Vidrala

The role of the administrative, management and supervisory bodies

Composition of the Board of Directors

Vidrala's Board of Directors comprises 11 non-executive members:

• Carlos Delclaux Zulueta – Non-executive Chairman of the Board since 2002. With experience in banking and the glass industry, he has held executive positions at BBVA and various industrial and financial companies.

• Fernando Gumuzio Iñíguez de Onzoño – Independent Director since 2019. Founder of Grupo Azora, with experience in asset management, private banking, and energy.

• Aitor Salegui Escolano – Non-executive Director since 2008, representing Addvalia Capital, S.A. With experience in logistics and operations, he was COO of DHL Iberia.

• Eduardo Zavala Ortiz de la Torre – Non-executive Director since 2005. CEO of Workcenter and founder of several businesses.

• Gillian Anne Watson – Non-executive Director with experience in finance, energy, and healthcare. CEO of Noble & Co.

• Inés Andrade Moreno – Non-executive Director with extensive experience in investment banking and asset management. Partner at Altamar CAM Partners and Chairwoman of the "Client Solutions" division.

• Iñigo Errandonea Delclaux – Non-executive Director with a background in auditing and corporate banking.

• Luis Delclaux Muller – Non-executive Director with experience in financial control, investment, and renewable energy development.

• Ramón Delclaux de la Sota – Non-executive Director and member of the Strategy Committee. With over 25 years of experience in corporate banking, capital markets, and digital transformation at BBVA.

• Rita Maria de Noronha e Melo Santos Gallo – Non-executive Director representing NORONHA GALLO S.à.r.l. Expert in marketing.

• Virginia Urigüen Villalba – Non-executive Director with experience in business internationalisation.

Gender diversity: 36% female representation

Independence: 27% are independent Board members

All members are non-executive, with 0 executive members.

Board Committees

Vidrala has established three Board committees:

Audit and Compliance Committee

Responsible for:

• Supervising the effectiveness of internal control and risk management systems
• Overseeing the process of preparing and presenting financial information
• Managing the relationship with the external auditor
• Reviewing the Risk Management System
• Identifying, preventing, obstructing, and reporting any operations involving criminal acts or fraud

The Committee operates independently and is presided by an independent director.

Nomination and Remuneration Committee

Responsible for:

• Evaluating the necessary competencies in the Board of Directors
• Reporting on proposals for the appointment of directors and senior managers
• Defining their remuneration policy
• Examining succession plans
• Assessing the annual performance of sustainability-related KPIs tied to incentive schemes

This Committee is presided by an independent director.

Strategy and Development Committee

Responsible for:

• Assessing strategic initiatives, such as potential investments, divestitures or growth opportunities

Sustainability Governance Framework

Sustainability Committee

Vidrala has established a Sustainability Committee that ensures a structured and strategic approach to ESG topics. The Committee comprises:

• Members of the Executive Committee
• Representatives from functional areas: Human Resources, Health and Safety, Environment, Finance, Procurement, Technical, and Communications & Marketing

Responsibilities:

• Monitoring progress against sustainability objectives
• Proposing new actions in sustainability
• Integrating periodic updates to analyse environmental and social dependencies, risks, and opportunities
• Developing and implementing different line actions related to sustainability strategy, including the climate transition plan
• Reporting quarterly to the Board

Meeting frequency: The Committee meets regularly, with quarterly reporting to the Board of Directors.

Working Groups

In 2024, Vidrala launched a new working group dedicated to:

• Analysing the EU taxonomy
• Overseeing capital expenditure (CAPEX)
• Evaluating investment proposals
• Identifying associated risks and opportunities
• Providing recommendations to optimise sustainable investment strategies

Sustainability Expertise and Training

The Board maintains robust sustainability competencies through several key mechanisms:

• Regular consultations with an internal, permanent working group of environmental experts
• Ongoing engagement with external stakeholders and specialists on environmental issues
• Integration of environmental knowledge into the board nominating process
• Continuous training on environmental topics, industry best practices, and relevant standards such as TCFD and SBTi

Directors receive continuous training on environmental topics, ensuring that the board remains well-equipped to oversee the sustainability strategy.

In 2024, Vidrala offered a total of 10 hours of training to the Board and the Executive Committee related to specific critical risks or updating of the legislation, covering 100% of people at-risk functions.

Specific Sustainability Roles

Sustainability Director:

• Responsible for day-to-day strategy building, goal setting, execution, and progress of all 4Ps related performance metrics (People, Place, Planet and Prosperity)
• Has management responsibility for climate-related issues, including sustainability initiatives, targets, and disclosure of emissions annually
• Provides information on fiscal policies and criteria applied to the Board of Directors through the Audit and Compliance Committee

Executive Committee:

• Advises on the 4Ps sustainability strategy
• Monitors progress against this strategy
• Responsible for the overarching approval of the strategy
• The Group's top climate-related risks and opportunities are reported to the Board through its delegated Audit Committee at least annually

Supporting Teams:

• Human Resources (HR), Health and Safety Executive (HSE) and Environmental teams bring a broad spectrum of experience to ensuring the sustainability strategy is fit for the future
• Support the achievement of 4Ps targets

Oversight of Sustainability Matters

Board of Directors:

• Ultimately accountable for performance against the Group's sustainability targets and goals
• Led by non-executive chairman, separate from the Chief Executive Officer, to ensure the separation of powers
• Assumes among its powers the supervision of the fiscal strategy
• Periodically reviews the Risk Management System and analyses those that may be more relevant, resulting in specific policies or actions for their monitoring and mitigation

Audit and Compliance Committee:

• Receives information on the fiscal policies and criteria applied and reporting on tax consequences when they are a relevant factor
• Reviews and endorses materiality assessment findings
• Clearly documents the ownership of risks, as well as the various controls and actions taken to mitigate and adapt to climate-related risks and opportunities

Integration of Sustainability in Decision-Making

Throughout 2024, Vidrala's Executive Committee has been actively involved in sustainability discussions through:

• Participation in Sustainability Committee meetings
• Dedicated sessions on specific topics regarding internal sustainability workstreams

These engagements have been instrumental in driving the double materiality assessment process, allowing the integration of expertise and sector-specific insights into the evaluation of sustainability-related risks and opportunities.

As a result, Vidrala has been able to take further action on material sustainability topics, refining existing initiatives while also defining more granular and sector-specific targets and objectives. The findings of the materiality assessment were presented and validated in the Q4 2024 Sustainability Committee meeting and subsequently reviewed and endorsed by the Audit and Compliance Committee.

Additionally, sustainability considerations are embedded within Vidrala's risk management framework, with corresponding controls and processes ensuring a structured approach to identifying, assessing, and mitigating sustainability-related risks.

From 2024 onwards, a structured set of initiatives has been planned to keep the sustainability agenda active across departments, ensuring that material topics remain an ongoing priority. Following the publication of sustainability results, an annual review of material topics will be conducted to reflect the latest regulatory developments and sustainability trends.

Remuneration and Sustainability Performance

Board of Directors:

• Has a fixed salary with no bonus based on the company's results, neither financial nor environmental

Executive Committee:

• 30% of the long-term incentive is tied to the achievement of the objectives of decarbonisation, use of renewable energy and security
• This bonus is reviewed by the Nominations and Remuneration Committee at least once a year
• Performance is assessed against GHG emission reduction targets (47% reduction in Scope 1 and 2 emissions and 28% reduction in Scope 3 emissions by 2030, relative to 2019 figures)

Climate Risk Oversight

The Group's top climate-related risks and opportunities are reported to the Board through its delegated Audit Committee at least annually to ensure that they have oversight of the potential impact, as well as the mitigation and control measures being taken to reduce the climate-related impact.

In 2022, the Executive Committee independently assessed a list of climate-related risks and opportunities based on potential future impact, as well as the time horizon over which these could impact the Group. During 2024, the analysis have been reviewed and will be updated in 2025.

Integration of sustainability-related performance in incentive schemes

Roles covered by sustainability incentives

The Board of Directors has a fixed salary with no bonus based on the company's results, neither financial nor environmental.

The Executive Committee has sustainability-related performance integrated into its remuneration.

Sustainability KPIs tied to remuneration

The Executive Committee has 30% of the long-term incentive linked to the achievement of:

• Decarbonisation objectives
• Use of renewable energy
• Safety targets

Type of incentive

The sustainability metrics are linked to long-term incentive (LTI) only.

Weighting

30% of the long-term incentive is tied to sustainability performance.

Performance assessment and review

Performance is assessed against the GHG emission reduction targets outlined under the Metrics and Targets section.

This bonus is reviewed by the Nominations and Remuneration Committee at least once a year.

The Remuneration Committee will assess the annual performance of sustainability-related KPIs tied to incentive schemes, reinforcing the alignment between sustainability commitments and business objectives.

Climate-specific considerations

For climate-related performance, the Executive compensation scheme links 30% of the long-term incentive to the achievement of decarbonisation, use of renewable energy and safety targets. Performance is assessed against the GHG emission reduction targets.

Specific climate considerations factored into the remuneration policy include:

• Decarbonisation Goals: Incentives are directly linked to progress in reducing greenhouse gas emissions, with a focus on improving energy efficiency and increasing the share of renewable energy in our operations.

• Innovation in Sustainability: We encourage innovation by rewarding advancements in adopting new viable technologies, such as electrification of furnaces and the use of hydrogen trials, which form part of our transition plan towards a 1.5°C world.

• Circular Economy Practices: Incentivizing strategies that maximises the use of recycled glass (cullet) usage in our production processes.

• Engagement and Collaboration: Acknowledging the importance of stakeholder engagement, we incentivise actions that foster partnerships across our value chain to promote sustainability and knowledge sharing, specifically with sector organisations to align efforts and achievements.

Disclosure of payout against sustainability KPIs

No information disclosed regarding actual payout or performance achieved against sustainability KPIs in the reporting period.

Vidrala is a consumer packaging company. We produce glass containers for food and beverage products and offer a wide range of services, including logistics solutions and packaging operations. With a strong industrial track record, expanding geographical presence, and deep technical knowledge, we are a strategic partner to many of the leading brands in the consumer world.

Our business model is built on our commitment to serve our customers, manufacturing glass containers and providing packaging services in the most efficient, cost-effective, and sustainable way, while ensuring the safety and well-being of our people.

We currently produce over 9 billion containers per year, which are held in high regard by our portfolio of over 1,600 customers who have placed their trust in us. With over 4,500 employees, we are one of the leading manufacturers of glass containers in Western Europe and Latin America, supported by a network of nine strategically located production centres. Our activity takes place at three facilities in Spain, two in Portugal, three in the United Kingdom and Ireland and two in Brazil. Our manufacturing activity is an uninterrupted industrial process, operating 24 hours a day, 365 days a year.

Our value chain includes:

• Glass manufacturing at 9 sites
• 2 beverage filling facilities
• Logistics and packaging services
• Innovation and technology to create containers that meet evolving consumer needs

Glass is much more than just a packaging material: it is the ultimate sustainable choice. Its infinite recyclability, natural origin, and unparalleled ability to preserve product quality make it the best choice for brands and consumers alike.

Interests and views of stakeholders

Overview of stakeholder engagement approach

Vidrala actively engages with its key stakeholder groups through various channels and for multiple purposes. The stakeholder identification and selection is based on an internal assessment carried out by the management team, as well as on the strategic relationships forged with these groups.

As part of the ongoing commitment to strengthening stakeholder dialogue, Vidrala is continuously refining its approach to enhance direct interactions and better incorporate diverse perspectives into the strategic and operational framework.

Identified key stakeholder groups and engagement mechanisms

The following table outlines the nature of engagements, how perspectives are integrated into assessment, and supporting sources:

Detailed stakeholder analysis and engagement purpose

Employees

Through their work they make the business plan possible. To ensure their comfort and well-being and acquire a greater commitment, at Vidrala the company aims to achieve the following:

• Motivate and inspire them towards personal growth
• Listen to and understand their needs and interests
• Encourage and stimulate, so the company can continuously improve

Customers

They are the driving force, the 'why' of WHAT Vidrala does and HOW it does it. At Vidrala:

• Develop long-term relationships by meeting their needs and seeking their satisfaction
• Deliver sustainable packaging results
• Provide an adequate and quality service, at a competitive cost

Suppliers

They are the part of the supply chain of goods and services that contribute to business activity. The following are essential ingredients:

• Label them as a key player in the organisation

Shareholders

Those who believe in the effectiveness and operability of the business project, committing their capital. To make it work at Vidrala:

• Generate value, through sustained cash production and clear prioritisation of cash allocation
• Counterbalance the risk generated in the investment with an attractive return
• Constant updating of shareholders and investors on the status and progress of the project and business, both in terms of performance and expected risks

Communication channels with stakeholders

Vidrala has numerous communication channels that allow continuous dialogue, enabling the company to learn about stakeholder needs and concerns, and fostering transparency and collaboration.

For employees:

• Two-way communication
• Informative meetings adapted to their needs
• Union meetings
• Internal communication committees
• Multidisciplinary work teams associated with internal projects

For customers:

• Regular mail and online forms
• Specific supplier portal accessible from the website

For shareholders:

• Investor Relations department
• Website of the Spanish Securities and Exchange Commission (CNMV - Comisión Nacional del Mercado de Valores)
• Availability of regular public financial information
• Annual General Meeting of Shareholders (AGM)

Common communication means:

• Telephone
• Email
• Social media
• Corporate website

Integration of stakeholder perspectives into materiality assessment

Key internal and external stakeholders are identified based on their relevance to sustainability matters and their influence on or exposure to Vidrala's impacts, risks, and opportunities. This step involves determining engagement mechanisms (e.g., surveys, interviews, workshops) or leveraging existing consultation channels to capture their perspectives. The findings of this stakeholder engagement process are detailed in section SBM-3 in this report.

Own workforce - specific engagement

Recognition as valuable stakeholders:

Vidrala's most valuable stakeholders are employees—dedicated professionals across diverse roles and functions, who are integral to operational excellence and sustainability journey.

Categories of engagement:

Vidrala actively involves employees at all organisational levels, from the shop floor and operations teams to senior management, to ensure that a diverse range of viewpoints is incorporated into the decision-making process.

Organisational structure:

Vidrala's People department leads employee engagement initiatives, collaborating closely with sustainability and other core areas to ensure alignment with broader business and sustainability strategies.

Purpose of engagement:

The primary goal of engaging with people is to understand their needs, concerns, and aspirations in order to improve the value proposal, thereby enabling the company to enhance workplace experiences, foster well-being, and drive professional growth, among others.

Outcome integration:

Insights gained through engagement are critical in shaping Vidrala's HR policies, employee development programs, and sustainability practices, ensuring that people remain at the centre of business strategy.

Understanding team views:

In alignment with the materiality assessment process (referencing Disclosure Requirement IRO-1), Vidrala conducts comprehensive analyses to capture employees' perspectives. These analyses provide valuable insights into expectations related to work-life balance, career development, training opportunities, workplace safety, and overall job satisfaction. This continuous dialogue ensures that employee needs are effectively addressed in strategy and operations.

Adapting strategy and business model:

Addressing team interests: Vidrala is committed to evolving strategy and business model to reflect the priorities aligning Corporate & People priorities. Key focus areas include enhancing employee benefits, improving workplace safety measures, increasing inclusivity, and providing clear pathways for career progression.

Planned steps and timeline: As part of this commitment, Vidrala is continuously improving Employee Experience and People Development. This spirit will outline specific programs aimed at improving employee satisfaction and fostering professional growth.

Impact on team relationship: These efforts aim to deepen connection with employees, fostering higher engagement levels, increased retention, and a shared sense of purpose that aligns with Vidrala's sustainability goals.

Informing administrative, management, and supervisory bodies:

At Vidrala, the company ensures that leadership, including administrative, management, and supervisory level, is well-informed about the interests and concerns of people. Regular updates are provided through detailed reports, presentations, and summaries of employee feedback, enabling decision-makers to integrate these perspectives into socially responsible and sustainable strategies.

Employee engagement processes

Vidrala engages with employees both directly and indirectly through various processes to assess and address potential risks related to specific roles, work environments, or individual characteristics.

Key feedback mechanisms:

• Participation in the Great Place to Work rating, where employees evaluate workplace conditions, including health and safety, training opportunities, and overall well-being
• Insights collected through training requests and feedback from health & safety programmes, ensuring that employees in higher-risk roles or specific contexts receive targeted support and mitigation measures
• Engagement with workers' representatives across operations, fostering continuous dialogue to improve working conditions and identify areas for improvement

Stakeholder engagement and European Commission dialogue

Vidrala has engaged with the European Commission to discuss the inclusion of a specific NACE code for hollow glass under the framework of the EU Taxonomy. These consultations underline the commitment to aligning with regulatory developments and ensuring that the unique contributions of the industry are recognised.

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

Overview

Our identified material IROs are outlined in the DMA (see Annex 4.4.1) process and further described under each topic reported on in this report.

At Vidrala, our strategy and business model are designed for resilience, enabling us to effectively manage material impacts and risks while capturing emerging opportunities. We continuously invest in advanced, energy-efficient technologies and diversify our supply chain with a strong focus on sustainability. Our robust risk management systems, aligned with ISO standards and science-based targets, allow us to proactively mitigate both physical and transitional risks. Additionally, our ongoing supplier and customer collaborations ensure that our value chain remains adaptive. A culture of innovation and continuous improvement drives our commitment to sustainable principles, reducing environmental impact and ensuring long-term operational and financial stability. Regular reviews ensure our approach remains responsive to market changes and stakeholder expectations.

Vidrala remains alert to potential catastrophic events and regulatory changes. Likewise, the identified opportunities, such as adopting circular economy solutions and technological improvements, aim to enhance competitiveness and long-term value creation. Overall, Vidrala integrates these material risks and opportunities into its business model, addressing operational challenges and reaffirming its commitment to sustainability throughout its own operations and value chain. Further details related to current and anticipated financial effects will be disclosed in 2025, as we will determine quantitative thresholds. Qualitative thresholds for financial materiality are included in Section Double Materiality.

As a result of our continued CSRD implementation following 2023's part pre-alignment with agnostic material topics, the DMA 2024 provided us a higher level of granularity in the identified IROs. The material topics described in the FY23 sustainability statement have been assessed at a more detailed level in this report, considering sub and sub-sub-topics per CSRD requirements.

Material IROs by Topic Area

Climate Change (E1)

Material Risks:

• Energy price volatility and supply security (Short-term: 2023-2028)
• Increased cost of raw materials decreasing revenue if absorbed or making products less competitive if passed on (Short-term: 2023-2028)
• Damaged reputation through not meeting enhanced emissions reporting obligations imposed by regulators and suppliers (Short-term: 2023-2028)
• Inappropriate or untimely investment in technology leading to increased costs, reinvestment needs and failure to meet strategy (Medium-term: 2029-2034)
• Growing risk of drought and an increase in water scarcity could impact ability to produce products at maximum capacity (Long-term: 2035-2050)
• Extreme weather events (flooding, drought, wildfires etc.) could cause disruption to business operations (Long-term: 2035-2050)

Material Opportunities:

• Green capital knowledge could open access to green finance (Short-term: 2023-2028)
• Strengthening relationships with internal & external stakeholders, expanding business opportunities (Short-term: 2023-2028)
• Policy incentives driven by climate change for using a particular energy source may result in a cost saving. Early action on climate change could lead to a favourable position for public policy (Long-term: 2035-2050)
• Investing in the use of Cullet (recycled glass) can help to reduce The Group's reliance on virgin raw materials, as well as help reduce energy consumption (Medium-term: 2029-2034)
• Using new technologies, more environmentally-friendly fuels and developing new products and services is an opportunity to increase the brand image and the Group's reputation (Medium-term: 2029-2034)

Scenario Analysis: We assessed our top risks and opportunities against three different climate scenarios, including Current Policies (above 3°C), Delayed Transition (2°C) and Net Zero by 2050 (1.5°C). By analysing our top risks and opportunities across these climate scenarios, it allows us to better understand the importance of taking early action to combat future impact and implement risk management strategies to mitigate the risks.

Impact on Strategy: Vidrala's decarbonisation strategy is built on a multi-faceted approach that integrates energy efficiency improvements, alternative fuels, renewable energy adoption, and circular economy initiatives. Our key decarbonisation levers include:

• Electrification of Furnaces: Integration of electric boosting technology, currently at 10-15%, with new furnaces incorporating 25% electrification capacity and future designs targeting 40% electrification
• Alternative Fuels: We are actively preparing for the introduction of biofuels in 2025, following 2024 feasibility studies
• Circular Economy Initiatives: Maximisation of cullet (recycled glass) usage. Every 10% increase in cullet content leads to a 2.5% reduction in direct energy consumption and corresponding CO₂ reductions. In 2024, Vidrala achieved 53% of cullet usage rate
• Renewable Energy Integration: Expansion of on-site photovoltaic installations
• Hydrogen Projects: Participation in hydrogen valley initiatives (Nazaré, Hainet, and Aiala)
• Energy Efficiency and Industrial Optimisation: The furnace renewal plan integrates energy-efficient designs that enhance thermal performance and reduce energy losses

Targets: Vidrala's science-based decarbonisation targets (SBTi) establish clear goals for emissions reductions:

• Scope 1 and 2 GHG emissions: Targeted 47% reduction by 2030, using 2019 as the baseline
• Scope 3 GHG emissions: Targeted 28% reduction by 2030, also benchmarked against 2019 levels

These targets reflect our commitment to a 1.5°C trajectory in line with the Paris Agreement.

Pollution (E2)

The analysis identified SOx, NOx, and particulate matter as the primary pollutants linked to our production processes. We have centralised internal monitoring systems, including both continuous and periodic measurements, assessing deviations against the established budget and expected performance capacity.

Impact on Strategy:

• Investing in cleaner technologies and promoting the use of renewable energy sources
• Investment project developed for the installation in all production centres of special systems for purifying atmospheric emissions, called electrostatic precipitators or electrofilters, achieving a reduction in the usual emissions from glass melting furnaces by more than 90%
• Installation of SOx emission purification systems (desulphurisers)
• Investment of €193,000 in advanced monitoring systems for real-time pollutant tracking

Water Resources (E3)

Material Impacts and Risks:

• Water withdrawals for raw material extraction, particularly in quarrying, pose challenges by impacting local water availability and ecosystems
• Growing risk of drought and water scarcity could impact ability to produce products at maximum capacity

Material Opportunities:

• Efficient and responsible water management presents cost-saving potential by optimising consumption during manufacturing processes
• Adopting circular water systems could reduce water procurement costs and enhance operational resilience during periods of water scarcity

Impact on Strategy:

• Water efficiency through rainwater harvesting, greywater reuse, and process water recuperation
• Commitment to reduce potable water consumption in UK and EU plants up to 6% of the total consumption and reduce up to 0.10 m³ per glass melted ton produced
• Water Management System designed to drive continuous improvements
• Aim to reduce water consumption by 50% by 2030, using 2018 as the baseline for intensity usage
• Risk mapping using WWF risk categorisation and financial modelling to identify areas with higher water stress

Biodiversity (E4)

Vidrala is in the early stages of developing its biodiversity impact assessment. An initial assessment has identified potential impacts related to land use changes from raw material extraction, habitat loss in quarrying areas, and the company's activities on shared biological resources. Vidrala is conducting an initial mapping of critical areas and engaging with stakeholders, including local communities and suppliers, to develop its biodiversity action plan. Progress updates and finalised targets will be disclosed in 2025.

Resource Use and Circular Economy (E5)

Material Positive Impacts:

• Increased use of cullet and other recycled materials has contributed to reducing reliance on virgin resources
• Efforts to achieve zero waste to landfill and extend product life cycles
• Product design improvements have enhanced recyclability
• Decoupling business growth from resource demand

Material Negative Impacts:

• Challenges in managing hazardous and non-hazardous waste disposal
• Dependence on non-recycled and non-recyclable plastics in packaging contributes to resource scarcity
• Use of non-renewable raw materials such as sand and soda ash
• Improper disposal of operational waste materials

Impact on Strategy: Circular economy principles are integral to Vidrala's operational model. Glass as a material offers many benefits: high recyclability without loss of quality allows it to be used infinitely, reducing demand for raw materials. Our operational model itself is a clear representation of these principles, particularly our cullet management plan.

Actions:

• Action plan focused on increasing the use of recycled materials, improving raw material sourcing, and incorporating alternative materials
• Proportion of post-consumer cullet in production continues to grow (53% in 2024)
• Introduction of biomass slag to incorporate industrial residues that would otherwise go to landfill
• Materials such as Calumite and EP dust are being integrated into production

Own Workforce (S1)

Material Positive Impacts:

• Commitment to work-life balance and flexibility measures for family reasons
• Promotion of social dialogue
• Permanent contracts enhance job security
• Diversity and inclusion initiatives, such as enhancing the integration of women and persons with disabilities
• Efforts to increase female representation in leadership roles through Women in Manufacturing (WIM) program
• Investment in employee health and well-being, through occupational safety and mental health support

Material Negative Impacts:

• Risks related to workplace safety
• Concerns regarding gender discrimination in career opportunities
• Gender pay gap, directly attributable to the distribution of job roles, as women tend to occupy positions of lower responsibility and fewer roles in the production area
• Data privacy risks

Impact on Strategy: Vidrala's People department leads employee engagement initiatives, collaborating closely with sustainability and other core areas. The company is continuously improving Employee Experience and People Development. These efforts aim to deepen connection with employees, fostering higher engagement levels, increased retention, and a shared sense of purpose that aligns with Vidrala's sustainability goals.

All facilities are certified under ISO 45001:2018 Occupational Health and Safety Management System. Programs include the Behavioral Safety Program and the R3 initiative (reducing exposure to risks, recycling safe habits, and reusing lessons learned).

Workers in the Value Chain (S2)

Vidrala requires suppliers to adhere to its ethical standards through a Supplier Code of Conduct integrated into contracts. Sustainability audits, self-assessments, and access to facilities ensure ongoing compliance, with corrective actions enforced for violations.

Consumers and End-Users (S4)

Material impacts are assessed related to information provision and product safety for consumers and end-users.

Business Conduct (G1)

Material IROs:

• Corruption and bribery risks
• Corporate culture development
• Management of relationships with suppliers including payment practices
• Political engagement and lobbying activities
• Protection of whistle-blowers

Impact on Strategy: Vidrala prioritises responsible business aligned with its core values, formalised through the Vidrala Group's Code of Business Conduct (annually updated). Supporting policies include those against corruption, fraud, and antitrust violations, alongside human rights and criminal compliance frameworks.

A secure whistleblowing system ensures confidentiality and anonymity. Vidrala's Human Rights Policy prohibits child labour, forced labour, and exploitation while promoting fair wages, safe working conditions, and the right to unionise.

Integration with Risk Management

Climate-related risks and opportunities identified within the scenario analysis process are embedded into the risk register and risk management framework. The Audit Committee is responsible for clearly documenting the ownership of the risks, as well as the various controls and actions taken to mitigate and adapt to climate-related risks and opportunities.

Value Chain Considerations

Material IROs have been assessed across the value chain:

• Upstream impacts: Related to suppliers, including raw material sourcing, energy consumption in supply chain, supplier working conditions
• Own operations: Direct manufacturing impacts, employee-related impacts, direct emissions and resource use
• Downstream impacts: Related to customers, including product recyclability and end-of-life management

Resilience Assessment

At Vidrala, our strategy and business model are designed for resilience, enabling us to effectively manage material impacts and risks while capturing emerging opportunities. We continuously invest in advanced, energy-efficient technologies and diversify our supply chain with a strong focus on sustainability. Our robust risk management systems, aligned with ISO standards and science-based targets, allow us to proactively mitigate both physical and transitional risks. Regular reviews ensure our approach remains responsive to market changes and stakeholder expectations.

Financial Materiality Assessment

Risks and opportunities are assessed based on their magnitude and likelihood of occurrence. The likelihood of occurrence (expressed as a percentage between 0% and 100%) is multiplied by the potential financial size of the impact (also expressed as a percentage between 0% and 100%). A topic is considered financially material if the resulting score exceeds 50%. This methodology ensures that financial risks and opportunities are systematically identified, prioritised, and integrated into strategic decision-making.

For financial materiality, the methodology is integrated with Vidrala's corporate risk management framework, aligning with the COSO methodology to ensure consistency with broader enterprise risk management practices.

Transition Plan Impacts on Workforce

As Vidrala transitions towards greener and climate-neutral operations, it addresses how its plans impact its employees. This includes actions related to restructuring, employment changes, and opportunities for job creation or workforce development through reskilling initiatives. We are currently evaluating direct impact links arising from Vidrala's transition plans that may affect our employees. Meanwhile, we are focused on equipping employees with the skills needed to adapt to technological advancements and evolving industry requirements.

Executive Compensation Linkage

The Executive Committee has 30% of the long-term incentive linked to the achievement of decarbonisation, use of renewable energy and safety targets. This bonus is reviewed by the Nominations and Remuneration Committee at least once a year.

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

Vidrala Group conducted its double materiality assessment from May 2024 to September 2024 to identify how the company's operations impact people and the environment, while also considering how external factors affect the financial value of the company. This dual perspective of impact materiality and financial materiality forms the basis of the 'double' materiality approach.

Perimeter

The double materiality process covers all of the Vidrala Group's business units, in accordance with financial consolidation, as well as the relevant stages of its value chain and business relationships.

Methodology Overview

Vidrala's double materiality assessment methodology is based on the principles set out in the ESRS, in particular in Section 3. Double materiality as the basis for sustainability reporting and Appendix E. Flowchart for determining the information to be included in ESRS 1 as well as in the IG 1 Materiality Assessment developed by EFRAG.

The process consists of the following stages:

1. Understanding the context and establishing evaluation parameters

Analysis of the Operational and Strategic Context

The Sustainability Department assesses external trends (including regulatory developments, industry trends, and stakeholder expectations) and internal trends (corporate strategy, policies, and objectives) that shape the company's operating environment. This analysis ensures that sustainability considerations are fully integrated into Vidrala's strategic approach and align with both legal requirements and business priorities.

Value Chain Mapping

A comprehensive mapping of the main business lines' value chain is conducted, covering all stages from suppliers to clients. Despite our efforts, we are conscious that there is room for improvement regarding the value chain analysis. During the following years, we will work towards its development. This process identifies key activities, resources used, and involved stakeholders, allowing for the recognition of critical points where significant environmental, social, or economic impacts occur, as well as areas of key dependencies. This mapping serves as a foundation for assessing impacts, risks and opportunities across Vidrala's operations.

Identification of Information Sources

Internal and external sources of information are compiled and systematically organised to support the materiality assessment. These include:

• Internal: corporate policies, operational databases, risk assessments, and sustainability performance indicators.
• External: applicable regulations, international reporting standards (ESRS, GRI, SASB), and industry research.

This process ensures a robust and reliable data framework for subsequent assessment stages.

Determination and Engagement of Key Stakeholders

Key internal and external stakeholders are identified based on their relevance to sustainability matters and their influence on or exposure to Vidrala's impacts, risks, and opportunities. This step involves determining engagement mechanisms (e.g., surveys, interviews, workshops) or leveraging existing consultation channels to capture their perspectives. The findings of this stakeholder engagement process are detailed in section SBM-3 in this report.

Establishing Evaluation Parameters

The criteria and metrics that will guide the double materiality assessment are defined, ensuring alignment with evolving regulatory frameworks and best practices. This includes:

• Impact materiality: Magnitude, scope, and irreversibility of sustainability impacts.
• Financial materiality: Probability and financial magnitude of risks and opportunities.

For financial materiality, the methodology is integrated with Vidrala's corporate risk management framework, aligning with the COSO methodology to ensure consistency with broader enterprise risk management practices. Thresholds and assessment criteria are established to ensure transparency and consistency in determining material sustainability topics.

2. Identification of potential impacts, dependencies, risks and opportunities

Impact Analysis

Building on the list of issues identified in AR 16 of ESRS 2 (Annex 2), combined with previous years' analyses and additional topics deemed relevant by the Sustainability Department and sources analysed during the context mapping phase, a classification of potential impacts will be established. These will be categorised as current or potential, negative or positive, and short-, medium-, or long-term impacts. A distinction will be made between impacts occurring within Vidrala's own operations and those within the value chain, including: upstream impacts (related to suppliers) and downstream impacts (related to customers).

To the greatest extent possible, impacts will be identified at the most specific level (topic, subtopic, and sub-subtopic). Where further granularity is not possible, reference will be made to broader subtopics that encompass multiple issues.

Risk and Opportunity Analysis

Using Vidrala's corporate risk map, potential sustainability-related risks will be identified. Additionally, previously established sources will be leveraged to recognise emerging risks and opportunities that may be relevant. The findings mentioned in section 3.1.4 Determination and Engagement of Key Stakeholders will guide this process to ensure consistency and alignment with regulatory and business priorities.

Review of the Relationship Between IROs

The identified impacts will be reviewed to determine whether they could lead to specific risks or opportunities. Likewise, any identified risks and opportunities will be assessed to understand whether their management could, in turn, generate new sustainability impacts.

Validation with Business Units and Departments

The 2024 DMA assessment has been validated by the sustainability committee (including members of the Executive Board). From now on, the list of impacts, risks, and opportunities (IROs) will be validated through biannual workshops with key internal areas and business units. These sessions will serve to ensure completeness and comprehensiveness of identified IROs and adapt the IROs to Vidrala's specific operational and strategic context.

Departments involved in the validation process include: People, Operations, Purchasing, Finance, Internal Audit.

The list of identified impacts will specifically highlight those related to Human Rights, ensuring compliance with internationally recognised frameworks. Particular attention will be given to impacts concerning: Child or forced labour, Equal remuneration, Freedom of association, Fair working conditions and wages, Inclusion of vulnerable or minority groups and Limitations on excessive working hours.

3. Assessing the materiality of impacts, risks and opportunities

Impact Assessment

• Current impacts will be assessed in accordance with ESRS 1, based on their severity, which is determined by magnitude, scope, and, if negative, irremediability. Potential impacts will be evaluated based on their severity and probability of occurrence. The assessment criteria, rated on a scale from 1 to 5, will be detailed in Annex Double Materiality Parameters.
• Evaluators and Stakeholder Participation: Each department or function will evaluate the relevant impacts and associated parameters, based on prior identification processes and their direct connection to the identified impacts. The Sustainability Department will determine the scope of the impacts based on the findings during meetings and internal conversations, unless a justified weighting adjustment is necessary.

Impact Score

Each identified impact is assessed based on three key dimensions:

• Scale: The extent of the impact, measured on a 0 to 5 scale.
• Scope: The breadth of the impact, also measured on a 0 to 5 scale.
• Remediability (for negative impacts only): The degree to which an impact can be reversed or mitigated, measured on a 0 to 5 scale.

For potential impacts, an additional factor is introduced:

• Likelihood: The probability of the impact occurring, expressed as a numerical factor ranging from 0 to 1.

For positive impacts, scores are normalised on a 15-point scale to ensure comparability with negative impacts, following the formula: (Scale+Scope)/10×15. Additionally, no netting of impacts is applied—if a subtopic generates both positive and negative impacts, only the most significant impact is considered for assessment.

Once scores are calculated, impacts are classified into categories based on their materiality threshold:

Topics scoring above 8 are considered material, requiring further integration into risk management and strategic decision-making processes.

The methodology differentiates between actual and potential impacts, as well as positive and negative impacts:

• Negative Actual Impacts: Evaluated based on scale, scope, and remediability.
• Negative Potential Impacts: Evaluated based on scale, scope, remediability, and likelihood.
• Positive Actual Impacts: Evaluated based on scale and scope.
• Positive Potential Impacts: Evaluated based on scale, scope, and likelihood.

For negative human rights-related impacts, severity is prioritised over probability, ensuring greater weight is assigned to the severity of these impacts in the assessment.

Financial Score

Risks and opportunities will be assessed in accordance with ESRS 1 based on their magnitude and likelihood of occurrence. The likelihood of occurrence (expressed as a percentage between 0% and 100%) is multiplied by the potential financial size of the impact (also expressed as a percentage between 0% and 100%). A topic is considered financially material if the resulting score exceeds 50%. This methodology ensures that financial risks and opportunities are systematically identified, prioritised, and integrated into strategic decision-making. For further details related to internal scales, please refer to Annex Double Materiality Parameters.

Results Consolidation

The Sustainability Department will compile the list of relevant IROs, selecting those that exceed the materiality threshold. IROs close to the threshold will be reviewed to ensure that no significant IROs are excluded. A semi-annual review of the scores will be conducted.

Validation with Senior Management

The list of relevant IROs will be reviewed with the Board and the Sustainability Committee. If necessary, the results will also be presented to the Audit and Compliance Committee for further discussion.

4. Reporting sustainability information on material impacts, risks and opportunities

Mapping Material IROs to Materiality Issues

During the identification stage, each Impact, Risk, and Opportunity (IRO) will be linked to a relevant sustainability issue. If an IRO is classified as material, the associated sustainability issue will also be considered material at its most specific level. This process will result in a list of material IROs and sustainability issues, which will be mapped to the corresponding Disclosure Requirements (DRs) of the ESRS.

DR Identification and Data Points for Reporting

Following the principles of information materiality outlined in ESRS 1 (sections 31-35), the relevance of ESRS disclosures will be assessed in relation to the importance of the sustainability issue and its usefulness for stakeholders' decision-making. This assessment will be conducted at the data point level to ensure that the reported information aligns with materiality principles.

Frequency and Review

The 2024 DMA assessment has been validated by the sustainability committee (including members of the Executive Board). From now on, the list of impacts, risks, and opportunities (IROs) will be validated through biannual workshops with key internal areas and business units.

The findings of the materiality assessment were presented and validated in the Q4 2024 Sustainability Committee meeting and subsequently reviewed and endorsed by the Audit and Compliance Committee.

From 2024 onwards, a structured set of initiatives has been planned to keep the sustainability agenda active across departments, ensuring that material topics remain an ongoing priority. Following the publication of sustainability results, an annual review of material topics will be conducted to reflect the latest regulatory developments and sustainability trends.

Climate-Specific Process (E1-IRO-1)

Vidrala has assessed climate-related risks across every aspect of our value chain, assessing the risks across our own business operations, and products and services. We have also considered the varying climate-related risks and opportunities across the geographic regions in which we operate. As a result, we identified the six top climate-related risks and five top climate-related opportunities that could have a material impact upon the Group. Of these six risks, four are transition risks and two are physical risks.

The climate-related risks and opportunities have been classified by the time horizon within which we anticipate the impact to occur. These include:

• Short-term: 0-5 years (2023-2028)
• Medium-term: 5-10 years (2029-2034)
• Long-term: 10-27 years (2035-2050)

Determining focal questions prior to undertaking the scenario analysis helped to guide the key questions, and decisions the Group need to consider following the identification of a climate-related risk and/or opportunity. The Group identified broad focal questions that cover overarching strategy decisions relating to climate-related risks and opportunities, as well as more specific focal questions per individual risk. The Group recognises that our overarching focal questions are likely to develop each year as our climate-related risk identification, and assessment matures over time.

Pollution-Specific Process (E2-IRO-1)

The analysis of impacts, risks, and opportunities (IROs) related to pollution was conducted by reviewing environmental assessments required under national regulations for each business unit and evaluating the presence of regulated substances under relevant regulations such as REACH. This assessment identified SOx, NOx, and particulate matter as the primary pollutants linked to our production processes. Consultations were carried out with environmental managers at plant level and the Group Environmental Manager to ensure a consistent and aligned evaluation. To manage these IROs, we have centralised internal monitoring systems, including both continuous and periodic measurements, assessing deviations against the established budget and expected performance capacity.

Water-Specific Process (E3-IRO-1)

Consultations on water and marine resource management have been primarily conducted internally, ensuring alignment with the regulatory frameworks of each country where Vidrala operates. These consultations have involved cross-functional collaboration between environmental management teams, sustainability departments, and operational units to assess water usage, discharge practices, and compliance requirements.

Our Water Management Strategy incorporates analysis to ensure responsible water use, particularly in areas facing high or very high water depletion risks. Based on risk financial modelling, we have mapped our facilities against varying levels of water scarcity, allowing us to define targeted actions to optimise water consumption, enhance treatment processes, and mitigate operational risks associated with water restrictions.

Related to water risk areas, we have incorporated different analysis based on internationally recognised methodologies, such as WWF risk categorisation and financial modelling, to identify areas with higher water stress. This evaluation allows us to prioritise actions in sites where water depletion poses a significant challenge.

Resource Use and Circular Economy-Specific Process (E5-IRO-1)

Impacts, risks and opportunities related to resource use and circular economy have been guided by assessments conducted by Vidrala's operational teams, ensuring alignment with current legislation and operational priorities. Stakeholder consultations, primarily carried out through the assessments of Vidrala's operational teams and in strict adherence to existing regulations, have played a crucial role in identifying these challenges.

Own Workforce-Specific Process (S1-IRO-1)

Vidrala recognises the intrinsic link between material risks and opportunities stemming from its and its business strategy. By identifying and understanding these risks and opportunities, the company implements targeted measures to mitigate negative effects while leveraging positive impacts to drive sustainable growth.

All employees who have an employment relationship with Vidrala are included under the analysis.

General processes for employee engagement:

We engage with our employees both directly and indirectly through various processes to assess and address potential risks related to specific roles, work environments, or individual characteristics. One of our key feedback mechanisms is our participation in the Great Place to Work rating, where employees evaluate workplace conditions, including health and safety, training opportunities, and overall well-being.

Additionally, we collect insights through training requests and feedback from health & safety programmes, ensuring that employees in higher-risk roles or specific contexts receive targeted support and mitigation measures. We also engage with workers' representatives across our operations, fostering continuous dialogue to improve working conditions and identify areas for improvement.

The IROs assessed in the employee section have emerged from the analysis of these interactions, providing a structured understanding of material impacts. These findings have been reviewed and validated by management and employee leadership functions, ensuring that they accurately reflect workplace realities and guide effective decision-making.

Business Conduct-Specific Process (G1-IRO-1)

At Vidrala, we are committed to an inclusive and comprehensive approach towards identifying and assessing material impacts, risks, and opportunities which influence our business conduct and operations. We acknowledge the necessity of a robust system that duly considers varying criteria including location, activity, sector, and the transaction structure.

Transition plan for climate change mitigation

Scope of the plan

Vidrala's transition plan is based on achieving science-based emission reduction targets and in the periodic monitoring of climate-related risks. While the plan is currently under development, its key components have already been analysed and approved by our Administrative and Management Bodies, establishing a solid foundation for its formalisation during 2025.

The plan covers all Group production facilities across Spain, Portugal, the United Kingdom, and Brazil.

Target year(s) for net zero / carbon neutral

Net Zero by 2050: Vidrala had its Net Zero Target validated by the SBTi in 2023.

2030 Interim Targets:

• Scope 1 and 2 greenhouse gas emissions: Targeted 47% reduction by 2030, using 2019 as the baseline
• Scope 3 GHG emissions: Targeted 28% reduction by 2030, also benchmarked against 2019 levels

These targets reflect our commitment to a 1.5°C trajectory in line with the Paris Agreement.

Alignment with 1.5°C / SBTi validation status

Vidrala's plans are formally aligned with the goal of limiting global warming to levels below 1.5°C, after being validated by the Science-based Target Initiative (SBTi) in 2022.

Specifically, the Executive compensation scheme links 30% of the long-term incentive to the achievement of decarbonisation, use of renewable energy and safety targets. Performance is assessed against the GHG emission reduction targets.

Key levers / decarbonization pillars

Vidrala's decarbonisation strategy is built on a multi-faceted approach:

Energy

Electrification of Furnaces: Integration of electric boosting technology, currently at 10-15%, with new furnaces incorporating 25% electrification capacity and future designs targeting 40% electrification.

Alternative Fuels: Vidrala is actively preparing for the introduction of biofuels in 2025, following 2024 feasibility studies. This transition will be backed by Guarantees of Origin (GdOs) to ensure traceability and sustainability. In 2024, for the first time, Vidrala invested in guarantees of renewable origin in biomethane, sourced from the Spanish grid.

Renewable Energy Integration:

• Commitment to achieving 100% renewable electricity by 2030
• On-site Generation: Development of Solar and Wind generation assets across facilities
• Near-Site Generation: Explore generation project opportunities near production facilities
• Power Purchase Agreements (PPAs): Vidrala signed a Power Purchase Agreement (PPA) with Acciona Energía for the supply of renewable energy that will cover between 20% and 25% of the company's electricity needs over the next 10 years. The contract will allow Vidrala to source clean electricity for operations at several manufacturing plants in Llodio (Álava), Caudete (Albacete), Castellar del Vallés (Barcelona), and Marinha Grande (Portugal). This PPA will avoid the emission of 150,000 tons of CO2 into the atmosphere during the contract's duration.

Hydrogen Projects: Participation in hydrogen valley initiatives (Nazaré, Hainet, and Aiala) to explore its potential as an alternative low-carbon energy source. The UK Prime Minister announced a funding package of £21.7 billion over the next 25 years for hydrogen and carbon capture adoption.

Process

Energy Efficiency and Industrial Optimisation:

• The furnace renewal plan integrates energy-efficient designs that enhance thermal performance and reduce energy losses
• Continuous modernisation of furnace technology, enhancing thermal efficiency while reducing absolute and intensity-based emissions
• Batch and cullet preheater at Santos Barosa plant in Marinha Grande, Portugal, which captures waste heat from furnace exhaust gases

Product

Light-weight and right-weight of product to reduce material and energy consumption.

Supply chain & circular economy

Circular Economy Initiatives:

• Maximisation of cullet (recycled glass) usage: Every 10% increase in cullet content leads to a 2.5% reduction in direct energy consumption and corresponding CO₂ reductions
• In 2024, Vidrala achieved 53% of cullet usage rate, an 8% increase vs 2023 figures
• Exploration of decarbonised raw materials, selecting components that have undergone pre-treatment or incineration to lower their embedded emissions

Supplier sustainability policy: Vidrala has developed a Sustainable Procurement Policy, aligned with the Supplier Code of Conduct. Suppliers are expected to adhere to the Science-Based Targets initiative (SBTi) framework for emissions reduction. Currently, a total of 370 suppliers are undergoing ESG assessment.

CapEx / investment commitments

Vidrala remains committed to integrating sustainability into its financial planning and operational strategy. The allocation of financial and other resources to our action plan is aligned with our long-term vision and ongoing business priorities. Over the coming years, Vidrala will refine its methodology to provide a more detailed and structured approach to assessing and disclosing these financial indicators.

Sustainability is integral to Vidrala's strategy, with emissions targets embedded in financial planning and operational decision-making.

Performance metrics

2024 Progress:

• Scope 1 and 2 emissions reduced by 3.7% in absolute terms compared to 2023
• Emissions intensity (measured as tonnes of CO2e per tonne of melted glass) achieved a reduction of 6.1%
• Energy intensity improved by 3% in 2024 compared to 2023
• Carbon intensity: 0.337 tCO2e/tmg (market-based) in 2024 vs 0.356 in 2023

2024 Emissions data:

Locked-in emissions and stranded asset analysis

Not explicitly disclosed in the excerpts provided.

Use of carbon credits / removals

Vidrala is exploring the potential use of biodiversity offsets to compensate for unavoidable environmental impacts. However, specific details on carbon credits or removals strategies are not substantively disclosed.

Alignment with Commission Delegated Regulation 2021/2139

Vidrala's aim is to ensure that all economic activities align with the criteria outlined in the regulation. The company is currently revising its CapEx and OpEx strategies to prioritise sustainability and ensure full compliance as specified in the EU Taxonomy Regulation section.

Climate risk scenario analysis

In 2022, the Executive Committee independently assessed climate-related risks and opportunities based on potential future impact across three different climate scenarios:

1. Current Policies (above 3°C): Business as usual scenario
2. Delayed Transition (2°C): Late action taken scenario
3. Net Zero by 2050 (1.5°C): Smooth transition scenario

The analysis will be reviewed and updated in 2025.

Governance and implementation

Climate considerations are integrated into remuneration: The Executive compensation scheme links 30% of the long-term incentive to the achievement of decarbonisation, use of renewable energy and safety targets.

All climate-related risks and opportunities identified are embedded into the risk register and risk management framework. The Audit Committee is responsible for documenting the ownership of risks and the various controls and actions taken to mitigate and adapt to climate-related risks.

Future developments

Vidrala actively monitors all related aspects and provides annual updates to ensure alignment with sustainability objectives and regulatory requirements. Further alignment with the internal Financial Risk will be developed in 2025. The company is also working to develop a Net Zero transition plan to 2050, which will be formalised during 2025.

Policies related to climate change mitigation and adaptation

Vidrala integrates its commitment to climate change mitigation and adaptation within its broader sustainability and environmental management approach. The company's strategy is centred on continuous improvement in processes, energy efficiency, and resource optimisation, aligning with its sustainability and decarbonisation objectives.

In terms of climate change mitigation, Vidrala actively works to reduce the environmental impact of operations by prioritising energy efficiency in the use of gas and electricity, enhancing the environmental performance of processes, and adopting more sustainable solutions in the procurement of products and services.

Regarding climate change adaptation, the company takes a proactive approach by identifying and managing risks associated with activities, ensuring the implementation of safety, resilience, and resource efficiency measures across facilities and processes. Additionally, Vidrala maintains ongoing dialogue with stakeholders to anticipate and address potential impacts, aligning strategies with evolving expectations and environmental challenges.

Integrated Policy

Vidrala's integrated Policy includes references related to its commitment to climate change and sustainability.

• Approval and oversight: The policy was signed in 2020 and is being reviewed for update during 2025
• Content: The policy encompasses the company's commitment to climate change mitigation and adaptation as part of its broader sustainability framework

Sustainable Procurement Policy

Vidrala has developed a Sustainable Procurement Policy, aligned with the Supplier Code of Conduct.

• Key principles:

  • Sustainability Integration: Suppliers are integral partners in reducing greenhouse gas (GHG) emissions and enhancing circularity. Vidrala expects suppliers to adhere to sustainability standards
  • Resource Efficiency: Suppliers are encouraged to optimise resource usage, implement recycling initiatives, and support Vidrala's mission to close the glass loop by maximizing recycled content in production
  • Ethical and Social Responsibility: Adherence to high standards of human rights, labor conditions, and workplace safety is mandatory for all suppliers. Vidrala promotes fair wages, diversity, and equitable working conditions across its supply chain
  • Transparency and Accountability: Suppliers are required to disclose their sustainability performance, including environmental, social, and governance (ESG) metrics, via standardised reporting frameworks
  • Decarbonisation Goals: The policy addresses greenhouse gas emissions reduction in the supply chain

• Scope: All suppliers across the supply chain

Transition Plan for Climate Change Mitigation

While the transition plan is currently under development, its key components have already been analysed and approved by Vidrala's Administrative and Management Bodies, establishing a solid foundation for its formalisation during 2025.

• Approval and oversight: Key components analysed and approved by Administrative and Management Bodies
• Timeline: Plan to be formalised during 2025
• Key components:
  • GHG emission reduction targets aligned with science-based targets (SBTi)
  • Decarbonisation levers and key actions including electrification, biofuels, and renewable energy
  • Alignment with Commission Delegated Regulation 2021/2139
  • Business strategy and financial planning alignment with sustainability embedded in financial planning and operational decision-making

Integration in Executive Compensation

Vidrala links sustainability performance to executive incentives:

• Scope: Executive compensation scheme
• Content: 30% of the long-term incentive is linked to the achievement of decarbonisation, use of renewable energy and safety targets. Performance is assessed against GHG emission reduction targets. Incentives cover:
  • Decarbonisation goals with focus on reducing greenhouse gas emissions, improving energy efficiency and increasing renewable energy share
  • Innovation in sustainability, rewarding advancements in adopting new technologies such as electrification of furnaces and hydrogen trials
  • Circular economy practices, incentivizing strategies that maximise recycled glass (cullet) usage
  • Engagement and collaboration, fostering partnerships across the value chain to promote sustainability and knowledge sharing

Actions and resources in relation to climate change policies

Vidrala's decarbonisation strategy is built on a multi-faceted approach that integrates energy efficiency improvements, alternative fuels, renewable energy adoption, and circular economy initiatives.

Key Decarbonisation Levers

1. Electrification of Furnaces

• Description: Integration of electric boosting technology into furnace operations
• Current status: Currently at 10-15% electrification
• Planned progression:
  • New furnaces incorporating 25% electrification capacity
  • Future designs targeting 40% electrification
• Scope: Own operations
• Time horizon: Medium to long-term (progressive implementation)

2. Alternative Fuels (Biofuels)

• Description: Introduction of biofuels to replace fossil fuels in operations
• Timeline:
  • 2024: Feasibility studies completed
  • 2025: Introduction of biofuels planned
• Supporting measures: Backed by Guarantees of Origin (GdOs) to ensure traceability and sustainability
• Status: Previous trials using low carbon biofuels have demonstrated feasibility
• Scope: Own operations
• Time horizon: Short-term (2025 implementation)

3. Circular Economy Initiatives - Cullet Usage

• Description: Maximisation of cullet (recycled glass) usage in production
• Impact: Every 10% increase in cullet content leads to a 2.5% reduction in direct energy consumption and corresponding CO₂ reductions
• Current performance: 53% cullet usage rate achieved in 2024
• Target: Further increase cullet proportion as established in the cullet plan
• Additional measures: Exploration of decarbonised raw materials, selecting components that have undergone pre-treatment or incineration to lower embedded emissions
• Scope: Own operations
• Time horizon: Ongoing

4. Renewable Energy Integration

• Description: Expansion of on-site photovoltaic installations
• Expected outcome: Reducing Scope 2 emissions while supporting self-consumption
• Additional benefits: Cost savings, generation of additional income, expansion of energy independence
• Scope: Own operations
• Time horizon: Ongoing expansion

5. Hydrogen Projects

• Description: Participation in hydrogen valley initiatives to explore potential as an alternative low-carbon energy source
• Projects: Nazaré, Hainet, and Aiala hydrogen valley initiatives
• Status: Not yet commercially viable for full-scale operations
• Purpose: Ensures Vidrala remains at the forefront of industrial decarbonisation solutions
• Scope: Own operations
• Time horizon: Long-term (exploratory phase)

6. Energy Efficiency and Industrial Optimisation

• Description: Furnace renewal plan integrating energy-efficient designs
• Actions:
  • Enhancement of thermal performance
  • Reduction of energy losses
  • Continuous modernisation of furnace technology
  • Light-weight and right-weight product design
• Expected outcome: Reducing absolute and intensity-based emissions
• Scope: Own operations
• Time horizon: Ongoing modernisation programme

Supply Chain Actions

ESG Supplier Risk Assessment Programme

• Description: Structured approach to integrate ESG criteria into supply chain management
• Current scope: 370 suppliers undergoing assessment
• Assessment criteria: Financial stability, compliance, business continuity, operational performance, cybersecurity, and ESG criteria
• Process stages:
  1. Development of Risk Matrix to classify suppliers
  2. GoSupply Platform evaluation generating benchmarking scores
  3. Specific audits for lowest-scoring suppliers by specialised teams
  4. Development of corrective action plans with concrete measures, defined timelines and continuous monitoring
• Target: Analyse 100% of Vidrala's strategic suppliers to ensure full ESG compliance
• Support provided: Resources, training, and partnership opportunities for continuous improvement programs
• Scope: Upstream value chain
• Time horizon: Ongoing (target to reach 100% strategic supplier coverage)

Supplier Climate Action Requirements

• Description: Expectations for suppliers to measure, report, and reduce emissions
• Requirements:
  • Adherence to Science-Based Targets initiative (SBTi) framework
  • Active work to measure, report, and reduce Scope 1, 2, and 3 emissions
  • Priority given to innovations in energy efficiency and renewable energy adoption
• Collaboration areas: Low-carbon solutions including alternative raw materials, energy-efficient logistics, and decarbonised manufacturing processes
• Scope: Upstream value chain
• Time horizon: Ongoing requirement

Achieved GHG Emission Reductions

Vidrala's science-based decarbonisation targets (SBTi) establish clear goals:

• Scope 1 and 2 GHG emissions: Targeted 47% reduction by 2030 (baseline: 2019)
• Scope 3 GHG emissions: Targeted 28% reduction by 2030 (baseline: 2019)
• Alignment: 1.5°C trajectory in line with the Paris Agreement
• Note: Target achievement depends on the availability and allocation of resources

Resources Allocated

Financial resources: No specific capex or opex amounts are quantified in the disclosure.

Non-financial resources:

• Specialised audit teams for supplier assessments
• GoSupply Platform for supplier evaluation and monitoring
• Resources, training, and partnership opportunities provided to suppliers
• Participation in three hydrogen valley initiatives (Nazaré, Hainet, Aiala)
• Internal technical teams for feasibility studies and trials

Links to Policies and Targets

• All actions support the science-based targets validated by SBTi in 2023
• Actions align with the integrated Policy (signed 2020, under review for 2025 update)
• Supply chain actions support sustainability and decarbonisation objectives
• Climate action and sustainability integration policies drive supplier engagement requirements

Our work at Vidrala is aligned with the SBTi (Science Based Targets initiative) to set greenhouse gas emission targets that conform to the Paris Agreement. Our aim is to reduce our scope 1 and 2 greenhouse gas emissions in the short term by 47% and our scope 3 emissions by 28%, both by 2030 and with respect to our 2019 figures.

At Vidrala, we are committed to increasing our cullet usage up to 66% by 2030.

Vidrala's commitment to achieving 100% renewable electricity by 2030 is underpinned by a diversified energy transition plan.

Energy consumption and mix

Energy consumption by source (2024 vs 2023)

Note: Data restated to reflect current perimeter, including Vidroporto and excluding Vidrala Italy operations.

---

Detailed energy consumption and mix (2024)

The following table presents energy consumption disaggregated by fossil, renewable, and nuclear sources in accordance with ESRS E1-5 requirements:

Comparative data for 2023 presented aligned with national requirements established by Law 11/2018, audited by an independent third party in 2024.

---

Energy intensity for high climate impact sectors

High climate impact sector as defined in Commission Delegated Regulation (EU) 2022/1288.

---

Scope and methodology:

• All energy consumption figures cover Vidrala's operational perimeter, restated to include Vidroporto and exclude Vidrala Italy operations.
• Energy consumption disaggregation follows ESRS E1-5 requirements.
• Renewable electricity includes purchased renewable electricity (with Guarantees of Origin) and self-generated photovoltaic electricity.
• In 2024, Vidrala invested in guarantees of renewable origin for biomethane sourced from the Spanish grid (first time).
• Energy intensity improved by 3% in 2024 vs 2023 (per tonne melted glass).
• Four facilities have 100% renewable Guarantees of Origin contracts; three have solar panels supplying 5-20% of consumption; 30% of electricity for three Spanish facilities comes from renewable sources (with GOs).

---

Nuclear energy:

Vidrala reported no consumption from nuclear sources and does not carry out, fund, or have exposures to nuclear energy-related activities (as disclosed under Commission Delegated Regulation (EU) 2022/1214).

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG Emissions

Scope 1 breakdown: Emissions primarily derive from fossil fuel use for the fusion process and decarbonisation of carbonated raw materials (99% of Scope 1). Remaining emissions include mobile combustion from internal material transport, own fleet, and fugitive emissions from refrigerant gases. Biogenic CO₂ emissions: 37.93 tCO₂ reported separately.

Scope 2 GHG Emissions

Scope 3 GHG Emissions

Scope 3 note: Categories 13 (Downstream leased assets) and 14 (Franchises) omitted as not applicable. Category 15 (Investments) planned for inclusion in 2025. Categories 10 and 11 reported for the first time in 2024.

Total GHG Emissions

GHG Intensity

Intensity metric note: Measured per tonne of melted glass (tmg). Net revenue 2024: €1,588 million. Total energy consumption per net revenue: 0.25%.

Methodology and Scope Notes

Scope 1 accounting principles: Calculated using direct activity data with emission factors from national inventories and DEFRA.

Scope 2 accounting principles: Calculated using direct activity data with emission factors from national inventories, DEFRA, and renewable Guarantees of Origin for market-based calculations.

Scope 3 accounting principles:

• Category 1: Raw materials and packaging calculated using actual activity data (95% of Category 1); remaining emissions based on economic cost.
• Category 2: Based on executed CapEx and type of service/product acquired.
• Category 3: WTT (Well to Tank) methodology.
• Category 4: Tank-to-Wheel and Well-to-Tank methodologies combined.
• Category 5: European Waste Classification for EU/UK facilities; local regulations for non-EU/UK.
• Category 6: Tank-to-Wheel and Well-to-Tank methodologies.
• Category 7: Employees' home cities to nearest production centre distance; Tank-to-Wheel and Well-to-Tank methodologies.
• Category 8: Activity data (natural gas/electricity) or economic expenditure.
• Category 9: Number of trucks, origin, destination; Tank-to-Wheel and Well-to-Tank methodologies.
• Category 10: Activity data by glass container type and nominal capacity.
• Category 11: Activity data by bottled product quantity and electrical energy consumption during cooling.
• Category 12: Tonnes sold per country and recycling rates.

Perimeter note: Data reflects perimeter variation implemented in 2024. Includes Vidroporto (Brazil) consolidated from December 2023; excludes Vidrala Italia from March 2024. Normalised data will be represented in future reports alongside updated SBTi targets undergoing rebaseline.

GHG Protocol alignment: Calculations align with GHG Protocol/ISO 14064-1:2019.

Estimated figures: Some 2024 data (energy, emissions) based on estimates due to unavailability of final invoices at report preparation (February 2025). Estimation accuracy: ±10% for upstream/downstream impacts.

No primary supplier data: Currently no primary supplier or value chain partner data utilised; progress planned for 2025.

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

Scenario analysis methodology

Undertaking climate-related scenario analysis allows us to assess the impact of our top climate-related risks and opportunities across three climate scenarios by time-horizon. Scenario analysis ensures that our business can adequately plan potential impact into our 4Ps strategy and address risks and uncertainties, as well as capitalise on opportunities presented.

The Network for Greening the Financial System (NGFS) Framework is one of the TCFD recommended frameworks for scenario analysis and meets the recommendation to assess business resilience under different climate-related scenarios, including a 2°C or lower scenario.

Climate scenarios used

Net Zero 2050 (1.5ºC)

• Policies are implemented immediately and smoothly
• Technology change is fast and there is reliable on CO2 removal
• Global carbon prices over $600USD/tCO2e by 2050
• Aligned to RCP 2.6 - equivalent of warming of above 1ºC
• Impact: Higher transition risk: Lower physical risk. Sharp changes towards decarbonising all aspects of the economy from today

Delayed Transition (2ºC)

• Without immediate additional policies, emissions rise until 2030. After 2030, there are stringent policies imposed causing emissions to decline aggressively to get to Net Zero by 2050
• Carbon pricing increases over $200 USD/tCO2e between 2030 and 2050
• Aligned to RCP 4.5 - equivalent of average warning of above 1.5ºC by 2050
• Impact: Transition risk high in this scenario with increased physical risk. Higher transition risk; significant physical risk. Aggressive change towards decarbonising the economy from 2030 onwards

Current Policies (3ºC)

• Only currently implemented policies influence businesses and society, leading to a continued rise in emissions
• Technology change remains slow
• No modelled changed
• Aligned to RCP 8.5 - equivalent to an average warming of above 2ºC by 2050
• Impact: Limited transition risk: Higher physical risk. Reduced support to limit the effects of climate change - only current policies applied

Time horizons

• Short-term: 2023-2028
• Medium-term: 2029-2034
• Long-term: 2035-2050

Transition risks impact by scenario and time horizon

Transition risks are modelled to have the highest risk to the Group in a Net Zero 2050 and Delayed Transition Scenario over the medium-long term. The risk is highest in these scenarios due to pressure from governments, investors, and customers to decarbonise. Over the long-term, the Group can expect the highest impact in a Delayed Transition Scenario, as late action is expected to cause strict regulations to be imposed quickly. In a Current Policies Scenario, limited change to current regulation and carbon pricing is expected, and as such the impact of transition risks remain low in this scenario.

Table 2: Transition risks impact on The Group by time horizon and climate scenario

Scenario 1: Current policies (3 °C) - Business as Usual Scenario 2: Delayed transition (2 °C) - Late action taken Scenario 3: Net Zero 2050 (1.5 °C) - Smooth transition

Physical risks impact by scenario and time horizon

Due to the differing geographic regions in which we operate, an increase in the physical risks of climate change poses a risk to the Group in the long term. The physical risks are modelled to have the most severe impact under a Current Policies Scenario. Limited climate action will cause warming to be highest in the medium-long term, with warming potential modelled to exceed 3°C. It is important to note that there is still risk in a delayed transition and Net Zero 2050 scenario, mainly due to the uncertainty surrounding the analysis of physical risks. This uncertainty is due to the potential to reach a tipping point, causing severe and unpredictable extreme weather events.

Table 3: Physical risks impact on The Group by time horizon and climate scenario

Scenario 1: Current policies (3 °C) - Business as Usual Scenario 2: Delayed transition (2 °C) - Late action taken Scenario 3: Net Zero 2050 (1.5 °C) - Smooth transition

Policies related to pollution

Vidrala does not disclose a specific named policy dedicated to pollution. Instead, the company addresses pollution prevention and control through its broader Environmental Management System and environmental policy.

Environmental Management System and Environmental Policy

Scope:

• Covers all Vidrala's production facilities
• Distributed and known to all employees
• Made available to all relevant stakeholders, including employees responsible for execution and external parties potentially affected by its outcomes
• Developed considering the interests of key stakeholders, including regulatory bodies, customers, employees, and local communities

Governance and oversight:

• The Group Environmental Manager holds ultimate responsibility for overseeing Vidrala's Environmental Management System (EMS)
• Ensures alignment with regulatory requirements and internal sustainability objectives

Key content and principles:

The environmental policy is centred on the precautionary principle and the following guidelines:

• Foster respect for the environment by preventing pollution, mitigating the environmental impact of processes and products, and reducing resource consumption; specifically committed to minimising energy consumption of operations
• Committed to efficient resource management
• Comply with applicable legislation and other commitments assumed by public administrations; scan for current or foreseeable legislative changes that could be applicable
• Drive continuous improvement at all levels by establishing ways to measure performance and impact of activity, planning for improvement and reviewing results; take into account certifications and basic audit tools in this process

Certification and standards:

• All of the Group's production facilities are currently certified under ISO 14001:2015 standards
• Processes initiated to implement and verify new environmental standards such as ISO 14064:2018 in 5 production facilities (related to voluntary declaration of CO2 emissions)
• ISO 50001:2018 on energy management systems already certified in 5 factories
• From April 2025, transition to a global group-wide verification for CO₂ footprint assessment

Material area commitments:

• Related to air: investing in cleaner technologies and promoting the use of renewable energy sources
• Related to water: committed to reduce potable water consumption in UK and EU plants up to 6% of total consumption and reduce up to 0.10 m³ per glass melted ton produced

Emergency response and monitoring:

• Emergency response plan to manage incidents effectively and minimise impact on people and the environment
• Standardised procedures for spill response in specific plants
• Predefined protocols for emission exceedances, with notification process to plant manager or environmental management officer and, if necessary, relevant authorities in accordance with regulatory requirements
• Centralized internal monitoring systems, including continuous and periodic measurements, assessing deviations against established budget and expected performance capacity

Public availability:

• Not specified (no URL or public location provided)

Link to international standards:

• Not explicitly disclosed

Actions and resources related to pollution

Vidrala Group implements Best Available Techniques (BAT) in line with ISO 14001:2018 guidelines. The approach to pollution management aligns with a tiered mitigation hierarchy involving prevention, reduction, and control of pollution.

Action 1: Upgrading automatic measurement systems across production facilities

• Description: Modernisation of automatic measurement systems to enhance ability to monitor pollutants in real time, allowing for more effective tracking and control of emissions
• Scope: Own operations (production facilities)
• Time horizon: Progressive implementation (specific dates not provided)
• Resources allocated:
  • Financial: €193,000 total investment
• Expected outcomes: More precise and proactive approach to pollution management; enhanced data collection and analysis capabilities
• Link to strategy: Aligns with broader pollution reduction strategy, supporting regulatory compliance and long-term sustainability targets; reinforces strategic goal of optimising pollution control measures

Action 2: Installation of electrostatic precipitators (electrofilters)

• Description: Installation of special systems for purifying atmospheric emissions in all production centres. Electrofilters act by retaining particles generated in the fusion process by attracting them through electric fields
• Scope: Own operations (all production centres)
• Time horizon: Recent years (completed)
• Resources allocated: Not quantified
• Expected outcomes: Reduction in usual emissions from glass melting furnaces by more than 90%; reduction of polluting particles
• Technology: Recognised as the best technology available for this purpose by European regulations

Action 3: Installation of SOx emission purification systems (desulphurisers)

• Description: Installation of desulphurisers accompanying the electrofilters to purify SOx emissions
• Scope: Own operations (production centres)
• Time horizon: Recent years (completed)
• Resources allocated: Not quantified
• Expected outcomes: Considerable reduction in SOx pollutant emissions

General resource allocation approach

• Vidrala allocates financial resources to initiatives focused on improving air quality, reducing industrial emissions, and enhancing environmental controls
• These measures are part of investment planning, but the methodology for assessing and publicly reporting financial commitments will be further developed
• Vidrala maintains an investment commitment specifically aimed at minimising the potential polluting effect of its facilities
• Future evaluation of actions related to value chain planned, as current impacts, risks and opportunities are associated with own operations

Targets related to pollution

Vidrala explicitly states that it is in the process of developing measurable outcome-oriented targets to manage pollution. No quantified targets are currently disclosed for pollution-related metrics.

Current Status

According to the disclosure:

"Vidrala is in the process of developing measurable outcome-oriented targets to manage pollution. Over the next two years, we will focus on defining sector-oriented targets aligned with national laws as requested, ensuring they are supported by a calculation baseline and references aligned with regulatory frameworks of the countries in which we operate."

"While formal targets are not yet in place, we are closely monitoring the effectiveness of our policies and actions in addressing the identified IROs."

Actions and Investments (not quantified targets)

• Automatic measurement systems upgrade: Investment of €193,000 allocated for modernising monitoring systems across production facilities
• Electrostatic precipitators: Installation across all production centres achieving >90% reduction in particle emissions from glass melting furnaces (compared to usual emissions, but no baseline year or absolute target provided)
• SOx emission purification systems: Installed alongside electrofilters

Pollution Emissions Data (monitoring, not targets)

These are actual emissions data under E2-4, not targets under E2-3.

Emissions

*Data restated to reflect our current perimeter, including Vidroporto and excluding the Vidrala Italy operations.

Vidrala maintains an investment commitment specifically designed to minimise the potential pollutant effect of its facilities. Of special importance in recent years, this concrete effort has materialised in the conclusion of an extensive investment project developed for the installation, in all the production centres, of special systems of purification of atmospheric emissions, denominated electrostatic precipitators or electrofilters. These installations are aimed at reducing emissions of pollutant particles and are recognised as the best technology available for this purpose by the European legislation. The installed electrofilters act to retain the particles generated in the melting process by attracting them through electric fields, reducing the usual emissions of glass melting furnaces by more than 90%. The electrofilters installed in Vidrala have been accompanied by systems for purifying SOx emissions, desulfurisers, which have considerably reduced the emission of this pollutant.

Substances of concern and substances of very high concern

Monitoring and Management

Vidrala's waste management strategy includes specific protocols for handling hazardous substances and substances of concern. The company implements a comprehensive approach that includes:

Risk Assessment and Identification: The company evaluates hazardous components including heavy metals in furnace dust, waste oils, and critical raw materials.

Specialised Containment and Storage: Dedicated hazardous waste storage facilities ensure containment before treatment.

Licensed Treatment and Disposal Partners: Vidrala works with certified waste treatment providers to ensure compliance with disposal regulations.

The company has obtained zero waste certification from Aenor, which verifies the amount of waste valorised and avoided from being sent to landfill. This certification is being extended to other group plants as the Waste Management System under ISO 14001 standard is implemented.

Hazardous Waste Data

Vidrala reports the following hazardous waste quantities for 2024:

Note: The company reports hazardous waste quantities but does not provide specific breakdown by substances of concern (SoC) or substances of very high concern (SVHC) as defined under REACH, nor does it break down by specific hazard classes (CMR, endocrine disruptor, PBT, vPvB).

Policies related to water and marine resources

Vidrala has adopted a specific policy to manage impacts, risks and opportunities related to water and marine resources.

Water Policy of Vidrala

Scope:

• All industrial operations
• All employees (internally available)

Governance:

• Led and monitored by the Group Engineering Director

Key principles and content:

The Water Policy of Vidrala establishes the company's commitment to responsibly manage the water resource in all industrial operations. The policy includes the following commitments:

• Efficient water use: Pledge to use water efficiently and responsibly in all operations, implementing technologies and practices to minimise water consumption and maximise its reuse within processes

• Water conservation: Adopt measures to conserve water in facilities, including leak repairs, optimisation of supply systems, and rainwater harvesting whenever possible

• Regulatory compliance: Comply with all regulations and standards related to water use and discharge, as well as water quality standards established by competent authorities

• Monitoring and evaluation: Implement monitoring and evaluation programs to measure and control water use, and identify opportunities for continuous improvement in water management

• Training and awareness: Provide training to employees on the importance of responsible water management and equip them with the tools and knowledge necessary to actively contribute to water conservation efforts

• Collaboration with stakeholders: Seek opportunities to improve efficiency and reduce environmental impact through collaboration with suppliers, customers, local communities, and environmental organisations

• Innovation and continuous improvement: Foster innovation and continuous improvement in water management practices

• Transparency and disclosure: Be transparent in water management and publicly disclose efforts, results, and challenges in this area to promote accountability and build trust with all stakeholders

Alignment with international frameworks:

• United Nations Sustainable Development Goals (SDGs), particularly Goal 6 (clean water and sanitation) and Goal 12 (responsible consumption and production)

Related plans:

The policy is supported by the Water Ambition 2030 plan, which aims to ensure responsible and efficient water management across all production sites, with objectives focused on defining water management practices, including measuring and reducing water usage, managing water-related risks, and implementing strategies to improve water efficiency and conservation.

Public availability:

• Internally available for all employees (no specific public URL mentioned)

Monitoring and implementation:

• The policy is led and monitored by the Group Engineering Director
• A Water Management System has been implemented to drive continuous improvements in water efficiency
• The company has implemented a state-of-the-art reporting system to monitor key variables, manage equipment and facilities, and measure performance

Actions and resources related to water

Vidrala has implemented a Water Management System designed to drive continuous improvements in water efficiency, with a focus on maximizing efficiency, minimizing environmental impact, and mitigating risks related to excessive water usage.

Water Ambition 2030 Plan

Target: Reduce water consumption by 50% by 2030, compared to 2018 baseline (intensity usage)

Scope: All production sites (own operations)

Time horizon: Long-term (by 2030)

Actions include:

• Specific reduction goals tailored to each community where Vidrala operates
• State-of-the-art reporting system to monitor key variables, manage equipment and facilities, and measure performance

Specific Water Management Initiatives

1. Reduction of water-cooled equipment

• Description: Implementing more efficient processes that minimize compressed air consumption, decreasing the number of operational systems and overall water demand for cooling
• Scope: Own operations
• Expected outcome: Lower overall water consumption

2. Water management improvements

• Description: Reducing internal movements, maximizing reuse cycles, and lowering overall consumption through improved water treatment to extend use across different processes
• Scope: Own operations
• Expected outcome: Enhanced efficiency and reduced environmental impact

3. Rainwater harvesting projects

• Description: Innovative projects for rainwater harvesting
• Scope: Own operations
• Time horizon: Short-term ("will soon be implemented")
• Expected outcome: Further strengthen sustainability strategy

4. Water treatment optimization

• Description: Optimizing water treatment processes and raising purification standards; improving quality of discharged water; maintaining high-quality discharge standards and investing in advanced treatment technologies
• Scope: Own operations
• Expected outcome: Enhanced water treatment processes and compliance with environmental regulations

5. Water recycling and alternative sources

• Description: Prioritizing alternative sources such as rainwater collection and water recycling to limit dependency on freshwater sources
• Scope: Own operations
• Expected outcome: Reduced dependency on external water sources

6. Regional water risk management

• Description: Proactive management of water consumption in regions subject to potential industrial water restrictions (specifically mentioned: Cataluña)
• Scope: Own operations
• Expected outcome: Minimize impact of regulatory constraints

Resources Allocated

Financial resources:

• Vidrala dedicates financial resources to initiatives aimed at reducing water consumption, minimizing wastewater discharge, and enhancing water treatment processes across facilities
• Investment in advanced treatment technologies
• Note: "While these measures are already integrated into our current investment planning, we are committed to further refining our approach to assess and report these financial commitments transparently." (No specific amounts disclosed)

Non-financial resources:

• Group Engineering Director leads and monitors the Water Policy
• Training programmes for employees on importance of responsible water management and water conservation efforts
• Stakeholder collaboration with suppliers, customers, local communities, and environmental organizations
• State-of-the-art reporting system for monitoring

Policy Linkages

All actions are linked to:

• Vidrala's Water Policy, which includes commitments to efficient water use, water conservation, regulatory compliance, monitoring and evaluation, training and awareness, stakeholder collaboration, innovation and continuous improvement, and transparency
• Water Ambition 2030 plan
• Alignment with UN Sustainable Development Goals 6 (clean water and sanitation) and 12 (responsible consumption and production)

Targets related to water

Water Consumption Reduction Target

Target metric: Water consumption (intensity-based)

Target value: 50% reduction

Target year: 2030

Baseline year: 2018

Baseline value: Not disclosed

Type: Intensity-based, voluntary target

Scope: Own operations; specific reduction targets tailored to communities where Vidrala operates

Validation: Internal (voluntary target, based on internal measurements and supported by technical knowledge and internal stakeholders)

Supporting systems: State-of-the-art reporting system implemented to monitor key variables, manage equipment and facilities, and measure performance

Progress to date: Not disclosed in the excerpts provided

Water consumption

*Data restated to reflect our current perimeter, including Vidroporto and excluding the Vidrala Italy operations.

Cullet and raw materials

*Data restated to reflect our current perimeter, including Vidroporto and excluding the Vidrala Italy operations.

In 2024, we managed to increase our cullet consumption by more than 53% per tonne of melted glass, which represents an 8% increase vs 2023 figures.

Policies related to own workforce

Vidrala has implemented several policies addressing its own workforce, as disclosed under ESRS S1-1.

Occupational Health and Safety Management System - Integrated Policy

Scope:
Applies to all employees and operations across all manufacturing sites.

Certification and standards:
The policy is governed by ISO 45001:2018 certification, ensuring all facilities operate under the highest health and safety standards.

Key content and principles:

• Reflects a strong commitment to safe, legal, and sustainable working conditions, prioritising employee well-being, equal opportunities, and professional development
• Applies to all employees and operations, ensuring compliance with best labour practices and a structured approach to risk prevention
• Emphasises consultation and dialogue with employees and their representatives, fostering inclusion and active participation in decision-making

Governance:
The Executive Leadership and Management Team are responsible for overseeing its implementation, ensuring alignment with labour laws, occupational safety standards, and industry best practices.

Public availability:
The policy is actively communicated through internal channels, training programmes, and compliance processes. It is published on the company website.

Implementation and monitoring:
The policy is supported by programs that foster a culture of prevention, such as the Behavioral Safety Program and the R3 initiative, which focuses on reducing exposure to risks, recycling safe habits, and reusing lessons learned to enhance workplace safety. Regular internal and external audits ensure compliance. Vidrala systematically provides accident prevention training, covering areas such as emergency response and incident investigation.

Human Rights Policy

Scope:
Applies to all Vidrala Group companies and suppliers.

Key content and principles:

• Enforces a zero-tolerance approach to modern slavery, human trafficking, and forced labour
• Prohibits child labour, forced labour, debt bondage, and ensures fair wages and safe working conditions
• Ensures non-discrimination and gender equality, prohibiting any bias in salary, hiring, training, promotion, maternity protection, or dismissal based on race, ethnicity, religion, age, disability, gender, or other protected characteristics
• Upholds political, philosophical, and religious neutrality and guarantees equal treatment for female employees

Alignment with international standards:
Developed in 2022 based on the Modern Slavery Act 2015 and international treaties including:

• United Nations Universal Declaration of Human Rights
• ILO core conventions

Governance:
The Executive Leadership oversees compliance, with regular audits and ESG reviews, including SEDEX membership and SMETA 4-Pillar audits covering labour practices, health and safety, and business ethics.

Monitoring and remediation:

• Suppliers must adhere to contractual anti-slavery clauses, and non-compliance may lead to contract termination
• The policy is communicated through supplier agreements, internal audits, and Vidrala's Whistleblowing Channel
• Vidrala continuously monitors adherence through supplier audits and self-assessment mechanisms
• The Audit Committee is informed at least once a year of any human rights violations
• No violations were registered in 2024

Public availability:
Available to all employees via the corporate intranet.

Code of Business Conduct

Scope:
Applies to all Vidrala Group employees.

Key content and principles:

• Annually updated document incorporating legal developments
• Serves as a guide for decision-making and staff conduct
• Zero-tolerance stance towards corruption and bribery

Supporting policies:
Supported by policies against corruption, fraud, and antitrust violations, alongside criminal compliance frameworks.

Governance:
Approved in 2019.

Public availability:
Conveyed to all new employees and available via the corporate intranet. Regularly sent to current employees by email.

Remuneration Policy

Key content and principles:
Establishes salary bands linked to the position held within the organisation, irrespective of gender, race, religion, etc., thus ensuring a fair and equitable remuneration scheme.

Additional policies and practices mentioned:

Employment practices:

• High proportion of indefinite contracts
• Flexible working arrangements where feasible
• Work-life balance through flexible schedules, hybrid work models for eligible roles
• Strong commitment to digital disconnection

Social benefit programs:

• Flexible remuneration schemes
• Voluntary early retirement options
• Work schedules tailored to operational needs
• Initiatives to enhance physical and mental well-being

Diversity commitment:
Vidrala holds the Diversity Mark Accreditation, certifying commitment to building diverse and inclusive working environments.

Taking action on material impacts on own workforce

Vidrala actively manages risks and maximises opportunities within its workforce through a combination of policies, processes, and programs specifically designed to address the needs of employees and evolving workplace dynamics.

Work Organisation & Flexibility

Flexible work schedules and regimes

• Scope: Own operations (adapted to specific characteristics of each plant and operational area)
• What it does: Balances production needs with personal demands of employees, reducing stress related to time management and improving work-life balance
• Link to policy: Work-life balance policies

Hybrid remote work systems

• Scope: Own operations (several roles)
• What it does: Reinforces commitment to adapting to new ways of working

Digital disconnection

• What it does: Ensures employees can enjoy personal time without work-related interruptions, contributing to emotional and mental sustainability in the long term
• Link to policy: Workplace policies

Psychosocial Risk Management

Continuous dialogue processes

• What it does: Addresses psychosocial risks related to workload, time management, and communication through structured processes including confidential interviews and consultations with prevention delegates
• Expected outcomes: Early identification of issues with personalised and effective solutions

Career Development & Compensation

Professional classification policies and flexible remuneration systems

• What it does: Enables employees to advance in their careers transparently and fairly
• Link to policy: Remuneration policy with salary bands linked to position held within the organisation, irrespective of gender, race, religion, etc.

Social benefit schemes

• What it does: Includes voluntary early retirement, paid leave, and reduced working hours
• Expected outcomes: Reinforces commitment to overall employee well-being

Well Being - Be Healthy Company Programme (2024)

Programme structure: Five areas adapted to each organisational habitat: nutrition, healthy sports, health, work-life balance, and corporate social responsibility

Nutrition initiatives

• Weekly fruit offerings
• Specific campaigns: cholesterol combat (nuts), cardiac defense (berries)
• Healthy food guidelines for work meetings and training sessions
• Online platform for purchasing local 'zero km' meat products
• Package delivery service in offices for online purchases

Healthy Sports initiatives

• Spinning classes (adapted to each habitat)
• Yoga practice
• Participation in corporate running events
• Activities accessible to everyone catering to diverse staff preferences

Health & Safety Programs

Behavioral Safety Program

• What it does: Fosters a culture of prevention involving all levels of the organisation
• Link to policy: ISO 45001:2018 Occupational Health and Safety Management System

R3 initiative

• What it does: Focuses on reducing exposure to risks, recycling safe habits, and reusing lessons learned to enhance workplace safety
• Scope: All levels of organisation with collaboration encouraged

Accident prevention training

• Areas covered: Emergency response and incident investigation
• Expected outcomes: Further reduce risks

Health support initiatives

• Regular health checks
• Ergonomics workshops
• Smoking cessation programs

Diversity & Inclusion

Equality Plan implementation

• What it does: Ensures impartial salaries and promotes gender diversity across all roles
• Link to policy: Equality Plan and equal pay policy to eliminate gender pay gap for the same job

Recruitment process improvements

• What it does: Eliminates unconscious bias with continuous assessment and refinement of practices to ensure discrimination-free workplace

Women and persons with disabilities integration

• What it does: Enhances integration, increases female representation in leadership roles, recruits underrepresented groups
• Expected outcomes: Cultural change and greater workforce inclusivity

Gender Pay Gap Mitigation

Strategies to address role distribution imbalances

• What it does: Addresses identified risk where women tend to occupy positions of lower responsibility and fewer roles in production area
• Expected outcomes: Foster equitable distribution of leadership opportunities and roles involving responsibility

Transition Planning (Under Development)

Evaluation of transition plan impacts

• Status: Currently evaluating direct impact links arising from Vidrala's transition plans
• Time horizon: Future projects in 2025 will focus on comprehensive analysis
• What it does: Addresses restructuring, employment changes, and opportunities for job creation or workforce development through reskilling initiatives
• Expected outcomes: Equip employees with skills needed to adapt to technological advancements and evolving industry requirements

Effectiveness Monitoring

The effectiveness of actions and initiatives is assessed through:

• Internal employee surveys
• Performance indicators
• Consultations with worker representatives
• Analysis of internal data on workplace climate, turnover rates, and health and safety
• Ongoing employee dialogue

Expected outcomes: Early identification of risks, implementation of corrective measures, and real impact measurement on job stability, working conditions, and professional development

Targets related to own workforce

Vidrala recognises the critical role its team plays in driving success and is committed to managing impacts, risks, and opportunities responsibly. The company presents outcome-oriented targets designed to address employee well-being and ensure effective management of workforce-related risks.

Monitoring and Tracking Approach

The effectiveness of policies and actions related to material sustainability impacts, risks, and opportunities is primarily tracked through:

• Qualitative assessments and workforce-related KPIs
• Employee engagement surveys
• Absenteeism rates
• Retention levels
• Health and safety performance indicators

The tracking process relies on internal reporting mechanisms, feedback gathered through employee consultations, and compliance with labour regulations and sustainability frameworks. Progress is evaluated based on continuous improvement and key workforce-related data points are regularly reviewed by HR and management teams to identify trends and areas requiring action.

Baseline Year

Vidrala currently monitors workforce indicators on an ongoing basis, without a formally established reference year. Future developments in sustainability objectives for employees may include the introduction of structured targets and a defined baseline year to enhance progress tracking.

Progress Indicators (2024)

• Voluntary turnover rate: 3.2% (improved from 5.0% in 2023)
• Total employee turnover: 10%
• Total employees: 4,886 (as of 31 December 2024)
• Employees who left: 475 during 2024

No specific quantified targets with target years are disclosed in the provided excerpts.

Characteristics of the undertaking's employees

Total headcount and distribution

As of 31 December 2024, Vidrala had 4,886 employees belonging to the different business units. According to voluntary turnover, the rate was 3.2%, improving from 5.0% in 2023.

Employees by country

*The Italian plant was divested in early 2024, and its operations are no longer included in the scope of the consolidated financial statements.

Gender distribution

Employees by professional category

Employees by age

Contract type breakdown

Permanent contracts by gender, age and professional category

Annual average of permanent contracts (calculated as the average over 12 months)

Temporary contracts by gender, age and professional category

Annual average of temporary contracts (calculated as the average over 12 months)

Part-time contracts by gender, age and professional category

Annual average of temporary contracts (calculated as the average over 12 months)

Employee turnover

The percentage of employee turnover was 10% and 475 left Vidrala during 2024.

Number of dismissals by gender, age and professional category

Annual number of dismissals (sum over 12 months)

Methodologies and Assumptions

Total Employees: The total headcount of employees at Vidrala is calculated by aggregating the employee count across all countries where the company operates. This calculation is based on an average taken over the reporting period.

Permanent Employees: Permanent employees are defined as those with an employment contract, regardless of whether it has a fixed-term or indefinite duration. This category also includes employees under partial retirement schemes. The calculation is based on an average headcount over the reporting period.

Temporary Employees: Temporary employees are those without a permanent contract and whose employment is limited to a defined period. This category includes employees working under fixed-term agreements.

Part-Time Employees: Part-time employees are defined as those whose working hours are less than 100% of a full-time schedule. This excludes employees on temporary parental leave with a reduced workload.

Employee Turnover: Employee turnover is assessed based on voluntary and involuntary departures. Specifically, dismissals are classified as non-voluntary exits, excluding resignations or retirements.

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

Methodology and Assumptions

Vidrala provides the following methodology for workforce calculation:

Total Employees

The total headcount of employees at Vidrala is calculated by aggregating the employee count across all countries where the company operates. This calculation is based on an average taken over the reporting period. Employee data is updated in internal systems.

Permanent Employees

Permanent employees are defined as those with an employment contract, regardless of whether it has a fixed-term or indefinite duration. This category also includes employees under partial retirement schemes. The calculation is based on an average headcount over the reporting period.

Temporary Employees

Temporary employees are those without a permanent contract and whose employment is limited to a defined period. This category includes employees working under fixed-term agreements.

Part-Time Employees

Part-time employees are defined as those whose working hours are less than 100% of a full-time schedule. This excludes employees on temporary parental leave with a reduced workload.

Non-Employee Workers

The document acknowledges the section to disclose "Characteristics of non-employees in the undertaking's own workforce" as determined in DR S1-7 from ESRS regulation, but does not provide specific metrics on the number of non-employee workers (contractors, agency workers, self-employed) in the own workforce.

The only reference to non-employees relates to health and safety monitoring:

Fatalities among other workers

• In 2024, Vidrala recorded 0 fatalities among contractors or external workers operating on our sites.

No quantitative data is provided on:

• Total number of non-employee workers
• Breakdown by type (contractor, agency, self-employed)
• Headcount vs FTE methodology for non-employees
• Multi-year comparisons of non-employee workers

Collective bargaining coverage and social dialogue

Overall coverage

100% of the workforce is partially or fully covered by collective bargaining agreements.

Geographic breakdown

Collective Bargaining Coverage

Social Dialogue - Workplace representation

Commitments and practices

Vidrala insists on strict compliance with the regulations of the International Labour Organisation and has established internal policies to ensure that all employees are supported. The company's Integrated Policy emphasizes consultation and dialogue with employees and their representatives, fostering inclusion and active participation in decision-making.

The company promotes social dialogue, ensuring that employees have a voice in shaping their working conditions, reinforcing engagement and productivity. 100% of employees are entitled to family-related leave through social policy and/or collective bargaining agreements.

All value chain workers can raise concerns, including grievances related to human rights, through the reporting system (https://vidralawhistleblowing.integrityline.com/).

Our commitment to People extends to creating a safe, diverse, and inclusive workplace, supported by initiatives such as our Women in Manufacturing (WIM) program, which fosters gender diversity in leadership and operational roles.

Engagement, Equality, Diversity, and Inclusion (EDI) are deeply embedded in our organisational culture and guide our efforts to create a workplace that reflects our values. We are committed to ensuring that every employee could thrive, contributing their unique perspectives and talents to our collective goals. Through strategic initiatives and a focus on continuous improvement, Vidrala aims to cultivate an inclusive environment where diversity drives innovation, collaboration, and sustainable growth.

Adequate wages

Benchmark Used

Vidrala does not disclose the use of a living wage benchmark. The company states:

"Vidrala Group presents a compensation strategy based on promoting both internal and external competitiveness, adapting to market circumstances and local conditions. The Group fosters a competitive and coherent remuneration system that ensures the satisfaction of basic needs while providing the opportunity for employees to enjoy an improved standard of living."

The disclosure references:

• Internal and external competitiveness
• Market circumstances and local conditions
• Collective Bargaining Agreements
• Legal minimum wage compliance

The Human Rights Policy mentions "fair wages" but does not specify a living wage methodology or benchmark.

Wage Data Disclosed

Vidrala provides comparative data showing internal minimum hourly wage, internal average hourly wage, and legal minimum hourly wage by country for 2024:

*Internal minimum wage relates to other services and represents less than 1% of total employees

*Internal average hourly wage calculated excluding Director salaries

The company states: "The data on our salary offerings across all countries illustrate consistency with the above principles, as well as alignment with our short-, medium-, and long-term compensation strategy."

Coverage

No specific coverage percentage is disclosed regarding assessment against any wage adequacy benchmark.

Geographic Scope

The wage data covers all six countries where Vidrala operates: Spain, Portugal, France, UK, Ireland, and Brazil.

Targets / Commitments

No specific targets related to living wage coverage are disclosed. The company states:

"The implementation of a 'Fair Wage' policy is not a one-time action but a continuous commitment that requires regular adjustments and adaptations to economic and social changes."

However, no quantified targets or timelines are provided.

Methodology

Vidrala does not disclose a specific living wage calculation methodology. The company references:

• Alignment with Collective Bargaining Agreements
• Social dialogue incorporation
• Variable compensation tied to performance
• Voluntary internal turnover as an indicator of compensation adequacy

The disclosure states that compensation strategy "ensures the satisfaction of basic needs while providing the opportunity for employees to enjoy an improved standard of living" but does not define how "basic needs" are calculated or assessed against living wage standards.

Social Protection

At Vidrala, we ensure that our employees are protected against income loss in the event of significant life events, including illness, occupational injury, parental leave, and retirement. These protections are provided in line with applicable employment terms and conditions, as outlined in employee contracts and internal policies.

Coverage

No quantitative data on percentage of employees covered by social protection schemes is disclosed. The company states that protections are provided "in line with applicable employment terms and conditions" but does not specify:

• Percentage of employees covered for sickness
• Percentage of employees covered for occupational injury
• Percentage of employees covered for parental leave
• Percentage of employees covered for retirement
• Percentage of employees covered for unemployment/disability
• Whether coverage is through public schemes, private schemes, or both
• Country-specific breakdown of coverage
• Specific exclusions by country or employee group

Persons with disabilities

Vidrala has grown in terms of hiring people with disabilities or handicaps, which already account for more than 1% of its workforce.

% of own employees with disabilities

Methodology and scope

Internal data have been used as a continuation of previous reports and in accordance with the respective legal framework of each region and/or country.

In addition, collaboration has been consolidated with Special Employment Centres and other external entities, composed of people with reduced abilities or physical and mental disabilities, who provide certain auxiliary services to Vidrala's main activity, under the direct coordination of professionals specialised in monitoring these professionals.

In 2024, we reached a total of 102,917 training hours through personalised development programmes and global initiatives all across Vidrala.

The One Horizon Programme, started in 2015, continues to play a pivotal role in the continual improvement of our talent. Renewed every three years, it targets over 350 operational leaders, including line managers, supervisors, and technical specialists. This programme focuses on cultivating skills from strategic short-, medium-, and long-term perspectives, facilitating the exchange of knowledge across the Group, and providing accessible online training to all participants.

Additionally, our Strategic Leadership Programme aims to enhance leadership and team management skills, empowering participants to drive the organisation towards achieving current and future objectives.

We encourage and motivate our employees through customised development programmes based on performance appraisals. These programmes identify specific training needs, considering challenges that require new or renewed skills and knowledge.

The Cantera Programme offers engineering students a nine-month professional experience. Participants work on real projects in a high-performance industrial environment whilst completing their final Bachelor's or Master's projects.

The Graduates Programme involves a one-year engagement on an operating internal project, combined with technical training, soft skills development, and language skills.

Health and safety metrics

Coverage of health and safety management system

100% of Vidrala employees are covered by health and safety management systems. The Health and Safety Management System is aligned with ISO 45001 and covers 100% of the Group's manufacturing facilities.

Fatalities

Recordable work-related accidents

Frequency rate (per 1,000,000 hours worked)

Severity rate (per 1,000 hours worked)

Work-related ill health

Vidrala identified 120 cases of work-related illnesses among employees in 2024. The identification and reporting of occupational diseases vary across geographical locations due to differences in legal frameworks and procedural approaches.

Days lost

The total number of lost workdays due to occupational accidents, work-related fatalities, and work-related illnesses in 2024 was 4,647 days.

Absenteeism

Methodology notes:

• Frequency rate calculated as (number of accidents / number of hours worked) × 1,000,000
• Severity rate calculated as (number of lost workdays / number of hours worked) × 1,000
• Absenteeism hours exclude maternity/paternity leave, illnesses, or justified absences
• Health and safety training provided: 39,496 hours in 2024

Work-life balance metrics

Family-related leave entitlement and uptake

Vidrala reports that 100% of employees are entitled to family-related leave through social policy and/or collective bargaining agreements. A total of 9% of employees took a family-related leave during the reporting period.

Work-life balance initiatives

Vidrala prioritises employee well-being through a range of benefits and flexible work arrangements, including:

• Professional classification systems
• Adaptable work schedules based on different shifts
• Flexible entry and exit times
• Paid leaves and sabbaticals
• Reduced working hours to support work-life balance
• Voluntary early retirement plans
• Social security systems
• Flexible compensation policies
• Hybrid work model tailored to different organisational environments (subject to validation by respective department heads)
• Digital disconnection culture to safeguard personal and family privacy
• Measures to respect employees' rest periods and vacations
• Discouragement of digital device use for work purposes outside designated hours

The company acknowledges that not all roles in production-based operations can benefit from remote work, and has adjusted compensation measures for employees whose positions require physical presence to ensure fairness across teams.

Compensation metrics

Pay gap

At Vidrala, we are committed to fostering an inclusive workplace that ensures equal opportunities for all employees, regardless of gender. We actively promote the meaningful participation of women in leadership roles across all levels of the company, reinforcing our dedication to equity in economic, operational, and strategic decision-making.

Pay equity is a fundamental human right, and we are dedicated to eliminating any gender-based wage disparities. We work closely with employee representatives to address this responsibility and ensure that our remuneration policies are fair, transparent, and aligned with our commitment to equality.

However, if we focus on the organisation's salary dynamics, we can see that the average salary for women is actually (3)% lower than for men (compared to (10.7)% in 2023 and (12.3)% in 2022). This disparity is directly attributable to the distribution of job roles, as women tend to occupy positions of lower responsibility and fewer roles in the production area, both of which contribute to a lower associated pay level. With this in mind, we are aware that there is still a great deal of work to be done in the corporate sphere. However, we know that addressing these imbalances is important, which is why we are implementing strategies to foster an equitable distribution of leadership opportunities and roles involving responsibility.

We also have a remuneration policy in place that establishes salary bands linked to the position held within the organisation, irrespective of gender, race, religion, etc., thus ensuring a fair and equitable remuneration scheme.

In addition, we also hold the Diversity Mark Accreditation, which certifies our commitment to building diverse and inclusive working environments, and is awarded to organisations that demonstrate significant progress in this area.

Remuneration ratio

In 2024, the CEO remuneration ratio compared to median Vidrala was 1:16.

Methodology

The average salary for women being 3% lower than for men is directly attributable to the distribution of job roles, as women tend to occupy positions of lower responsibility and fewer roles in the production area, both of which contribute to a lower associated pay level.

Average remuneration reported includes variable remuneration, mainly related to results and productivity, as well as other remuneration items (such as social benefits, retirement supplement, travel supplements and allowances, etc.). In order to improve comparability, the average remuneration by category does not include amounts related to multi-year variable remuneration of irregular perception.

Incidents, complaints and severe human rights impacts

Discrimination and harassment

Vidrala firmly opposes all forms of human trafficking, slavery, servitude, forced labor, and any related activities, as explicitly stated in our Human Rights Policy, developed in 2022 in alignment with the Modern Slavery Act 2015 and international treaties such as the United Nations Universal Declaration of Human Rights. This policy outlines the concrete steps we have taken—and continue to take—to ensure that modern slavery and human trafficking do not exist within our business operations or supply chain.

In the reporting period, we received 9 complaints through our Whistleblowing channel, mainly related to harassment or discrimination. Six of these communications were resolved.

Severe Human Rights Incidents

We have not identified any severe human rights incidents in our workforce in the reporting period. This includes incidents of forced labor, human trafficking, or child labor and complaints filed to National Contact Points for OECD Multinational Enterprises.

Fines, Penalties, and Compensation

There were no fines, penalties or compensations in 2024.

Value Chain Workers

Vidrala has not reported issues, complaints, or cases under investigation regarding high-risk worker groups in the value chain, reinforcing the effectiveness of its policies.

Business conduct policies and corporate culture

Vidrala has established comprehensive policies related to business conduct matters, embedded in its corporate culture to promote responsible behaviour at every level of the organisation. The company encourages continuous development and evaluation of corporate culture through periodic reviews, employee training, and stakeholder engagements.

Code of Business Conduct

• Scope: Group-wide scope; annually updated document that serves as a guide for decision-making and staff conduct
• Governance: Available to all employees via the corporate intranet; conveyed to all new employees
• Content: Incorporates legal developments and formalises Vidrala's responsible business aligned with core values
• Monitoring: Regularly sent to current employees by email; annual updates

Anti-Corruption, Anti-Bribery and Anti-Fraud Policy

• Approval: Approved in 2020
• Scope: Applicable group-wide
• Content: Zero-tolerance stance on corruption, bribery and fraud, ensuring transparency and adherence to ethical principles. Sets out applicable regulations, to whom the policy applies, basic general principles and the channel to communicate suspicions
• Training: Employees must report suspected violations via established channels, supported by compliance training. All employees are trained on these matters
• Standards: Interactions with public authorities adhere strictly to legal and ethical standards
• Monitoring: Software identifies suspicious behaviour involving purchases and payments. Continuous audit of purchasing, invoicing and treasury processes. Annual risk assessment to identify areas of high risk for corruption and bribery, focusing on geographic regions, high-value transactions, and areas with elevated risk levels
• Oversight: Audit and Compliance Committee operates independently to identify, prevent, obstruct and report criminal acts or fraud. Vidrala offered 10 hours of training to the Board and Executive Committee in 2024 related to specific critical risks

Whistleblowing Channel

• Scope: Open to both internal and external people
• Content: Secure whistleblowing system ensuring confidentiality and anonymity, enabling reports on breaches or misconduct
• Availability: Available on the corporate website at https://vidralawhistleblowing.integrityline.com/forntpage; management policy published in the channel
• Standards: Strictly adheres to laws transposing Directive (EU) 2019/1937
• Protection: Safeguards whistleblowers from any form of retaliation
• Monitoring: Created in 2022; continued use in 2024. Received 9 complaints in reporting period, mainly related to harassment or discrimination; six were resolved

Human Rights Policy

• Scope: All individuals impacted by Vidrala's operations and value chain
• Content: Prohibits child labour, forced labour, and exploitation while promoting fair wages, safe working conditions, and the right to unionise. Establishes firm commitment to protecting and promoting human rights across value chain. Explicitly prohibits forced labour, child labour, human trafficking, and all forms of discrimination
• Standards: Aligns with International Labour Organisation (ILO) and United Nations Universal Declaration of Human Rights
• Monitoring: Supplier and operational audits ensure compliance with ethical standards; enforces strict corrective action plans when non-compliance is identified. At least once a year the Audit Committee is informed of any human rights violations. No violations registered in 2024
• Partnerships: Reinforced by membership in initiatives like SEDEX
• Availability: Internally available
• Grievance mechanism: All value chain workers can raise concerns through reporting system

Supplier Code of Conduct

• Approval: Approved in 2022
• Scope: All suppliers and business partners; Group-wide scope
• Content: Sets out minimum ethical and behavioural standards aligned with the Group's values to secure safe working conditions, high ethical standards and environmentally responsible processes. Sets out human rights compliance framework that each supplier must accept. Requires suppliers to promote these principles in their own supply chains
• Governance: Mandatory framework integrated into contracts when concluding new commercial agreements
• Availability: Permanently available and accessible on corporate website; publicly available
• Monitoring: Sustainability audits, self-assessments, and access to facilities ensure ongoing compliance. Suppliers must provide full access to facilities, documents and records for audits. Corrective actions enforced for violations. 33 supplier audits carried out in 2024 (compared to 35 in 2023), 100% satisfactory
• Oversight: Quality Department responsible for carrying out supplier audits

Anti-Trust Policy

• Content: Addresses anti-competitive behaviour
• Training: All employees trained on this policy
• Monitoring: No infringements recorded or legal action brought in respect of anti-competitive behaviour or violations in 2024

Integrated Policy

• Scope: All operations, employees, suppliers, and stakeholders affected by Vidrala's activities
• Content: Ensures product safety, quality, environmental sustainability, and responsible business practices. Establishes commitment to ensuring safety and integrity of packaging solutions, preventing risks related to product contamination, material compliance, and environmental impact
• Governance: Compliance Officer holds most senior accountability
• Availability: Publicly available

Modern Slavery and Human Trafficking Statement

• Content: Outlines concrete steps taken—and continuing—to ensure that modern slavery and human trafficking do not exist within business operations or supply chain
• Governance: Executive Leadership oversees compliance
• Monitoring: Regular audits and ESG reviews, including SEDEX membership and SMETA 4-Pillar audits covering labour practices, health and safety, and business ethics. Suppliers must adhere to contractual anti-slavery clauses; non-compliance may lead to contract termination
• Transparency: Communicated through supplier agreements, internal audits, and Whistleblowing Channel

Governance Framework

• Board oversight: Led by Board of Directors composed of 11 non-executive members
• Committee oversight: Audit and Compliance Committee reviews and monitors risk management system. Sustainability strategy endorsed at Group level
• Implementation: Compliance Officer, supported by competent governing body, holds operational responsibility for ensuring worker engagement initiatives are effectively implemented
• Reporting: Board of Directors periodically reviews Risk Management System and analyses relevant risks, resulting in specific policies or actions for monitoring and mitigation

To ensure sustainable practices across our supply chain, Vidrala collaborates with suppliers to promote responsible sourcing, reduce carbon impacts, and meet our high environmental standards. These partnerships strengthen both our supply chain resilience and our environmental commitments.

Vidrala has developed a Sustainable Procurement Policy, aligned with the Supplier Code of Conduct which is based on the following principles:

▪ Sustainability Integration: our suppliers are integral partners in reducing greenhouse gas (GHG) emissions and enhancing circularity. Vidrala expects its suppliers to adhere to the Science-Based Targets initiative (SBTi) framework for emissions reduction in alignment with global climate goals.

▪ Climate Action: our suppliers must actively work to measure, report, and reduce Scope 1, 2, and 3 emissions, with priority given to innovations in energy efficiency and renewable energy adoption.

▪ Resource Efficiency: our suppliers are encouraged to optimise resource usage, implement recycling initiatives, and support Vidrala's mission to close the glass loop by maximizing the recycled content in production.

▪ Ethical and Social Responsibility: adherence to high standards of human rights, labor conditions, and workplace safety is mandatory for all suppliers. Vidrala promotes fair wages, diversity, and equitable working conditions across its supply chain.

▪ Transparency and Accountability: our suppliers are required to disclose their sustainability performance, including environmental, social, and governance (ESG) metrics, via standardised reporting frameworks.

▪ Continuous Improvement: Vidrala supports suppliers in their sustainability journey by providing resources, training, and partnership opportunities.

Vidrala has implemented a system to evaluate its highest-risk suppliers. Currently, a total of 370 suppliers are undergoing an assessment based on key criteria, including financial stability, compliance, business continuity, operational performance, Cybersecurity and ESG criteria. The ultimate goal is to analyse 100% of Vidrala's strategic suppliers to ensure they are fully ESG-compliant.

Prevention and detection of corruption and bribery

Vidrala does not tolerate any violations of its anti-corruption, anti-bribery and ethical policies and is committed to addressing any incidents that do occur.

Anti-Corruption, Anti-Bribery and Anti-Trust Policy

• Approval and year: Approved in 2020
• Key content: Sets out the applicable regulations, to whom the policy applies, the basic general principles and the channel to communicate suspicions regarding or clear violations of the policy. Also addresses the issue of anti-competitive behaviour.
• Scope: All employees (the Code of Conduct is conveyed to all new employees and is available via the corporate intranet; it is also regularly sent to current employees by email)
• Training: All employees are trained on these matters through onboarding training, online resources and training modules accessible to all employees
• Extension to value chain: References included in Supplier Code of Conduct

Prevention and Detection Framework

Vidrala has established a comprehensive framework to prevent and tackle corruption and bribery issues, which encompasses:

• An outlined policy describing the various forms of corruption and bribery, explicitly detailing the consequences of involvement
• Periodic risk evaluations to detect and address potential corruption and bribery risks
• Anonymous reporting channels through which employees and stakeholders can report suspicions or allegations of corruption and bribery securely and without fear of reprisal

Whistleblowing Channel and Management Policy

• Creation: Created in 2022
• Legal basis: Compliance with European Directive 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and its transposition into the legislation of the countries in which the Vidrala Group operates
• Aim: To ensure confidentiality around the complaint, thereby guaranteeing anonymity
• Public availability: https://vidralawhistleblowing.integrityline.com/forntpage
• Continued use: In 2024, the Vidrala Group continued to use the Whistleblowing Channel

Governance and Oversight

• Oversight body: Audit and Compliance Committee, as a delegated body of the Board of Directors
• Role: Operates independently and is tasked with identifying, preventing, obstructing, and reporting any operations involving criminal acts or fraud within the company's business activities. This ensures impartiality and effective oversight in addressing potential risks.
• Investigation process: After completing an investigation, the findings are communicated to the appropriate administrative, management, and supervisory bodies, who take the required actions based on the conclusions and recommendations. Comprehensive reports are kept on record to guide future policy decisions.

Training Programs

• Coverage: Comprehensive programs covering various aspects including the identification of corruption and bribery, reporting mechanisms, and preventive measures
• Mandatory: For all employees, with special modules designed for functions identified as higher risk
• At-risk functions: Total of 8 at-risk functions identified

Policy Review and Effectiveness

The company constantly reviews these policies to ensure their effectiveness and to incorporate best practices as they evolve.

Performance

In 2024, there were no infringements recorded or legal action brought in respect of anti-competitive behaviour or violations.

Incidents of corruption or bribery

Confirmed incidents

In 2024, there were no confirmed incidents of corruption or bribery at Vidrala.

Convictions and fines

There were no cases of non-compliance related to anti-competitive behaviour, corruption, bribery, money laundering or violation of human rights in 2024.

There were no convictions or legal decisions (criminal or administrative) recorded in 2024.

There were no fines, penalties or compensations paid for violations of anti-corruption or anti-bribery laws in 2024.

Disciplinary actions

Not disclosed.

Contracts terminated

Not disclosed.

Investigation procedures and speak-up mechanisms

Vidrala maintains a zero-tolerance stance on corruption, bribery and fraud, ensuring transparency and adherence to ethical principles. Employees must report suspected violations via established channels, supported by compliance training. Interactions with public authorities adhere strictly to legal and ethical standards.

Whistleblowing Channel: A secure whistleblowing system ensures confidentiality and anonymity, enabling reports on breaches or misconduct. This channel is available on the corporate website (https://vidralawhistleblowing.integrityline.com/forntpage), is open to both internal and external people, and its policy is published in the channel. Vidrala strictly adheres to the laws transposing Directive (EU) 2019/1937, safeguarding whistleblowers from any form of retaliation.

In 2024, the Vidrala Group received 9 complaints through the Whistleblowing channel, mainly related to harassment or discrimination (not specifically corruption or bribery). Six of these communications were resolved.

Prevention and Detection Procedures: Vidrala has established a comprehensive framework including:

• An outlined policy describing various forms of corruption and bribery
• Periodic risk evaluations to detect and address potential corruption and bribery risks
• Anonymous reporting channels
• Software that identifies suspicious behaviour involving purchases and payments
• Continuous audit involving purchasing, invoicing and treasury processes
• Annual risk assessment to identify areas of high risk for corruption and bribery

The Audit and Compliance Committee, as a delegated body of the Board of Directors, operates independently and is tasked with identifying, preventing, obstructing, and reporting any operations involving criminal acts or fraud.

Training: Vidrala offered a total of 10 hours of training to the Board and Executive Committee in 2024 related to specific critical risks, covering 100% of people at-risk functions. Training topics covered include definition of corruption, policies and procedures. The Anti-Corruption, Anti-Bribery and Anti-Trust Policy, approved in 2020, is conveyed to all new employees and is available via the corporate intranet.

Political influence and lobbying activities

Political engagement approach

Vidrala engages with governments, policymakers, and regulators on matters related to sustainability and business operations. The company reports engagement across upstream, own operations, and downstream activities through:

• Direct dialogue with policymakers, including Government Ministers, Members of the Legislative Assembly and departmental officials
• Answering public consultations
• White papers, programmes, and studies
• Joint initiatives and programmes (primarily focused on biomethane and hydrogen)

Vidrala collaborates with industry stakeholders including furnace manufacturers, energy providers, and policymakers to ensure access to low-carbon energy sources and supportive regulatory frameworks.

Industry and sustainability associations

Vidrala maintains memberships in trade associations and sustainability organizations, specifically:

• FEVE (European Container Glass Federation)
• ANFEVI (Spanish Glass Container Manufacturers Association)
• IPGR (International Partners in Glass Research) - where Vidrala is a relevant member

Through these associations, Vidrala provides:

• Inputs into strategic directions (including the Packaging and packaging waste directive)
• Workshops and knowledge sharing

The company identifies "Political engagement and lobbying activities" as demonstrating "commitment to important issues through associations, political engagement and lobbying to ensure that business and employee rights are upheld" (classified as an Opportunity).

Focus areas

Vidrala's advocacy and engagement topics include:

• Low-carbon energy access and supportive regulatory frameworks
• Packaging and packaging waste directive
• Biomethane and hydrogen initiatives
• Glass manufacturing sustainability and innovation
• Energy efficiency and decarbonization

Quantitative disclosures

No specific quantitative data on political contributions, lobbying expenditure, or trade association membership fees is disclosed in the report.

EU Transparency Register

No information is provided regarding registration in the EU Transparency Register or equivalent registries.

Payment practices

The standard payment terms of the Vidrala Group vary depending on the geographical region and the applicable regulatory framework. In Spain and France, legislation mandates that payments must be made within 60 days from the invoice date, a requirement that we have met in 62% of invoices in Spain and 68% in France. In the other countries where the Group operates – the United Kingdom and Ireland, Brazil, and Portugal – there are no legal deadlines for payment terms, with the average payment periods standing at 65, 27, and 70 days, respectively.

From a consolidated perspective across the entire Vidrala Group, the average supplier payment period in 2024 was 44 days from the invoice date, with 71% of the total amount paid within 60 days.

Consolidated metrics

Regional breakdown

Legal proceedings

There were no cases of non-compliance related to anti-competitive behaviour, corruption, bribery, money laundering or violation of human rights.