprint on drinking water resources abstracted by over 1.5 billion m³

Water savings indicator (performance criteria):

• Freshwater savings target by 2026: ≥1.45 billion m³ (measured as sum of: (i) annual volume of water reused after treatment, (ii) annual value of water desalinated, and (iii) annual volume of water preserved by freshwater networks thanks to improvements in yield compared to 2023)
• Freshwater savings target by 2027: ≥1.5 billion m³
• Baseline year: 2023

Water reuse and recycling

Veolia develops water reuse solutions:

• Water reuse projects in progress in Morocco (treated wastewater for agriculture)
• Water recycling plant in Singapore reducing city water consumption by up to 60%
• Desalination and process water reuse capabilities across industrial sites
• Zero liquid discharge plant services offered to industrial customers

Water treatment volumes

Microplastics removal efficiency (2024):

• Wastewater treatment processes remove >99% of microplastics (MEDITPLAST project results)

Water consumption in areas of water stress

The document acknowledges water stress as a significant risk factor:

• Mining sector consumption equivalent to annual domestic consumption of the United States
• 70% of major mining projects in water stress zones
• Industrial operations in water-stressed regions (Middle East, Australia, North Africa)
• Climate change vulnerability studies conducted at 2,000+ operating sites (2022-2023) including water stress assessment

Specific quantification of water consumption volumes in water stress areas is not disclosed in these excerpts.

Water intensity

Water intensity metrics per unit revenue or production volume are not disclosed in these excerpts.

Water discharge

Wastewater treatment capacity is reported operationally:

• 3,198 wastewater treatment plants managed
• 98 million people connected to wastewater systems

Specific discharge volumes by destination are not quantified in these excerpts.

Multi-year comparison

Historical multi-year data for water consumption, withdrawal, or discharge volumes are not provided in these excerpts. The targets reference 2023 as baseline year for freshwater savings calculations.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Biodiversity integration in corporate strategy and business model

Nature is integral to Veolia's strategy. The Group responds to challenges linked to the protection and restoration of biodiversity through its very activity or through operational methods adopted at the sites where it operates, but also more widely by making biodiversity an integral part of its policy and processes.

Veolia's activities contribute to preserving the environment (water, air, soil) and to reducing several of the factors that erode biodiversity as a result of the activities of its municipal and industrial customers (climate change, pollution, overexploitation of natural resources including water resources). Industrial activities carried out on sites operated by the Group can however cause direct or indirect negative local environmental impacts of a magnitude infinitely smaller than that associated with the reduction of the impacts of its customers, the control of which is part of the Group's environmental policy.

Under its GreenUp strategic program, as part of its 2024-2027 multifaceted performance approach, Veolia chose to monitor the roll-out of action plans designed to improve the footprint on environments and biodiversity of "sensitive" sites.

Specific biodiversity targets

The multifaceted performance approach for 2024-2027, associated with the new GreenUp strategic program, includes new standard targets associated with the topic "Biodiversity and Ecosystems":

Four objectives for multifaceted performance under GreenUp 2024-2027 relate to erosion factors:

• Scope 1 and 2 GHG emissions reduction – 2027 target -18% (vs. 2021)
• Scope 4 GHG erased emissions – 2027 target 18 Mt CO2 eq.
• Action plan deployment rate on sensitive sites – 2027 target 85%
• Volume of freshwater saved (reuse, desalination, leakage reduction) – 2027 target 1.5 billion m³

Renatured areas target: The Group has set a target for renatured areas of 745 hectares by 2027 for all landfills.

Act4nature international commitments for 2027 include:

• Implementation of action plans at "sensitive" sites with an overall deployment rate of 85% for 2027
• Deployment of ecological management at all Group sites with over one hectare of green space with a target of 95% by 2027
• Discontinuation of phytosanitary products at all operational sites with a target of 95% for 2027
• 100% traceability and 100% certification target for the wood biomass supplies in the energy sector for sites whose supply chain the Group controls
• Zero deforestation commitment, maintain 100% traceability of wood products in the energy sector and aim for 100% certified supplies in the operational control scope of the supply chain
• Volume of freshwater saved: 1.5 billion m³ by 2027 through reuse of treated water, desalination and leakage reduction

2024 performance on key targets:

• Action plan deployment on sensitive sites: 73%
• Ecological management deployment: 60%
• Phytosanitary product discontinuation: 68.99%
• Wood traceability: 100%, Wood certification: 79% (100% certification in Europe)
• Water saved: 1.45 billion m³

Geographic and value chain scope

The methodology used to identify sensitive sites factors in the location of direct operations with regard to the sensitivity of the natural environment (using the IBAT mapping tool developed with the support of IUCN) and the nature of site activities. In 2024, Veolia identified 158 sensitive sites out of around 1,800 main sites managed by the Group.

Sites said to be "sensitive" are identified according to two major criteria:

• Issues related to the sensitivity and potential of the site: the type of environment in which the site is located, the presence of protected natural areas or areas of great importance to biodiversity near the site, the potential presence of threatened or protected species, land and water surface areas and level of water stress.

To this end, Veolia reconciles information extracted from the IBAT database.

Value chain analysis: In 2023, the analysis of direct operations and the value chain, conducted according to the LEAP approach advocated by the TNFD, identified issues at Veolia's sites and for certain raw materials, calling for more consideration to be given to nature in the value chain. As a result, by 2025 this will lead to a more extensive dialog with the main suppliers of the most affected procurement categories in order to incorporate environmental protection criteria into the supplier selection and assessment.

Use of TNFD and other frameworks

TNFD: Veolia was one of the first undertakings to have used, in its 2023 Universal Registration Document, the nature-related impact reporting framework developed by the Taskforce on Nature-related Financial Disclosures (TNFD). Veolia was singled out at the Davos Forum in January 2024 as being one of the TNFD's 19 French early adopters.

As a TNFD Early adopter, Veolia aligned information published in the URD with TNFD requirements as of 2024 (URD 2023). Since 2024 (URD 2023), the URD has included sidebars focusing on each of the four TNFD pillars, as well as a cross-reference table linking the TNFD's recommended disclosures with the relevant chapters of the URD.

In March 2024, the Group renewed its commitment to the initiative act4nature international. These new commitments for 2027 are structured according to the pillars of the TNFD. Their progress at the end of 2024 is presented in Appendix 8.10.1.

Other frameworks and initiatives:

• Global Biodiversity Framework (GBF): The new Act4nature international commitments are in line with the targets of the Global Biodiversity Framework (GBF), which emerged from COP15. The GBF sets global nature protection targets for 2030.
• It's Now for Nature: In 2024, the Group joined the twin initiative It's Now for Nature, led by the organization Business for Nature, which encompasses more than 100 business networks worldwide.
• IUCN: The Group has been a partner of the French IUCN committee since 2008. This committee shares its expertise with the Group for implementing the Group's biodiversity strategy.
• COP16: In November 2024, the Group attended COP16 in Cali, and was invited to take part in the Business and Biodiversity Summit. To mark the occasion, Veolia published its first biodiversity report, entitled "Conserving and regenerating nature: from commitment to action".

Investment commitments

Under the GreenUp strategic program, Veolia's innovation policy plans to boost the deployment of the offering relating to Nature-based Solutions, particularly in large water cycle management.

The Group's new commitments include providing customers with conservation and restoration solutions derived from its performance and innovation policy, such as nature-based solutions.

Linkage to nature-related risk assessment

Risk assessment approach: The main risks that Veolia faces are subject to an annual mapping process. Risks are classified according to their potential impact and probability of occurrence, and ranked according to importance. Among these risks are environmental and industrial risks.

In 2023, Veolia assessed its impacts, dependencies, risks and opportunities using the LEAP (Locate Evaluate Assess Prepare) method. This analysis, performed on direct operations and the upstream value chain, identified issues at Veolia sites and for certain raw materials.

The analysis conducted covers physical and transition risks, but Veolia has not yet assessed systemic risks as the Group is in the learning phase of the TNFD framework and is waiting for methodologies to be proven.

Integration into risk management: The results of the LEAP study improved the Group's risk nomenclature (Veolia Risk Universe), which seeks to develop a common language for risks and their descriptions by integrating the risk of biodiversity loss.

Governance framework: To review the risks and opportunities relating to the nature-related impacts and dependencies of Veolia's activities, the Board of Directors primarily relies on two of its Committees:

• The Purpose Committee, which performs an annual review of the multifaceted performance objectives, including the protection of natural environments and biodiversity, and related metrics
• The Accounts and Audit Committee, which is in charge of reviewing the financial and non-financial risk mapping, including challenges relating to nature, understanding the management initiatives and corrective measures

Like all multifaceted performance objectives, the objective of protection of natural environments and biodiversity is supported by a sponsor, Executive Committee member and Senior Executive Vice President for Strategy, Innovation and Development. Its progress, evaluated by an independent third-party organization, is taken into account in calculating the variable compensation of the Group's Executive Officers.

The sharing of objectives and the rollout of Veolia's biodiversity strategy in the Business Units takes place via a network of more than 40 contacts across the Group. Quarterly meetings are held to facilitate this information exchange. The biodiversity contacts are specifically tasked with implementing nature conservation action plans on sites that Veolia operates.

Mitigation hierarchy and operational approach

Mindful of its potential impacts, the Group applies the mitigation hierarchy by prioritizing actions, aimed first at avoiding these impacts, then at minimizing them, and finally, as a last resort, at compensating for them where necessary (AMC: avoid, minimize, compensate).

Green Spaces and Zero Phytosanitary Products charters:

• The "Green Spaces" charter is intended to support the transition of operational entities toward more ecological practices. It formalizes the commitments made by Veolia's sites and service providers in the ecological management of green spaces.
• The "Zero Phytosanitary Products" charter (covering herbicides, fungicides, insecticides and biocides) lists the practices to be adopted for a site to be considered virtuous with regard to the management of its green spaces.

Stakeholder engagement

The Group raises awareness among internal (on-site personnel, support functions) and external (subcontractors, customers, general public, etc.) stakeholders in the protection of environments and biodiversity. E-learning content on biodiversity, designed specifically around the biodiversity issues raised by Veolia's activities, has been available since 2022.

Veolia is also an active participant in the think tanks of leading French non-profit organizations, such as Entreprises pour l'environnement (EpE) and Orée, as well as Business for Nature, an international network.

In November 2023, following the publication of the National Biodiversity Strategy 2030, the Group was invited by the Ministry of Ecological Transition to participate in the Business and Biodiversity "Roquelaure" working group, aimed at formulating recommendations to reduce risks and identify opportunities with regard to biodiversity in the main business sectors in France. Roquelaure's findings were presented in November 2024.

Policies related to biodiversity and ecosystems

Veolia does not disclose a named standalone biodiversity or ecosystem policy in the provided excerpts. Instead, the company describes biodiversity as integrated within its broader risk management policy and strategic approach.

Integration of biodiversity within risk management policy

Scope:

• The main risks Veolia faces are subject to an annual mapping process, including environmental and industrial risks
• Analysis of direct operations and the value chain was conducted in 2023 according to the LEAP approach advocated by the TNFD
• Issues were identified at Veolia's sites and for certain raw materials

Key content / principles:

• Risks are classified according to their potential impact and probability of occurrence, and ranked according to importance
• The 2023 LEAP analysis identified the need for more consideration to be given to nature in the value chain
• By 2025, this will lead to more extensive dialog with the main suppliers of the most affected procurement categories to incorporate environmental protection criteria into supplier selection and assessment

Alignment with international frameworks:

• The company uses the TNFD (Task Force on Nature-related Financial Disclosures) framework
• Veolia was one of the first undertakings to use the TNFD nature-related impact reporting framework in its 2023 Universal Registration Document
• Veolia was singled out at the Davos Forum in January 2024 as being one of TNFD's 19 French early adopters
• The Group joined the act4nature international commitment
• The Group has been a partner of the French IUCN committee since 2008

Stakeholder engagement:

• Partnership with French IUCN committee since 2008, which shares expertise for implementing the Group's biodiversity strategy
• Active participant in think tanks including Entreprises pour l'environnement (EpE), Orée, and Business for Nature
• Joined the It's Now for Nature initiative in 2024, led by Business for Nature
• Participated in the Business and Biodiversity "Roquelaure" working group in France (2023-2024)
• Attended COP16 in Cali in November 2024

Monitoring and implementation:

• E-learning content on biodiversity, designed specifically around the biodiversity issues raised by Veolia's activities, has been available since 2022
• The ultimate aim is to firmly establish the change of culture needed to transform operational practices at all of the Group's decision levels (ecological management, green infrastructures, etc.)

Public availability:

• Biodiversity Report published in November 2024: "Conserving and regenerating nature: from commitment to action"
• URL: https://www.veolia.com/sites/g/files/dvc4206/files/document/2024/10/biodiversity-report-veolia-101624.pdf
• TNFD disclosure framework information presented in Appendix 8.10.2

The company does not name a specific standalone "Biodiversity Policy" or "Nature Policy" but rather describes biodiversity protection as integrated into its risk management framework and strategic commitments.

Actions and resources related to biodiversity

Overview of biodiversity action plan deployment

In 2024, Veolia reviewed the list of sites considered to have significant issues with regard to the protection of environments and biodiversity, taking into account its new scope of activities. The target for biodiversity action plan deployment on these sensitive sites now includes 158 sites instead of 107 in the previous scope (2020-2023), with the addition of 51 new sites, including 14 from the former Suez.

2024 Performance: The 2024-2027 GreenUp plan target of 63% average progress of action plans on sensitive sites was exceeded, reaching 73% (a gain of 14 points in one year).

2027 Target: ≥ 85% progress on action plans at sensitive sites.

Action plan structure and implementation

Veolia's biodiversity action plans are defined based on biodiversity footprint assessments conducted with the involvement of ecologist experts. The action plans include:

• 15 generic actions to be deployed at each site
• Additional actions recommended by ecologists based on biodiversity footprint analysis results

The deployment rate measures the progress of planned actions, calculated by dividing the number of actions actually carried out by the total number of actions required.

Scope of actions

Actions are focused on:

• Reducing impact on habitat fragmentation and artificialization
• Preserving rare or threatened species
• Managing green spaces ecologically
• Protecting water resources
• Tackling invasive alien species
• Reducing light pollution
• Preventing pollution
• Fighting climate change
• Raising awareness among stakeholders

Scope: The implementation covers all of Veolia's activities at industrial sites (own operations).

Example: Parque Ecológico Las Cuadras (Colombia)

Located in the city of Pasto on a landfill and incineration site, this 98 hectare park has maintained three conservation areas totaling 73 hectares since 2021.

Partnerships: The environmental protection association Viva el Planeta supports Veolia in ecological management.

Activities:

• Ecological management of rare species of trees (oak, palm, Colombian pine)
• Protection of rare bird species (acorn woodpecker)
• Creation of a nursery ensuring availability of endemic species for regreening or reforestation
• Awareness raising among employees and local communities through visits and conferences on biodiversity

Biodiversity footprint assessment process

Veolia uses a biodiversity footprint methodology to assess site-level impacts across multiple criteria:

• Site location and management of spaces (protected natural areas, green spaces, invasive species, lighting)
• Operations and activities (raw materials, discharges, waste production, energy and material recovery)

Resource allocation (non-financial): Involvement of ecologist experts in local biodiversity to help Business Units measure their on-site footprint and define action plans.

Value chain engagement

Upstream: The market and clients of environmental services are increasingly concerned about the state of nature and commitment to preserve it.

Downstream: Main beneficiaries include the planet, local communities, and investors (through recognition of positive impact on nature).

Governance

Sponsor: Sébastien Daziano, Executive Committee member, Senior Executive Vice President, Strategy, Innovation and Development

Impact metrics related to biodiversity and ecosystems change

Sites within or near protected areas / Key Biodiversity Areas

Sensitive sites overview

The list, updated in 2024 under the GreenUp strategic plan to cover a broader scope following the acquisition of Suez, includes 158 sensitive sites with a total area of 21,290 hectares, including 103 sites located within five kilometers of a sensitive or protected area (source: IBAT). In 2024, 135 of these sensitive sites implemented biodiversity actions covering a total area of 17,655 hectares.

Number of sensitive sites and surface area near sensitive/protected areas (103 out of 158 sensitive sites)

Restoration metrics

Action plan deployment at sensitive sites

Methodology

The methodology used to identify sensitive sites takes into account the location of direct operations with regard to protected areas or areas of great importance for biodiversity using the Integrated Biodiversity Assessment Tool (IBAT), as well as the nature of the site activities. Veolia reconciles information extracted from the IBAT database (developed by Birdlife International, Conservation International, the IUCN and the United Nations Environment Program) and site geo-location data. The natural areas defined by IUCN (categories I to VI), UNESCO (natural world heritage sites), the Ramsar Convention, MAB (Man and the Biosphere Programme), the Alliance for Zero Extinction, and Important bird and biodiversity areas (IBAs) are considered.

Sensitive sites are identified according to two major criteria:

• Issues related to the sensitivity and potential of the site (type of environment, presence of protected natural areas, potential presence of threatened or protected species, land and water surface areas, level of water stress)
• Issues relating to the site's activity (air and water discharges, treatment efficiency, abstraction of resources, potential past non-compliance, soil sealing)

The biodiversity footprint of sensitive sites is measured to assess direct or indirect negative and positive impacts generated by site activities at local level, including analysis of metrics relating to site process, site location and management of spaces.

Deforestation commitment

Veolia has undertaken to achieve 100% traceability and certification of the wood biomass used for energy within the Group's scope of operational control by 2027. With this certification, the Group can guarantee the non-deforestation and non-conversion of wood supply sectors, as well as the absence of provenance from areas of high environmental value.

Policies related to resource use and circular economy

The excerpts provided do not contain specific information about Veolia's policies related to resource use and circular economy as required by ESRS E5-1.

The excerpts primarily describe:

• External regulatory framework: French laws and regulations applicable to Veolia's operations, including:
  • Law no. 2015-992 on energy transition for green growth (focusing on circular economy and waste reduction)
  • Law no. 2020-105 (AGEC law) on fighting waste and the circular economy
  • Various orders and decrees related to water, waste, and energy

These are external legal requirements rather than Veolia's own corporate policies.

The document index indicates that E5-1 policies should be disclosed in section 4.1.2.5.1 (Introduction) and 4.1.2.5.2 (Develop material and energy recovery), but the content of these sections is not included in the provided excerpts.

Without access to the actual policy content from the referenced sections, it is not possible to extract the required policy information (policy names, scope, governance, key principles, public availability, links to standards, and monitoring mechanisms).

E5-4 Resource Inflows

Veolia monitors several metrics for resource inflows across its three core business lines (Water, Waste, Energy):

Resource Inflows by Business Line (2024)

Material Inflows

These inflows are divided into three main categories reflecting Veolia's core operations:

• Municipal and industrial waste sent to treatment centers for recovery applying the hierarchical principle of waste management: prevent production, identify opportunities for reuse, recycling and recovery, and if recovery is not possible, ensure treatment in accordance with applicable regulations

• Fuel used to produce energy (gas, coal, biomass): saving and conserving energy resources is a major lever in Veolia's contribution to combating climate change, notably by increasing energy efficiency at operated installations, prioritizing the use of renewable energy and energy from waste, and exploiting the energy potential of waste and wastewater

• Water taken from natural environments to produce drinking water for communities, as well as domestic and industrial wastewater which is collected and then treated before being either reused or returned to the natural environment

Additional Monitored Metrics

The Group also monitors:

• Quantity of incoming hazardous waste: Not quantified separately in main table, but a GreenUp target for 2027 of 9 million metric tons (scope impact related to disposal of RGS United States)

Circular Economy Context

Veolia's resource inflows feed into circular solutions across its value chain. The inflows from customers (waste, wastewater) are processed to produce alternative secondary materials, energy and water that reduce pressure on virgin resources. Raw water is the primary virgin resource input for drinking water production.

These resource inflows support Veolia's circular economy strategy focused on resource regeneration, including treating waste and complex pollution, waste and wastewater energy and material recovery, and industrial and regional ecology services.

Waste

Waste Management Activities

Veolia is one of the leading players in the management of liquid, solid, non-hazardous and hazardous waste. The Group operates across the entire waste life cycle, from collection to final processing and makes waste recycling and recovery a priority. Veolia plays a key role in the circular economy, developing innovative solutions to increase rates of waste recycled and recovered as materials and energy.

Key operational metrics (2024):

• 43 million people provided with collection services on behalf of local authorities
• 65 million metric tons of treated waste
• 861 waste processing facilities operated
• 572,834 business customers

Waste Collection

Due to the wide range of waste categories (household waste, non-hazardous commercial and industrial waste, construction waste, green waste, hazardous industrial and service sector waste), waste collection is a major logistics challenge. Veolia provides door-to-door household waste collections, as well as collecting waste from communal disposal points, non-hazardous commercial and industrial waste and green waste (keeping green spaces clean). It also collects hazardous waste from industrial and service sector customers, including biomedical waste from hospitals and laboratories and waste oil (e.g. from ships and gas stations).

Recycling and Material Recovery

Veolia's goal is to treat waste with a view to reintroducing it into the industrial production cycle and achieving the highest possible rate of recycling and material recovery. Veolia manages high-performance sorting centers for non-hazardous industrial waste and waste from selective collections, which guarantee recovery rates of over 50%. The Group's research and development center developed TSA2, a patented process for industrial application that enhances the performance of sorting facilities and enables the production of high-quality secondary raw materials. Thanks to a remotely operated sorting procedure, it is now possible to refine the sorting process even further to achieve recovery rates of over 95%.

Waste-to-Energy Recovery

Non-hazardous waste that cannot be recycled is transported to incineration plants or landfill sites. The incineration process produces energy in the form of steam that can either be used to power urban or industrial heating networks or converted to energy using turbines. At landfill sites, Veolia captures biogas produced by the fermentation of organic waste. This biogas may then be fed directly into a distribution network, used to produce electricity with turbines or engines, or used as fuel for vehicles.

Hazardous Waste Processing

Veolia is a world leader in processing, recycling and recovering hazardous waste and decontaminating land. Depending on the source and composition of the hazardous waste it may be incinerated or processed using physiochemical or biological techniques at specialized facilities or stabilized and buried in special landfill sites. The Group has a worldwide network of experts and resources and a full range of technologies and services for processing difficult-to-treat effluents and hazardous waste, and for soil remediation.

Strategic Commitment

As part of the GreenUp 2024-2027 strategic program, Veolia has committed to treat 9 million metric tons of hazardous waste and pollutants by 2027, representing one of the three key "booster" growth areas alongside decarbonized local energy and water technologies.

Policies related to own workforce

Veolia's policies related to its own workforce are integrated within broader governance documents and strategic commitments. The company does not present standalone, named "workforce policies" but embeds workforce-related principles and commitments across several key documents and programs.

Ethics Guide

The Ethics Guide sets out the Group's core values and resulting rules of conduct that form the foundation of economic, social and environmental performance. The Guide covers:

Core values and principles:

• Responsibility: Promoting harmonious regional development, improving living conditions of populations, developing employee skills, and improving health and safety at work
• Community spirit: Developing solutions for essential services and ensuring compliance with the Code of conduct for managers

Scope: All Group employees

Public availability: The fundamental values and principles are set out in the Ethics Guide (referenced in section 4.1.4.1.2)

Link to international standards: The Ethics Guide reflects the Group's commitment to the United Nations Global Compact (joined in 2003), recognition of collective bargaining rights, and the fight against employment discrimination

Anti-corruption Code of conduct

The Anti-corruption Code of conduct was adopted by the Executive Committee in 2018 and constitutes the sole appendix to the Ethics Guide.

Key content:

• Absolute prohibition of any form of corruption and similar or equivalent behavior
• Compliance with best practice and regulations in the field of corruption prevention

Scope: All companies controlled directly or indirectly by Veolia, in France and all countries where they operate or are located, regardless of legal status

Governance and oversight: All zones and Business Units must deploy the Code in their respective areas

Implementation: In France and certain countries, implementation requires integration of the Code in the internal regulations of legal entities. Within Veolia Environnement, modified internal regulations entered into force on July 15, 2018. The Code was presented to the Works Council in France.

Public availability: The Code was presented in illustrated sketches showing corruption scenarios to help employees better understand the issues

Link to international standards: The Code is implemented within the context of adherence to the Global Compact and the Group's Ethics Guide

Human Rights Policy

Veolia has a formal Human Rights Policy documented in 2016.

Key content - Eight priority issues:

Three issues relating to rights of people impacted by activities:

• Right to a healthy environment and protection of resources
• Right to water and sanitation
• Rights and lifestyles of local communities

Five issues relating to fundamental labour rights:

• Elimination of forced labor
• Abolition of child labour
• Non-discrimination
• Freedom of association and collective bargaining
• Health and safety

Scope: All Group entities. Local entities are responsible for deployment and implementation

Governance and oversight:

• The Human Rights and Duty of Care Committee, chaired by the Group's General Counsel and led by the Compliance Department, is responsible for proper roll-out and monitors implementation of action plans
• The Committee met three times in 2024
• The Compliance Department performs its human rights role through a network of compliance officers covering the entire Group, coordinated by a human rights and duty of care manager

Link to international standards:

• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social and Cultural Rights
• Convention on the Rights of the Child
• United Nations Global Compact (joined 2003)
• United Nations Sustainable Development Goals
• ILO Declaration on Fundamental Principles and Rights at Work and ILO fundamental conventions
• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights

Monitoring: Social performance is integrated into managers' annual objectives and regularly reported to the Executive Committee

Diversity and Inclusion Policy

The Diversity and Inclusion Policy focuses on three fundamentals:

Key content:

• Guarantee fair and non-discriminatory HR and managerial practices from recruitment until end of careers
• Guarantee non-discriminatory access to employment (age, origin, disability, gender, sexual orientation, religion, etc.)
• Guarantee advancement of social dialogue and employee freedom of speech

Specific focus areas:

• Professional equality and gender diversity
• Disability inclusion
• LGBT+ inclusion (in regions without anti-LGBT+ legislation)
• Social and cultural diversity

Scope: All Group employees. In accordance with applicable local laws and regulations, Veolia does not permit, practice or support discrimination based on age, medical condition, sex, gender identity, sexual orientation, pregnancy, disability, ethnic origin, religion, political opinions, philosophical opinions, family status, morals, family name, trade union activities, place of residence, economic vulnerability, migrant status, or ethnic/national/racial belonging

Governance and oversight:

• Led by the Group's Human Resources Director (Executive Committee member)
• Deployed by the Group's Diversity, Inclusion and Engagement department
• Network of nearly 100 local diversity and inclusion coordinators and 36 local networks at end of 2024

Link to international standards:

• UN Global Compact
• International Labor Organization
• Partnerships with French Association of Diversity Managers (AFMD), À Compétences égales association, ANVIE, and Île-de-France LGBTQIA+ center
• ILO Convention No. 190 (referenced in sexism and sexual harassment mechanism)

Monitoring: Annual Diversity and Inclusion index from Voice of Resourcers employee survey (78 points out of 100 in 2024). Multiple metrics tracked including women employment rates, disability employment rates, age diversity, and training rates by gender and age

Public availability: A formal LGBT+ policy was documented in 2024 for presentation in first half of 2025

Finance Manager Code of Conduct

A finance manager Code of conduct was drawn up by the Chief Financial Officer in November 2011.

Key content:

• Finance managers report to both functional and line management
• Formal reiteration of responsibility and autonomy of finance managers in effective performance of operational control function

Updates: The Code was updated in 2018 to strengthen detection and prevention of corruption risk and signed again by all finance managers

Monitoring: Each year, the Financial Internal Control Department confirms the signatories are updated

Health and Safety Policy

While not described as a single named policy, the company has comprehensive health and safety commitments:

Key framework:

• Five Veolia Health & Safety pillars
• Ten fundamentals on health, safety and well-being at work (adopted via Group European Works Council resolutions in April 2024)
• Workplace accident prevention policy or management system
• Performance contracts drawn up in 2023 to help BUs roll out priorities and transform safety culture

Governance: Health and Safety Monitoring Committee of the European Works Council

Link to international standards: The health and safety resolutions are aligned with Group commitments and applicable to all entities in the Veolia European Works Council scope

Social Dialogue Agreements

Veolia has multiple collective agreements addressing workforce topics:

Group France Agreement (2020): Quality and development of social dialogue, including comprehensive support, promotion and recognition system for trade union scheme

Group France Agreement (2021): Working from home in normal times, defining company-wide scheme with same guiding principles throughout Group in France

Amendment (2021): Support for changes to skills and jobs, integrating the Diversity and Inclusion Policy. Follows priority actions identified by Group European Works Council working group

European Framework Resolutions (2024): Common draft resolutions on health, safety and well-being at work, comprising ten fundamentals and ten priority measures

Governance:

• Group France and European Works Councils review strategic directives annually
• Special Negotiation Group with 19 trade union representatives from 13 European countries working on Diversity and Inclusion framework agreement (launched June 2023)

Scope: 86.6% of Group employees covered by social dialogue body in 2024 (100% in France, 76.7% in countries outside European Economic Area). 8,382 employee representatives worldwide

Additional Policy Elements

Code of conduct for Securities Trading: Covers executive and director transactions, insider trading prevention

Whistleblowing system (Whispli): Open to employees and third parties for reporting violations including human rights, health and safety issues. Managed by Ethics Committee

Personal Data Protection: Guidelines and instructions ensure GDPR compliance, led by Global Data Protection Officer reporting to Group Compliance Director

Training Requirements:

• Mandatory e-learning on Anti-Corruption Code of Conduct and anticompetitive practices for all managers (38,259 employees trained in 2024)
• "No to sexism and sexual harassment" training available in 18 languages (made available to 42,000 employees, completed by close to 22,000 in 2024)
• Human Rights e-learning course (completed by over 40% of registered employees)
• Personal data protection awareness and mandatory training

Monitoring and Implementation:

• Compliance Department network of officers covering entire Group
• Human Rights and Duty of Care Committee oversight
• Integration of social performance into managers' annual objectives
• Regular reporting to Executive Committee
• Annual risk mapping updates
• Third-party assessments of suppliers on human rights criteria

Taking action on material impacts on own workforce

Diversity and Inclusion Policy

Scope: Own operations (Group-wide)

Time horizon: Long-term, aligned with GreenUp 2024-2027 strategic program

Description: Veolia's diversity and inclusion policy focuses on three fundamentals:

• Guarantee fair and non-discriminatory HR and managerial practices, from recruitment until the end of careers, for all employee categories
• Guarantee non-discriminatory access to employment in Veolia (age, origin, disability, gender, sexual orientation, religion, etc.)
• Guarantee the advancement of social dialogue and employee freedom of speech

The increase in the number of women on the Executive Committee is one of Veolia's multifaceted performance metrics under its GreenUp 2024-2027 strategic program.

Governance and Resources (non-financial):

• Led by the Group's Human Resources Director and a member of the ExCom
• Deployed by the Group's Diversity, Inclusion and Engagement department
• Global network of local diversity and inclusion coordinators (nearly 100 correspondents and 36 local diversity and inclusion networks at end of 2024)
• Eight meetings held with the network of correspondents in 2024, including one specifically on the results of the D&I index and another on the LGBT+ issue with expert participation
• Bi-weekly meetings where best practices are shared

Partnerships:

• UN Global Compact
• International Labor Organization
• French Association of Diversity Managers (AFMD)
• "À Compétences égales" association
• ANVIE
• Ile-de-France LGBTQIA+ center

Expected outcomes / KPIs:

• Professional equality: employment rate for women, percentage of women managers, percentage of women in management recruitment, percentage of women departures, percentage of women Executive Resourcers, percentage of women on Group company Boards of Directors
• Disability: employment rate for employees with disabilities
• Employment rate for employees over the age of 55
• Employment rate for employees under the age of 30
• Training rate by age and gender
• Annual Diversity and Inclusion index from Group engagement survey (78 points out of 100 in 2024)

Link to policy: Integral part of Veolia's Purpose and GreenUp 2024-2027 strategic program; based on Group values of respect and solidarity; aligned with "management behaviors@veolia" guide

Diversity and Inclusion Roadmap

Time horizon: Long-term (roadmap structured in 2022 based on inventory, work to identify practices began in 2024)

Four priority areas:

1. Diversity
2. LGBT+ people (in regions where there is no anti-LGBT+ legislation)
3. Disability
4. Social and cultural diversity

Description: Promote a culture of inclusion that guarantees each employee is treated without discrimination, recognized as an individual and is a full member of the company's collective system.

In 2024, work began to identify D&I practices in the Group. A digital and interactive notebook currently lists some 40 actions aimed at strengthening the Group's "Copy and Adapt" culture so that each entity can draw inspiration from existing actions.

Link to policy: Aligned with Group's overall D&I policy; structured around cross-functional approach and four priority areas

Entity-specific Action Plans

Scope: All Group entities

Actions required:

• Pursue the implementation of action plans promoting diversity and gender equality
• Develop and create inclusion programs for people with disabilities
• Develop and create inclusion programs for LGBT+ people in accordance with local legislation
• Develop and create action plans to promote social and cultural diversity

Characteristics of the undertaking's employees

Total headcount

As of December 31, 2024, Veolia employed 215,041 people worldwide.

Headcount by geographic zone

While the document confirms operations in 56 countries across five continents and employment of 215,041 people (see page 2, 22, 51), detailed breakdowns by region, gender, contract type, or employment type are not disclosed in the excerpted sections.

Employee turnover and new hires

No employee turnover rate, number of departures, or new hire metrics are disclosed in the excerpted sections.

Employee commitment

The document reports an employee commitment rate of 88% (page 2) and 89% (page 22, 24), though this is an engagement metric rather than a turnover metric.

Employee shareholding

The Sequoia 2024 employee shareholding operation is mentioned as successful (page 2), and employees are described as the Group's leading shareholder (page 22), but no quantitative participation rates or share ownership percentages are provided.

Multi-year comparison

No prior year headcount or FTE data are disclosed in the excerpted sections to enable year-over-year comparison.

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

Non-employee workers

As of December 31, 2024, the Veolia Group had 215,041 employees. In addition to the permanent and fixed-term contract workforce, Veolia reports on temporary staff, self-employed people, and subcontractors.

Full-time equivalent non-employees:

• The number of temporary and self-employed full-time equivalent employees is 13,759.

Coverage by health and safety management system

In 2024, Veolia's total workforce (employees, temporary workers and self-employed people) covered by a health and safety management system (ISO 45001, ILO OSH 2001 or equivalent) was 205,074 full-time equivalents (FTEs), or 95% of the Group's FTEs.

For entities that declare they are covered by a health and safety management system, the percentage of staff covered was 94.93% in 2024, including temporary workers and self-employed people.

Health and safety metrics for non-employees

Lost time injuries 2024

Fatalities 2024

In 2024, the Group suffered a total of thirteen deaths, including:

• 6 deaths among employees
• 7 deaths among subcontractors

Monitoring of subcontractors and temporary staff

Since 2018, the Group has been monitoring workplace accidents involving temporary staff and subcontractors in the same way as those involving its own employees. Subcontractors are approved on the basis of a scoring system, with the possibility of exclusion in the event of a serious breach.

These populations receive a special "safety induction" which explains the risks and hazards associated with their job, the prevention measures and the associated procedures.

Methodology

The workforce and all social data used by the Group come from a reporting tool, Global Report, which is supplied with information by each legal entity present in the global consolidation within the financial scope. This annual social reporting covers employees of the company and for certain metrics reported in the text, temporary staff, self-employed people and subcontractors.

The counting methodology uses full-time equivalent (FTE) for non-employee workers where specified, particularly for health and safety management system coverage.

France-specific initiatives for temporary workers

In France, meetings were held with temp agencies and several projects were rolled out:

• Creation of a temporary employment charter specifying the responsibilities of temp agencies and Veolia sites to better integrate temporary employees. Signed by the seven main temp agencies at the end of 2023, it was put into effect in 2024.
• Launch of a satisfaction survey on the health and safety of temporary employees who have worked during the year at Veolia. Results show a 92% satisfaction rate among respondents. Veolia's temporary staff awarded a score of 7.9/10 for well-being.

International framework contracts

Internationally, a working group led by the Group Procurement Department was appointed to create two initial global framework contracts and a charter for temporaries by the end of 2025. The contracts will be rolled out across the entire scope of consolidation by 2027.

Collective bargaining coverage and social dialogue

Coverage by social dialogue body

In 2024, 86.6% of Group employees were covered by a social dialogue body on the basis of a company agreement, a collective agreement, a national agreement or a branch agreement.

Geographic breakdown:

• France: 100%
• Countries outside the European Economic Area: 76.7%

Employee representatives

At Group level, there were 8,382 employee representatives worldwide.

European Works Council

The Group European Works Council represents about two-thirds of Veolia employees. It is made up of 17 countries: Belgium, Bulgaria, Czech Republic, Denmark, France, Germany, Hungary, Ireland, Italy, Luxembourg, Netherlands, Poland, Portugal, Romania, Slovakia, Spain, United Kingdom.

Collective bargaining agreements

In 2024, 1,577 new collective agreements were signed at entity or company level or with Group bodies in each country. All of these collective agreements impact the undertaking's human resources performance and therefore economic performance.

The agreements have been signed in 41 countries where Veolia operates. The five main countries are France, Japan, Spain, Germany and Brazil.

Share of labor agreements by theme (2024): Signed labor agreements relating to prevention, health and safety represented 12.1% of agreements in 2024.

Directors representing employees

Two directors representing employees were appointed in 2014 by the Group French and European Works Councils, respectively, to sit on the Veolia Environnement parent company Board of Directors for four years:

• Mr. Pavel Páša was reappointed by the Group European Works Council in May 2018
• Mr. Franck Le Roux was elected by the Group French Works Council in September 2018

Their terms were renewed in 2022 for another four years and will expire on October 15, 2026.

Mr. Enric Amiguet i Rovira, a director representing employees on the Suez Board of Directors, was appointed as a non-voting member of the Veolia Environnement Board of Directors in 2022.

Social dialogue governance

An agreement was signed in the form of a letter of commitment with the Group European Works Council in 2018 (with an amendment signed in 2021), on changes in the businesses and skills, notably with regard to the Company's strategic direction.

Since 2015, management meets annually with members of the Group French and European Works Councils to discuss the Group's strategic direction and its human resource impacts.

Multi-employer pension plans

Approximately 4,000 employees in 2024 are covered by multi-employer defined benefit pension plans, mainly located in Germany and the United States. These plans are recorded as defined contribution plans in accordance with IAS 19. The corresponding expense totaled €8 million in 2024 compared with €9 million in 2023.

Diversity metrics

Gender split at top management level

Board of Directors:

• Female representation on the Board of Directors: 54.5% (2024), 54.5% (2023), 60.0% (2022)

Executive Committee: The document references commitments to increase women on the Executive Committee as part of GreenUp strategic program multifaceted performance metrics, but specific Executive Committee gender split percentages are not disclosed.

Management roles (broader):

• Female representation rate (management roles): 31.3% (2024), 31.0% (2023), 30.0% (2022), 29.0% (2021), 28.3% (2020)

Gender split - general workforce

Note: Male percentages calculated as complement to female percentages. No "other" gender category disclosed.

Gender pay gap

In 2024, the average gross compensation of men was €42,147 and €39,843 for women, a difference of €2,304 (-5.46%). This compensation includes base salary, paid leave allowances, possible 13th month payments, bonuses and overtime.

The annual average gross compensation for all Group employees was €41,651 in 2024.

Age band distribution of total workforce

Employees aged 30 to 49 inclusive constitute 109,499 employees, or 50.9% of the total.

Employees under 30 constitute 28,444 employees, or 13.2% of the total number of employees at the end of the year.

Employees aged 50 and over (by calculation): 35.9% of the total.

Age band breakdown by percentages (extracted from visual data):

• < 20 years: 0.1% (2024), 0.4% (implied earlier period)
• 20-24 years: 1.1% (2024), 3.1% (implied earlier period)
• Workforce under 30: 13.2%
• Workforce 30-49: 50.9%
• Workforce 50+: ~36% (by calculation)

Other diversity metrics

Employees over 55:

• Employment rate for employees over the age of 55: monitored but specific percentage not disclosed

Employees under 30:

• Employment rate for employees under the age of 30: 13.2% (2024)

Persons with disabilities:

• Disability employment rate: monitored but specific percentage not disclosed

Workforce composition (December 31, 2024):

• Total headcount: 215,041
• Permanent contracts (FTE): 94.9% (2024), 94.6% (2023), 93.3% (2022)
• Non-management positions: 81.6% (2024), 82.4% (2023), 83.2% (2022)

Professional equality index (France)

The male/female professional equality index for Veolia entities in France published in March 2024 achieved an overall index of 89/100, with most entities above 75/100 (legal minimum).

Adequate wages

Benchmark approach

Veolia applies a two-tier approach to adequate wages:

1. Primary benchmark: Statutory minimum wage / collective bargaining agreements

Veolia states: "Veolia has used the statutory minimum wages or the local minimum wages established by the most relevant collective agreements as the adequate reference wage whenever possible."

The company ensures:

• Compliance with legislation in force (minimum wage, overtime, etc.)
• Base salaries, particularly for blue collar workers (50% of workforce), are "systematically above national minimums or minimum wages paid on the labor market for a given job"

Coverage: Countries where a reference wage can be determined have no employees earning below the reference wage. However, for 5 countries representing less than 1% of the Group's employees, reference wages do not exist or are not applicable (e.g., for reasons of nationality). For these countries, "it was not possible to demonstrate that all employees were paid above an adequate wage."

2. Living wage pilot scheme (launched as part of ESG policy)

Veolia launched a pilot scheme on living wages in six countries representing a significant proportion of the workforce, covering all main operating regions:

• France
• United States
• United Kingdom
• Japan
• Colombia
• Poland

Definition: "The Group considers living wage to be the minimum income that enables employees to cover their basic needs and those of their families, and to enjoy a decent standard of living. It can therefore be different from the country's minimum wage."

Status: Work started at the end of 2023, but "it is still not possible to report the results. A further and more detailed study is to be conducted in 2025."

Target and commitment

2025 commitment: "In 2025, additional research will be carried out to determine reference wages for these countries [the 5 countries <1% of workforce] on the basis of a benchmark."

2025 commitment: Further and more detailed study on the living wage pilot to be conducted in 2025.

Additional context

Gender pay gap: Average gross compensation in 2024 was €41,651 overall (€42,147 for men, €39,843 for women, a difference of -5.46%).

Fairness ratio: The ratio between CEO total remuneration and average employee pay is 60.

Policy principle: "Veolia's policy, implemented by the Group Senior Executive Vice President for Human Resources, is to respect wage equality between men and women who have the same employment conditions and qualifications. For this purpose, the Group is particularly vigilant regarding the application of a fair wage policy."

Social protection

Veolia Cares program

Veolia has implemented a comprehensive social protection program called Veolia Cares, launched in 2022 and fully deployed across all regions as of September 1, 2023. This program establishes a minimum social protection floor for all Group employees worldwide.

Coverage pillars

The Veolia Cares program is based on five pillars providing coverage for major life events:

1. Parental leave: Base salary maintained over ten weeks for the first parent, and over one week for the second parent. This measure can also be used in the event of adoption.

2. Death cover: Capital equivalent to at least six months of salary is paid to beneficiaries, whatever the cause of death.

3. Health cover: Guaranteed access to medical care for all employees, whatever the local organizational methods (legal life insurance and corporate schemes).

4. Support for employee carers: All employees who are carers are given the necessary flexibility in the organization of working time.

5. Community charity work: Possibility for each employee to devote one paid day-off per year to a charity or environmental protection organization in line with Group values.

Program characteristics

• Coverage: Applies to all Group employees, without gender discrimination, and whatever their status from the first day of recruitment
• Type of schemes: Combination of public schemes and private/corporate schemes depending on local context
• Scope: 100% of employees entitled to coverage

Impact measurement (September 1, 2023 to August 31, 2024)

Additional social protection measures (France)

As of January 1, 2024, two additional measures were implemented in France:

1. Extended death cover for professional accidents: Previously limited to executives, coverage now extends to non-executives with payment of 2.5 years of wages to beneficiaries.

2. Return-to-work support program: Dedicated service provider assists employees returning from long-term illness to resume professional activity. Coverage extends to 2/3 of Veolia employees in France as of 2024, with full extension planned for January 1, 2025.

Supplementary social protection plans

Executive officers

Both the Chairman of the Board of Directors and the Chief Executive Officer benefit from:

• Collective healthcare and insurance plan in force within the Company
• Supplementary defined contribution group pension plan applicable since July 1, 2014
• Coverage under the same conditions as the employee category with which they are assimilated for social benefits

Pension commitments

As of December 31, 2024, pension obligations and related benefits (in € million):

Note: Obligations net of plan assets. Includes €2 million for Executive Committee members.

Actuarial assumptions (December 31, 2024):

• Discount rate: 3.60%
• Inflation rate: 2.00%

Work-life balance coverage

Methodology notes

• Veolia Cares coverage applies from the first day of recruitment for all employees regardless of status or geography
• Impact measurement for the Veolia Cares program covers the period September 1, 2023 to August 31, 2024
• Pension obligations are recognized per French Commercial Code Article L. 123-13, with details presented in off-balance sheet commitments
• The DDADUE Act of April 22, 2024 concerning entitlement to paid leave accrued during sick leave periods has been implemented

Persons with disabilities

Policy commitment

The Group has renewed its commitment to be a more diverse and inclusive undertaking, ensuring non-discrimination, equal opportunities and individual social promotion for all employees. Veolia's diversity and inclusion policy includes:

• Develop and create inclusion programs for people with disabilities
• Guarantee non-discriminatory access to employment in Veolia (age, origin, disability, gender, sexual orientation, religion, etc.)

The Diversity and Inclusion Policy is led by the Group's Human Resources Director and deployed by the Group's Diversity, Inclusion and Engagement department, which relies on a global network of local diversity and inclusion coordinators.

Metrics

Employment and social integration of people with disabilities

At the end of 2024, 2.1% of Veolia employees worldwide had disabilities, i.e. 4,303 employees.

Methodology

Definition: Number of employees with declared disabilities compared to the total workforce as of 12/31 in countries where it is possible to declare disability (excluding subcontractors and the sheltered sector).

Scope limitations: The metric is calculated only in countries where it is possible to declare disability status.

Training and skills development metrics

Overall training hours

In 2024, the Group delivered 30.5 training hours per employee, compared with 29 hours in 2023, i.e. a 1.5-hour increase per employee. This result exceeds the objective set by Veolia at the end of 2027, which is 30 hours. This consists of business, health and safety and soft skills training.

Training hours by gender

Health and safety training

In 2024, 174,596 Veolia employees received health and safety training, or 81% of the total FTE workforce. 2,578,796 hours of training were spent on health and safety, or 41.8% of the total training hours. Each year, Veolia aims to spend more than ten hours of health and safety training per employee per year. In 2024, this figure was 12.7 hours per employee in FTE.

Performance and career development reviews

A single annual interview process, One Form, is used for all managers at sites worldwide. The Group encourages the extension of this practice to non-managerial employees, for whom the Business Units adapt the form. In 2023, the annual executive interview form was modernized.

Following the optimized ergonomics proposed in 2022, the basic structure and reasoning behind the annual interview were questioned to provide a more tailored response to the expectations of the operational entities. The current version promotes dialogue between employees and management, while limiting data entry requirements.

Active training users

These actions have resulted in more than 86,500 active users (users who have logged in to Learning@Veolia at least once a year) and around 20,000 employees having taken at least one course provided by partner LinkedIn Learning.

Management and leadership programs

In 2024, more than 2,000 managers and executives attended a Group management or leadership training program.

More than 6,916 managers (including 883 members of executive committees), 517 safety coaches and 90 internal facilitators were trained in various BUs for OHS Leadership program.

Employee perception

In 2024, within the Voice of Resourcers survey, 84% of employees surveyed felt that they had strengthened their skills.

Group target

The Group has set itself a target for 2027: to deliver 30 hours of training per employee.

Health and safety metrics

Lost time injury frequency rate (LTIFR) - GreenUp strategic indicator

Comprehensive health and safety metrics (2024)

Coverage by health and safety management system

In 2024, Veolia's total workforce (employees, temporary workers and self-employed people) covered by a health and safety management system (ISO 45001, ILO OSH 2001 or equivalent) was 205,074 full-time equivalents (FTEs), representing 95% of the Group's FTEs (94.93% including temporary workers and self-employed people).

Methodology notes

Fatality breakdown (2024):

• 6 employee deaths: 4 process-related (2 working at height, 2 internal driving), 1 driving accident, 1 employee posted as temporary worker to third company
• 7 subcontractor deaths: 6 process-related (1 working at height, 4 explosion, 1 internal driving), 1 driving accident

Severity rate calculation: For fatal accidents, the number of days lost is estimated at 365 working days (one full year), representing the time needed for organizational adaptation, recruitment, training and familiarization.

Scope: LTIFR and severity rates exclude commuting accidents. Occupational diseases data may vary due to differences in local practices and regulations across countries.

Work-life balance metrics

Entitlement and uptake of family-related leave

Veolia Cares program implementation (September 1, 2023 to August 31, 2024)

The Veolia Cares program includes parental leave provisions:

• Parental leave (first parent/maternity): base salary maintained over ten weeks
• Parental leave (second parent/paternity): base salary maintained over one week
• These measures can also be used in the event of adoption

Impact measurement of Veolia Cares parental leave benefits:

• Of 1,683 employees who went on maternity (or first parent) leave, 248 (15%) saw an improvement in the benefit guaranteed by Veolia (ten weeks on the full base salary)
• Of 4,086 employees who went on paternity (or second parent) leave, 836 (20%) saw an improvement in the benefit guaranteed by Veolia (one week on full base salary)

Work-life balance satisfaction

According to the Voice of Resourcers 2024 survey, 81% of employees are satisfied with their work/life balance.

Veolia has set targets by 2027 to:

• Achieve and maintain a work-life balance satisfaction rate above 80% (percentage of employees with a score above 6/10) in the Voice of Resourcers survey

Part-time employment

The number of part-time employees in 2024 was 6.4% (6.1% in 2023).

Working time

• Average working week: 40 hours (following ILO recommendations)
• Total overtime hours worked: 18,912,478
• Average overtime per employee: 93 hours per year
• Maximum working time recorded: 48 hours per week (depending on local legislation)

Note: The definition of overtime varies from country to country. In service business, a large number of overtime hours are due to emergency work performed by on-call or on-site personnel.

Work organization flexibility

31% of collective agreements signed in 2024 relate to the organization and working time.

The Group has introduced working from home in several Business Units for jobs where this is possible. In France, a framework agreement was negotiated in 2021 defining the terms and conditions for working from home.

Compensation metrics

Pay gap

Gender pay gap (unadjusted)

In 2024, the average gross compensation of men was €42,147 and €39,843 for women, a difference of €2,304 (-5.46%). This compensation includes base salary, paid leave allowances, possible 13th month payments, bonuses and overtime.

This difference is mainly due to the distribution of men and women between different jobs. These averages are only indicative, however, and should be interpreted with an element of caution. They correspond to a wide diversity of situations due to the nature of the professions and jobs carried out and their geographic location. These values, converted into euro, are also impacted by fluctuations in exchange rates.

It is Veolia policy to respect equality between men and women who have the same employment conditions and qualifications. For this purpose, the Group is particularly vigilant regarding the application of a fair wage policy.

Remuneration ratio

CEO-to-median employee compensation ratio (France)

(1) The separation of duties on July 1, 2022 led to fairness ratios being calculated for only a portion of 2022 (fixed compensation allocated between Chairman and Chief Executive Officer and Chief Executive Officer) and 2023 (variable compensation for 2022 allocated between Chairman and Chief Executive Officer and Chief Executive Officer). The "Executive corporate officer" consolidation provides a comprehensive view.

CEO-to-average employee compensation ratio (France)

CEO total compensation statement

The ratio measuring the gap between the total remuneration paid to the Chief Executive Officer and the average pay of Veolia employees is 60.

Methodology

Gender pay gap: The annual average gross compensation for all Group employees was €41,651 in 2024. Calculations include base salary, paid leave allowances, possible 13th month payments, bonuses and overtime.

Remuneration ratios: Presented for France only. The separation of Chairman and CEO roles on July 1, 2022 impacts comparability for 2022-2023. Both median and average employee compensation ratios are disclosed.

Policies related to value chain workers

The excerpts provided do not contain specific details about policies related to value chain workers. The document indicates that ESRS S2-1 (Policies related to value chain workers) is addressed in section 4.1.3.2.2 titled "Responsible supply chain management", however the actual content of that section is not included in the excerpts.

The excerpts show cross-references to regulatory requirements:

• Human rights policy commitments (paragraph 17)
• Policies related to value chain workers (paragraph 18)
• References to UNGPs on Business and Human Rights principles and OECD guidelines (paragraph 19)
• References to due diligence policies on issues addressed by fundamental International Labour Organisation Conventions 1 to 8 (paragraph 19)

However, no specific policy names, scope, governance structures, key content, public availability, or monitoring approaches for value chain worker policies are disclosed in the provided excerpts.

Taking action on material impacts on value chain workers

Sustainable Procurement Policy

Veolia has implemented a sustainable procurement policy aimed at preventing serious incidents within its supply chain and promoting positive ethical, environmental, social and societal practices among suppliers and subcontractors.

Scope: Upstream value chain (suppliers and subcontractors, including tier 1 and indirectly beyond)

Key components:

• Supplier Charter "Our General Principle for Suppliers Relationship": Sent during consultations and signed by third parties, available at veolia.com. The Charter commits suppliers to:

  • Respecting fundamental principles of the International Labour Organization and UN Global Compact
  • Complying with the Universal Declaration of Human Rights and UN Convention on the Rights of the Child
  • Complying with ethical, social and labour law requirements, particularly all applicable mandatory labour law regulations and ILO conventions: concealed employment, child labour, forced labour, etc.
  • Applying these principles in their own supply chain
  • Eco-design of products and services
  • Environmental management systems

• Implementation mechanisms:

  • Integration of the charter into supplier contracts
  • Regular supplier assessments through annual evaluation campaigns at Group level
  • Corrective action plans in the event of non-compliance
  • Alert mechanism for reporting violations
  • Two points of contact for employees of Group suppliers to report incidents

• Inclusive procurement: Actions deployed worldwide adapted to local context, with specific metric monitoring for France

Governance and resources (non-financial):

• Under the responsibility of Veolia's Deputy Chief Executive Officer Finance and Procurement (member of the Executive Committee)
• Central team running a network of about fifty "sustainable procurement ambassadors"
• Platform for evaluating suppliers and subcontractors
• Additional resources (tools/data/audits) deployed to adapt the system to regulatory developments

Risk management approach:

• Comprehensive mapping of suppliers' CSR risks cross-referencing:
  • Procurement criteria (expenditure weight, strategic dimension)
  • CSR topics including environment (energy consumption, GHG emissions, water, etc.)
• Consistent approach to incidents affecting workers in the supply chain
• Not restrictive on specific typology of suppliers or subcontractors

Note: The actions described under this standard are recurrent. Human rights aspects are detailed in section 4.1.3.5.

Policies related to affected communities

The excerpts provided reference ESRS S3-1 (Policies related to affected communities) and indicate that the relevant content is located in section 4.1.3.3.2 titled "A Group committed to the regions and local communities."

However, the actual content of section 4.1.3.3.2 is not included in the excerpts provided. The table of contents shows that S3-1 maps to this section, but the policy details themselves are not disclosed in the excerpts.

Additionally, the excerpts reference human rights policy commitments in the context of SFDR alignment (ESRS S3-1 paragraph 16 and 17 referencing human rights policy commitments and non-respect of UNGPs, ILO principles, or OECD guidelines), but do not provide the actual policy names, scope, governance, or other required details.

Without access to the full section 4.1.3.3.2, the specific policies related to affected communities cannot be identified or described.

Policies related to consumers and end-users

Veolia's CSRD sustainability statement contains a cross-reference table indicating that ESRS S4-1 (Policies related to consumers and end-users) is addressed in section "4.1.3.4.2 Services provided to consumers / A customer relationship management policy focused on listening to end-consumers". However, the excerpts provided do not contain the actual content of that section.

The excerpts include extensive content on personal data protection policies and lobbying policies, but these relate primarily to ESRS G1 (Business conduct) rather than ESRS S4-1 specifically.

Based on the available excerpts, no specific named policy relating to consumers and end-users (as required by ESRS S4-1) is disclosed in sufficient detail to extract policy name, scope, governance, principles, public availability, links to international standards, or monitoring mechanisms.

The company appears to have a customer relationship management policy focused on listening to end-consumers (as indicated in the cross-reference table), but the policy details are not included in the provided excerpts.

Business conduct policies and corporate culture

Purpose of the Company

Veolia was one of the first French groups to define its purpose, adopted by its Board of Directors in April 2019. The Group's purpose was drawn up in consultation with its various stakeholders and approved by the Board of Directors, and articulates why Veolia exists and what it does and how, for the benefit of all its stakeholders.

The purpose states the fundamental way in which Veolia will act. It is both the direction in which the Group is heading and a means to show the extent of its ambition and to give its actions a firmer long-term foundation.

Veolia's Purpose: "Ecological transformation means acting to reconcile human progress and environmental protection.

We develop and implement locally solutions to depollute vital resources and preserve them from depletion, solutions to decarbonise our ways of living and producing and adapt them to the consequences of climate change.

All over the world, attuned to local cultures, we strive to improve the health and quality of life of communities.

At Veolia, we tackle economic, social and environmental issues as an inseparable whole to the benefit of the largest number of people."

Multifaceted Performance Framework

Veolia has committed to a multifaceted performance which takes into account the economic and financial, commercial, human resources, corporate social and environmental performance. Under the 2024-2027 GreenUp strategic program, 15 progress objectives were defined for 2027.

This commitment is broken down in all Group processes, so that the multifaceted performance objectives drive the management of activities. The related progress indicators are regularly audited and measured by independent third-party bodies and are included in the calculation of Veolia senior executive variable compensation.

Ethics and Integrity

2024 Results:

• Ethics and integrity metric: 86% of respondents to the Voice of Resources survey positively answered the question "Does Veolia act ethically in my country and satisfy compliance rules in its activities?"
• The result remains solid, but slightly below the 2023 reference (88%) due to drops in positive answers from some Business Units: Japan (-13 pts), Bulgaria (-10 pts), Nordic countries (-9 pts), RVD (-4 pts)
• 2027 Target: ≥ 83% positive responses

Governance Structure

Board of Directors Composition (as of December 31, 2024):

• 14 Directors and 1 Non-voting member
• Average age: 62 years
• Gender diversity: 54.5% female directors (excluding employee representatives)
• Independence: 64% independence rate (excluding employee representatives)
• International representation: 5 non-French directors
• Employee representation: 2 employee directors and 1 director representing employee shareholders

Skills Matrix of Directors:

• CSR expertise: 14 directors
• Experience in Veolia's businesses: 11 directors
• International experience: 11 directors
• Public affairs: 11 directors
• Bank Finance: 10 directors
• Digital: 6 directors
• R&D: 8 directors
• Industry: 7 directors

Board Committees:

1. Accounts and Audit Committee: 5 members, 100% independent, 95% attendance
2. Nominations Committee: 4 members, 50% independent, 100% attendance
3. Compensation Committee: 6 members, 60% independent, 79% attendance
4. Research, Innovation and Sustainable Development Committee: 5 members, 50% independent, 100% attendance
5. Purpose of the Company Committee: 7 members, 80% independent, 100% attendance

Management Structure

Executive Committee Composition:

• Chief Executive Officer: Estelle Brachlianoff
• Deputy CEO Finance and Purchasing: Emmanuelle Menning
• Chief Legal Officer: Éric Haza
• Multiple Senior Executive Vice Presidents covering different geographic regions and business areas

Corporate Culture and Values

Veolia's corporate culture is anchored in its Purpose and multifaceted performance approach. The company emphasizes:

• Usefulness: All projects prioritize usefulness for long-term prosperity
• Ecological transformation: Focus on solutions that decarbonize, depollute and regenerate resources
• Stakeholder value creation: Commitment to creating value for all stakeholders including customers, employees, communities, and shareholders
• Local adaptation: Solutions attuned to local cultures while maintaining global standards
• Employee engagement: 88% employee engagement rate in 2024, maintaining excellence above the 85% target

Management of Purpose Implementation

From creation to implementation, Veolia's Purpose has been supported and steered at the Company's highest level:

• Board oversight: Board of Directors validates Purpose objectives and monitors performance through the Purpose Committee
• Executive management: Group Executive Committee and Management Committee directly monitor implementation
• Steering structure: Purpose steering committee monitors progress and proposes new actions
• External validation: Critical Friends Committee of independent experts provides regular input
• Local implementation: Network of Purpose Officers in Business Units supports local teams
• Employee mobilization: Employees engaged through internal networks and special events

Fifteen metrics relating to multifaceted performance objectives are included in the remuneration of at least 16,000 Group managers to unite all employees around this ambition.

Incidents of corruption or bribery

Confirmed incidents

In fiscal year 2024, the Veolia Group was not convicted of violating anticorruption and anti-bribery laws.

Convictions and fines

No convictions or fines for violations of anti-corruption/anti-bribery laws are reported for 2024.

Whistleblowing and investigation procedures

Veolia operates a global whistleblowing system (Whispli) available 24/7 in multiple languages, accessible to both employees and third parties. The system is managed by an independent Ethics Committee and allows whistleblowers to remain anonymous if they wish.

In 2024, the Ethics Committee received 84 total alerts through the internal whistleblowing system relating to duty of care matters, broken down as follows:

• Human rights: 33
• Health and safety: 37
• Environmental damage: 2
• Suppliers and subcontractors: 12

Alerts that appear to have compliance content (including corruption, fraud, anti-competitive practices, or serious breaches of legislation) are immediately forwarded to the Compliance Department for investigation. Investigations are conducted by the Ethics Committee or its network of over 50 country ethics delegates, who act independently and confidentially.

The Group conducts mandatory e-learning on anti-corruption for functions at risk. In 2024, 38,259 employees (100% of all functions-at-risk) completed anti-corruption training.

Supplier relationships and third-party assessment

Veolia includes specific sustainable development and anti-corruption clauses in contracts with suppliers and subcontractors. The Group evaluates strategic and high-risk suppliers using EcoVadis assessments covering 21 criteria including ethical issues such as corruption. Nearly 130 entities across the Group were ISO 37001 certified (anti-corruption management systems) in 2024.

No convictions for human rights breaches

In fiscal year 2024, Veolia was not convicted of breaching human rights laws, including in connection with its tier 1 suppliers.

Political influence and lobbying activities

Political engagement approach

Veolia actively contributes to discussions, consultations and projects on changes in environmental services management initiated by international, European and French authorities, professional associations, think tanks and NGOs.

Pursuant to applicable regulations, these actions are implemented in the context of its adherence to the Global Compact and within the general framework of the Group's Ethics Guide and in accordance with its Anti-Corruption Code of conduct.

Ethical standards and guidelines

In June 2019, Veolia issued an internal standard on the appropriate conduct of employees who are members of professional associations or participate therein. This procedure aims to ensure that lobbying is performed to the highest prevailing standards.

In accordance with strengthened reporting obligations in France and the extension of the system to include activities conducted with certain local public decision-makers that came into force in July 2022, Veolia adapted its internal system to satisfy its legal obligations in this area. In 2023, the Group expanded its reporting requirements to fully comply with the strengthened reporting framework.

Similarly, lobbying employees (or employees likely to lobby) have been made aware of the two objectives of respecting ethics rules and the duty to declare, in coordination with the Group Compliance Department.

Through these rules and initiatives, the Group is formally committed to adhering and ensuring adherence to the rules adopted by the various countries and institutions to guarantee transparency and compliance for lobbying actions.

Political contributions

In addition, political contributions are prohibited within Veolia. Veolia therefore made no financial or in-kind political contributions during the 2024 financial year.

Transparency register memberships

Veolia Environnement is listed on several transparency registers, including:

• the transparency register, the European Commission and European Parliament register of lobbyists (since 2009);
• the lobbying disclosure register in the United States;
• the public digital directory managed by the High Authority for public transparency (HATVP) in France. The Group is also registered in the Senate register in France, which records lobbyists on its own list.

Payment practices

Disclosure status

Veolia has not disclosed key performance indicators concerning payment practices for the 2024 fiscal year. The company states:

"Veolia needs the conclusions of the Procure to Pay project, specifically regarding the measurement of payment practice performance, before publishing information on this matter. Therefore, for the 2024 fiscal year, Veolia has not disclosed any key performance indicators concerning:

• The average number of days to pay an invoice from the start date of the contractual or legal term of payment;
• The percentage of payments that comply with the standard payment terms;
• The number of legal proceedings pending for late payment."

Internal policy framework

Veolia maintains a Group internal policy on the "Procurement" process, implemented locally in each country, which aims to:

• Disseminate best practices
• Streamline the process to ensure payment of invoices within contracted deadlines
• Comply with local regulations in each country
• Control risks

Implemented measures include:

• Improving relations and communications with suppliers with access to information relating to their invoices
• Tools for digitizing supplier invoices
• Regular payment campaigns to reduce processing times
• Monitoring and prioritization of suppliers' aging balance

Ongoing project

A "procure to pay" project has been launched to help measure supplier payment performance, with action plans including:

• Obtaining data for the main business units by the end of 2025, representing a majority share of the Group's expenses
• Covering 80% of expenditure by fiscal year 2026

Standard contractual payment terms

Reference settlement periods applied (contractual or statutory):

• For invoices received: Generally 45 days from the end of the invoice month and 30 days from the invoice date
• For invoices issued: Generally 45 days from the end of the invoice month

Risk identification

Counterparty risk related to operating activities includes potential effects of:

• Non-payment or late payment by customers
• Economic balance of contracts compromised

Internal control framework ensures compliance with Group policies.