Wirtualna Polska Holding

Reference: page 94

Wirtualna Polska Holding describes the composition and oversight roles of its governing bodies. As at 31 December 2024 the Supervisory Board had 8 members (3 women, 37.5%; 5 men, 62.5%), with 6 members (75%) meeting independence criteria. The Management Board had 4 members (3 men, 75%; 1 woman, 25%). There is no employee representative on the Management Board, and the composition of Group bodies does not distinguish between executive and non-executive members.

Oversight of impacts, risks and opportunities is distributed across several bodies: the Supervisory Board Committee for Sustainable Development Strategy, the Audit Committee within the Supervisory Board, the CFO (responsible for the sustainability area, currently Elżbieta Bujniewicz-Belka, with the Director of Corporate Communication and the Investor Relations Director reporting to her), and the Strategy and Development Committee as an advisory body to the Management Board. Day-to-day management of IROs sits with business owners of the respective areas, who escalate significant changes to the Management Board or Supervisory Board. The company notes its ESG oversight policy is not formalized yet, as it is testing approaches before committing best practice to a written policy.

The Sustainable Development Strategy Committee is a permanent advisory and opinion-forming body of the Supervisory Board, composed of at least three members, that reports on its activity to the Supervisory Board at least once a year. The disclosure covers target setting and monitoring: the Supervisory Board and Management Board set targets on a semi-annual basis, with variable remuneration of the Management Board dependent on achievement, and the Supervisory Board receiving regular semi-annual progress reports.

On access to expertise and skills, the company states that both Boards have knowledge of sustainability across its three pillars (governance, social, environmental) and are familiar with frameworks such as the UN Sustainable Development Goals. Members update their knowledge through bodies including the 30% Club Poland and the Polish Association of Listed Companies (SEG), and have access to external advisors and training by sustainability specialists.

Reference: page 96

The company describes how sustainability information reaches its governing bodies. A review of the Group's risks is moderated by the Internal Audit Manager once a year, at the end of the fourth and first quarters, covering risks, opportunities and changes in how the environment affects the organization. The Audit Committee of the Supervisory Board is informed of the results. The review is prepared on the basis of meetings with the management of subsidiaries and the parent company.

Monitoring of relevant impacts, risks and opportunities is the responsibility of departmental managers, with escalation to the Management Board or Supervisory Board when there are significant market changes. The Group runs periodic materiality assessments to support ESG reporting and management, and the results are presented to the CFO and the Sustainability Committee, which reports to the Supervisory Board at least once a year.

The Management Board and Supervisory Board take impacts, risks and opportunities into account when overseeing strategy, key transactions and the risk management process. The disclosure lists the risk-management processes the Boards cover, including assessment of business impacts (market trends, competitiveness, technological innovation), analysis of social, environmental and economic impacts, operational risk management, strategic/long-term risk management, ethical and legal risks, innovation, financial aspects of decisions, environmental and societal impact (including greenhouse gas emissions), and compliance with legal regulations.

Throughout 2024 the Management Board analyzed a number of risks monitored through internal audit, including risks related to climate change and sustainability. The basis for the 2024 review of impacts, risks and opportunities was the prior year's risk map and the expert report Risk in Focus 2024. The way sustainability matters were addressed is further described in the SBM-3 section and in topical disclosures.

Reference: page 97

The company explains how sustainability performance is linked to remuneration. Management Board members receive fixed remuneration set monthly by Supervisory Board resolution, reviewed no more than once a year. They may also be entitled to variable remuneration in the form of bonuses for meeting bonus targets, and part of this remuneration has been linked to sustainability targets since H2 2021, at at least 5%. The ESG weighting in the overall management targets is generally about 5%.

Importantly, the company notes that sustainability targets currently do not directly include carbon footprint reduction. Instead, a mid-term target was set for the second half of 2024 to develop a methodology to calculate Scope 3 emissions and produce preliminary estimates. Achievement of strategic sustainability targets, including those related to climate change, is taken into account only in the compensation system for Management Board members.

In setting the variable-remuneration targets, the Supervisory Board is guided primarily by the business strategy and the long-term interests and stability of the company, and the targets cannot be contradictory to its short- and long-term interests.

Supervisory Board members may only receive fixed remuneration, determined by Shareholder Meeting resolution. Selected members holding functions such as Chairperson, Deputy Chairperson or committee membership may receive additional remuneration, but this may not be variable or linked to any performance, including financial performance.

Reference: page 97

The company provides a statement on due diligence in the form of a mapping table that links the core elements of the due diligence process to the relevant sections of the sustainability statement. The five core elements and their corresponding disclosures are:

• Embedding due diligence in governance, strategy and business model: E1-2, S1-1, S4-1, G1-3, GOV-2, GOV-3, SBM-3
• Engaging with affected stakeholders in all key steps: S1-2, S4-2, SBM-2
• Identifying and assessing negative impacts on people and the environment: IRO-1, SBM-3, GOV-5
• Taking action to address negative impacts on people and the environment: E1-3, S1-3, S4-3, G1-3
• Tracking the effectiveness of these efforts: E1-2, S1-5, S4-5

The table directs readers to where each part of the due diligence process is described elsewhere in the statement rather than restating the content in this section.

Reference: page 98

The company states that there are no specified sustainability controls within the unified internal control system. The identification of risk and opportunity levels is a separate process, carried out as part of the materiality assessment by a designated group of employees with the support of a specialized external consultant, with results accepted by the Management Board.

Within the risk management and internal audit system, which covers the entire scope of the Group's operations including sustainability matters, the main elements are: identification of risks and opportunities, identification of the most significant (material) ones, and, where possible, assignment of measures and business owners for active management, based on independence, objectivity and rationality. Risks, including sustainability risks, are assessed across the dimensions of probability, impact on the Company's operations, impact on financial performance, and impact on the Group's operations, with selected risks considered over short-, medium- and long-term horizons.

The main risks identified are described in Management's report on the activities of the Company and the Group (pages 46 to 55), and include business resilience, supply chain and e-commerce risks (with personal data protection as mitigation), and risk of changes in the employment structure. The separate double materiality process takes these results into account, focusing solely on sustainability issues, and is described on pages 114 to 116. Where material sustainability risks are found not to be allocated, they are assigned to the relevant company or department.

Internal audit plays a significant role in ensuring the accuracy and credibility of reported information. Based on the Internal Audit Charter, it covers all companies and is responsible for risk identification and for preparing and updating the risk map, which is moderated by the head of internal audit. ESG and environmental issues appear in the risk map because they are raised by stakeholders in interviews, including guided interviews referencing the World Economic Forum Global Risks Report. In 2024 internal audit paid particular attention to preparation for non-financial reporting and did not identify any processes that would prevent accurate and reliable reporting.

Reference: page 99

Wirtualna Polska Group is described as a technology holding conducting media, advertising, subscriptions and e-commerce activities. Its registered office is in Warsaw, with other Group companies in Gdańsk, Wrocław, Lublin, Chorzów and Miskolc. The Group owns the WP Home Page, operates specialized topical websites, and offers subscription services (Audioteka, Pilot WP, WP E-mail). In e-commerce it operates mainly in tourism (Wakacje.pl, the Szallas Group, Nocowanie.pl) and consumer finance (Superauto.pl and Totalmoney.pl). It operates primarily in Poland and, since acquiring the Szallas Group and Audioteka in 2022, across Central and Eastern Europe, including Hungary, Czech Republic, Romania, Croatia, Germany and Lithuania.

The disclosure connects the Sustainable Development Strategy to operations through several themes. On the environment, due to the high energy consumption of server farms the Group works to minimize its carbon footprint, purchasing renewable energy backed by certificates of origin and producing photovoltaic energy through WP Naturalnie. On society, employees are presented as the foundation of the Group, with priority placed on a respectful, diverse and supportive work environment. On credibility and accountability, the Group emphasizes its role as a supplier of reliable information, with independence and objectivity as strategic priorities.

On responsible investments and business cooperation, the Group states it does not operate in sectors related to fossil fuel, chemical production, controversial weapons or tobacco products. It has adopted the rule that the value chain downstream includes only end users, so business partners that could also be classified as customers (such as advertising agencies, global technology platforms, tour operators or owners of tourist facilities) are classified as upstream suppliers.

The disclosure presents the Group structure (the parent and subsidiaries across the Advertising and Subscriptions, Tourism, Consumer Finance and Other segments, including the Audioteka and Szallas sub-groups) and a detailed value chain description covering resource inputs, outcomes and benefits for clients, investors and stakeholders, and the upstream, operations and downstream actors for each segment.

Reference: page 105

The company describes how it identifies and engages with stakeholders. Key stakeholders were identified during the materiality assessment, using an analysis of the Group's business model and value chain and a survey among representatives of all major management areas, who assessed the strength of each stakeholder's influence on the Group and the Group's influence on the stakeholder. During the assessment, additional interviews and surveys were conducted primarily with upstream representatives (suppliers and business partners).

The disclosure identifies six stakeholder groups and the corresponding engagement methods:

• Investors: regular contact, annual and quarterly results publication, face-to-face meetings, conferences and a dedicated website
• Business partners and suppliers: business meetings, conference participation and media partnerships
• Society (website users, viewers, listeners): periodic surveys such as the Wirtualna Polska Image Survey and satisfaction surveys, plus the Customer Service Office and commenting on published content
• Customers: regular contact and satisfaction surveys for the WP Advertising Office and e-commerce services
• State institutions, regulators and legislators: industry conferences, consultations and disclosure obligations
• Employees and associates: internal stakeholders whose job satisfaction is monitored on an ongoing basis

The Group states that it regularly analyzes the outcomes of stakeholder engagement, including studies such as NPS and internal "pulse check" employee surveys, which are presented during Supervisory Board and Management meetings. As a result, both the Management Board and Supervisory Board have full access to the views of key stakeholder groups and can make informed decisions on the strategy and business model.

Reference: page 106

The materiality assessment identified material impacts, risks and opportunities across the Group's material topics: climate change (counteracting climate change/mitigation and energy), own workforce (employment-related working conditions and equal treatment and equal opportunities), consumers and end-users (impact of information, personal safety, and social inclusion), and business conduct (corporate culture, protection of whistle-blowers, management of supplier relationships, and corruption and bribery).

Key impacts include negative climate impacts from emissions related to IT infrastructure, growing energy demand and company cars, plus emissions from use of the Group's portals, alongside a positive impact from publishing content that raises climate awareness. On own workforce, positive impacts come from good working conditions, diversity support and development, while negative impacts include work intensity and stress, perceived instability (including group layoffs at WP Media) and a 22% uncorrected gender pay gap in 2024. For consumers, impacts include fact-checked content supporting impartial debate, price discrepancies in the travel segment, data protection, and the use of user activity for advertising. Business conduct impacts include strong ethics codes, limited capacity to monitor supplier compliance (a Supplier Code of Conduct was created in December 2024), and anti-corruption rules.

Key risks include operational disruptions from extreme weather and electricity supply interruptions, costs of meeting carbon-reduction regulatory expectations, rising energy costs, competition for talent and labor costs, undetected discrimination or bullying, unauthorized publication of malicious content, GDPR violation and data leakage, partner bankruptcy in tourism, multi-jurisdiction compliance difficulty, and corruption. Key opportunities include cost optimization through renewable energy, energy efficiency improvements, HR strategy development, holding the position of independent media, growing market share through verified content, and building trust by advocating for underrepresented groups.

The company states that the identified IROs have already been covered by the Group's strategy and strategic activities, with each area managed by its owners. Climate IROs are managed through E1-2 and E1-3 (including the Climate and Environmental Policy), employee issues through S1 policies (Diversity Policy, Code of Ethics), consumer issues through S4 disclosures (Code of Journalistic Ethics, cybersecurity, Personal Data Policy), and governance through G1 disclosures. In the E1 section the disclosure notes that, as part of the risk map update, a risk related to the increase in average temperatures and its potential impact on the Group's data centers was identified and included in the double materiality analysis, managed through crisis management procedures and environmental impact management. The Group believes the Sustainable Development Strategy ensures resilience to significant risks in the short- and medium-term horizon and plans to systematically monitor IROs to assess long-term resilience.

Reference: page 114

The company describes its double materiality assessment, conducted in 2023 and 2024 with support from an external consulting firm using the MAX 4 methodology (version 4 of the Materiality Assessment Matrix). The externally supported part is based on a matrix analysis of impacts, risks and opportunities from both the impact materiality and financial materiality perspectives. The study object was the impacts, risks and opportunities associated with all 90 sustainability issues taken into account in the AR16 ESRS 1 table.

The sources of information used included analysis of the Group's business model, strategy and value chain model; a comparative analysis of 17 media players from Poland and worldwide based on the IROs they identify in their sustainability reports; a questionnaire survey of 25 representatives of key management areas; a detailed questionnaire survey of 25 area experts; an assessment of detailed materiality parameters by three experts of the external consultant; and a questionnaire survey and structured interviews with 8 representatives of key external stakeholder groups. Representatives of employees participated in the survey; no other directly affected stakeholders did. This part of the assessment was conducted between November 2023 and February 2024, with a validation workshop held on 16 February 2024 attended by the CFO, and at the end of 2024 it was updated with the results of questionnaire surveys and interviews with external stakeholders.

The remainder of the assessment involved identification of specific IROs by in-house experts through workshops, including due diligence elements such as value chain analysis and risk map analysis, using internal data (questionnaire surveys, NPS reports, satisfaction surveys) and external data (sustainability reports, the Klimada 2.0 tool, industry reports). Scores were assigned based on ESRS parameters. The analysis focused mainly on the Advertising & Subscriptions and Tourism segments, which together accounted for 86% of 2024 revenues, but also covered Consumer Finance and Other.

For impact materiality, four parameters were assessed (strength, scope, irremediable character, and probability), each scored 1 to 5, with severity calculated as the average of scale, scope and irremediable character, weighted by probability, against a materiality threshold of 2. For financial materiality, risks and opportunities were assessed on scale of effect (scored 1 to 5) and probability (scored 1 to 5), with materiality calculated as scale weighted by probability, also against a threshold of 2. As a result, material IROs were identified with corresponding data points in the ESRS E1, S1, S4 and G1 areas. The section also documents the analysis showing ESRS E2, E3, E4 and E5 were assessed as not material, and that G1-5 and G1-6 were deemed non-material.

Reference: page 117

The company presents an ESRS compliance table listing the disclosure requirements covered by the statement and their page references. The statement covers ESRS 2 General disclosures and the topical standards assessed as material: E1 (Climate change), S1 (Own workforce), S4 (Consumers and end-users) and G1 (Business conduct).

The disclosure confirms that the topics in ESRS E2, E3, E4, E5 and ESRS S2, S3 were identified as not material in the materiality assessment and are therefore not reported. Within G1, the company also assessed G1-5 (Political influence and lobbying) and G1-6 (Payment practices) as not material.

Several disclosure requirements are omitted under the Appendix C phase-in available in the first year of the sustainability statement. These include E1-9 (anticipated financial effects from material physical and transition risks and climate-related opportunities), S1-7 (characteristics of non-employees in the own workforce), S1-11 (social protection), S1-12 (persons with disabilities), S1-13 (training and skills development), and S1-15 (work-life balance). The statement does not include disclosures concerning the expected financial effects of risks.

The table also includes a second list mapping data points in cross-cutting and topical standards that derive from other EU legislation, indicating the page reference or non-material status for each. The disclosure notes that 2024 was the first year the Group prepared its statement under the ESRS, and that the report was reviewed externally by PricewaterhouseCoopers Polska under the applicable limited assurance standards.

Reference: page 124

In 2024, the Wirtualna Polska Holding Group did not have a formalized climate transition plan. Plans to decarbonize the business model are instead included within the Group's Sustainable Development Strategy.

The Group plans to adopt and disclose a transition plan within the next three years, which is the transition period allowed under the ESRS.

Reference: page 126

The Group has adopted a Climate and Environmental Policy to manage environmental and climate change issues. Key points:

• Addresses climate change mitigation through targets such as climate neutrality in Scopes 1 and 2 by 2030, plus calculation and reduction of Scope 3 emissions.
• Promotes renewable energy use and energy efficiency improvements.
• Aims to address negative impacts from IT infrastructure emissions and risks from rising energy costs, reduced-carbon-footprint expectations, and regulatory requirements.
• Applies to all WPH Group subsidiaries and covers own operations as well as the upstream and downstream value chain (Scope 3).

Implementation is overseen by the Sustainable Development Strategy (ESG) Committee and managed by the Chief Financial Officer. Carbon footprint (Scope 1, 2 and 3) is monitored on a semi-annual and annual basis under the GHG Protocol, with annual ESG risk updates. The policy reflects commitments under the UN Global Compact and the GHG Protocol, and is publicly available on the WPH website.

Reference: page 126

Since 2021, the Group has taken action to increase renewable energy use:

• Electricity for server rooms is covered by guarantees of origin confirming renewable sources.
• Began generating electricity from a 3 MWp photovoltaic plant and commissioned an additional 1.85 MWp plant in May 2023.
• In 2024, expanded coverage to several Group offices. Overall, the Group purchased 9,129.90 MWh of energy covered by guarantees of origin, covering 95% of the Group's electricity needs.

Further actions include energy efficiency improvements in data centers (expanding the building management system / BMS and densifying computing power) and climate education (more than 700 articles on environmental issues published in 2024).

The Group has also taken out a Sustainability Linked Loan, where the margin is tied to ESG goals (including increasing the share of photovoltaic-generated energy in total electricity consumption).

In 2024, the Group did not estimate spending on policy-related activities; key indicators required under Commission Delegated Regulation (EU) 2021/2178 are presented in the EU Taxonomy section.

Reference: page 127

Climate-related targets set in the 2022-2030 Sustainable Development Strategy:

• GHG reduction (Scopes 1 & 2): -70% by 2025 compared to base year 2019; net-zero (0 Mg CO2e) by 2030 per the SBTi methodology.
• Energy efficiency of data centers and buildings: server room energy audit, ISO 50001 certification, and periodic internal audits.
• Zero- and low-carbon energy: 80% share of zero-carbon energy in the electricity mix and 90% share in the heating energy mix.
• Scope 3: perform calculations for 2022 and set a reduction target, with consistent attainment of reduction targets across all 3 scopes under the GHG Protocol.
• Energy poverty: transfer/purchase electricity from own RES installations for public benefit (100% of excess production directed to those in need).
• Climate education: 1,000 published materials by 2025, rising to 1,200 materials per year by 2030.

Important caveats stated in the report:

• These targets are not consistent with the requirements set forth in the ESRS; in the reporting year the Group was still aligning its policies with ESRS and MDR-T.
• The Strategy's reference year is 2022, but for reporting purposes the Group has adopted 2024 as the base year.
• Targets are consistent with limiting global warming to 1.5C, but have not been externally reviewed (not yet SBTi/1.5C validated).
• The Group plans to develop SBTi-based reduction targets and approve GHG Scope 1 and 2 reduction targets in Science Based Targets, and to develop emission reduction targets within a forthcoming 2025-2030 strategy.

Reference: page 129

The Group's 2024 energy consumption and mix:

• Fuel consumption from coal and coal products: 0.00 MWh
• Fuel consumption from crude oil and petroleum products: 2,348.18 MWh
• Fuel consumption from natural gas: 332.37 MWh
• Fuel consumption from other fossil sources: 0.00 MWh
• Purchased electricity, heat, steam and cooling from fossil sources: 1,431.24 MWh
• Total energy consumption from fossil sources: 4,111.79 MWh (share: 30.95%)
• Consumption from nuclear sources: 0.00 MWh (0.00%)
• Fuel consumption from renewable sources (incl. biomass): 0.00 MWh
• Purchased electricity, heat, steam and cooling from renewable sources: 9,129.90 MWh
• Self-generated non-fuel renewable energy: 44.81 MWh
• Total energy consumption from renewable sources: 9,174.70 MWh (share: 69.05%)
• Total energy consumption: 13,286.50 MWh

Energy intensity in high climate impact sectors: 9.31 MWh/PLN million (Superauto) and 15.90 MWh/PLN million (WP Naturalnie). Net revenue from high climate impact sectors used to calculate intensity: PLN 148 million.

The Group also reported gross generated electricity of 5,244.81 MWh, all from photovoltaics (heating energy generated: 0.00 MWh; net electricity fed into the grid: 0.00 MWh).

Heat energy and office-building electricity values were partly estimated where precise consumption data could not be determined. The indicators were not verified by any external body other than the assurance service provider.

Reference: page 131

The Group reports Scope 1, 2 and 3 emissions for 2024 (the base year), calculated using GHG Protocol tools with the assistance of an external consultant. Figures are in tons of CO2 equivalent (t CO2e):

• Gross Scope 1 GHG emissions: 639.97 t CO2e (0% from regulated emission trading schemes)
• Gross Scope 2 GHG emissions (location-based): 6,029.49 t CO2e
• Gross Scope 2 GHG emissions (market-based): 516.58 t CO2e
• Total indirect gross Scope 3 GHG emissions: 255,655.71 t CO2e (printed in source as "2,556,55.71")

Scope 3 by category:

• Cat. 1 Purchased goods and services: 11,663.17 t CO2e
• Cat. 2 Capital goods: 1,731.11 t CO2e
• Cat. 7 Employee commuting: 793.08 t CO2e
• Cat. 11 Use of sold products: 236,181.02 t CO2e
• Cat. 14 Franchises: 2,004.36 t CO2e
• Cat. 15 Investments: 2,389.26 t CO2e

Totals:

• Scopes 1+2 (location-based): 6,669.46 t CO2e
• Scopes 1+2 (market-based): 1,156.55 t CO2e
• Scopes 1+2 (location-based) + 3: 262,325.17 t CO2e
• Scopes 1+2 (market-based) + 3: 256,812.26 t CO2e

Notes on Scope 3: much of it is estimated (the Group obtained only 1.02% direct data and 0.03% primary data). Categories 10 and 9 are not reported as they do not occur in the Group's operations, and categories 3, 4, 5, 6, 9, 12 and 13 were considered not material. Several categories (7, 11, 14, 15) were estimated using spend-based, distance-based and average-data methods with DEFRA, EPA, KOBIZE, URE, Ademe and IEA emission factors.

Emissions intensity per net revenue: Scopes 1+2 location-based 4.25 t CO2e/PLN million, market-based 0.74; including Scope 3, 167.30 (location-based) and 163.78 (market-based).

Reference: page 134

In 2024, Wirtualna Polska Holding did not acquire carbon credits. The disclosure on GHG removals and carbon credits is treated as not material in the report's content index.

Reference: page 134

In 2024, Wirtualna Polska Holding did not apply an Internal Carbon Price.

Reference: page 151

Wirtualna Polska reports that its workforce policies were originally developed for internal purposes and do not, in all cases, meet the ESRS MDR requirements, as most predate the introduction of ESRS. The Group will assess whether and how far to adjust them.

Key policies and commitments:

• Code of Ethics (overriding document) committing the Group to respect for human rights and dignity, compliance with applicable human rights laws, and prohibition of slavery, human trafficking and exploitation of minors. It explicitly addresses forced and child labor.
• Respect for all International Labour Organization (ILO) Conventions and reference to the UN Charter (1945), the Universal Declaration of Human Rights (1948), the International Bill of Human Rights, and the 1966 Covenants.
• Diversity Policy (adopted 2022) covering all Group workers, managing equal treatment, equal opportunities and working conditions regardless of gender, ethnicity, religion, age, health condition or gender identity. It promotes transparent recruitment, combats harassment and discrimination, supports well-being and references the Diversity Charter and the UN Global Compact. It is publicly accessible on the WPH website. Responsibility sits with Management Team members overseeing corporate governance and HR; monitoring is by the Supervisory Board's ESG Committee.
• Whistleblowing procedure with a communication channel for reporting potential violations.

Responsibility for defining policy objectives, adopting policies and overseeing implementation lies with the Management Board or its designees.

The Group notes it does not have separate policies addressing employment security, working time, adequate remuneration, social dialogue, work-life balance, equal pay for work of equal value, training and skills development, or the employment and inclusion of persons with disabilities, though it undertakes activities in these areas (described in S1-4). It also does not apply dedicated procedures specifically for preventing or responding to discrimination or for increasing diversity and social inclusion beyond the Code of Ethics, Diversity Policy and Whistleblowing Procedure.

Reference: page 153

The Group engages its workforce primarily through regular anonymous surveys and feedback mechanisms.

• At least once a year, the Group conducts a detailed, anonymous employee satisfaction survey covering working conditions, development opportunities, work-life balance, internal communication and confidence in the Management Board. Results are analyzed by company management teams and communicated back to all employees.
• Two types of anonymous employee opinion surveys are carried out regularly during the year. All employees and associates take part, including those who are particularly vulnerable or marginalized. Topics include acceptance of diversity, the company's care for employees, and satisfaction with measures supporting physical and mental well-being.
• The Group operates a Leadership Trust Index (LTI) measuring employees' trust in their direct manager, on a scale from -100 to +100, which is positive in each holding company. LTI provides feedback to help leaders improve dialogue and leadership skills.

Employee opinions feed into decisions on identifying areas for improvement, planning corrective actions and strategies, transparency and engagement, monitoring progress and trends over time, and promoting diversity and equality.

Reference: page 154

The Group provides a whistleblower communication channel for reporting potential violations of law or internal regulations, reviewing the effectiveness of measures on an ongoing basis. The number of confirmed whistleblower reports is one of its indicators, reported at Board meetings with discretion and confidentiality. In 2024, there were no reports from whistleblowers.

Every employee and associate may report unwelcome conduct toward themselves or others, including anonymously, through multiple channels:

• online, via a form
• to the HR Business Partner
• to any Employee Council member
• to a direct supervisor or Division Director
• to etycznawp@grupawp.pl (accessible to the Head of the Legal Department and the Ethics Officer)
• to the Management Board of Wirtualna Polska Holding S.A.
• to the Supervisory Board of Wirtualna Polska Holding S.A.
• to the Compliance Officer in person, by email or traditional mail

Upon receipt of a report, an Irregular Conduct Commission is established within 2 days, and it begins its investigation no later than 7 days after appointment.

The procedure for reporting and following up irregularities and breaches of law is designed in compliance with the Whistleblower Protection Act, providing whistleblower protection, prohibition of retaliation, and a transparent handling process for internal and external reports, with personal data processed in accordance with GDPR. Every employee and associate is required to complete training on counteracting workplace harassment and discrimination.

Reference: page 155

Workforce risks are integrated into the Group's risk management process and internal risk map, with personnel risks (notably availability of qualified staff) among the most important. Mitigation measures include a partnership with a university, a strategic approach to remuneration levels within company budgets, and manager training initiatives. Business continuity processes address retention of employee knowledge and protection of key personnel.

Mental and physical health and well-being:

• Access to Luxmed private medical care, FIT Profit and FIT Sport cards
• Access to the gym and group insurance
• The Worksmile cafeteria platform, where employees receive Social Security funds for sports subscriptions or entertainment
• Psychological consultations, webinars/workshops on mental health, preventive health care, dietetics, BadaBus (testing for women), mobile blood donation, first aid training
• A specialized online platform supporting mental health and resilience

Competitive and developmental working conditions:

• Promotion of growth opportunities within companies and the Group
• A remuneration policy for the Management Board and Supervisory Board is implemented; a remuneration policy for all employees is to be implemented in 1-2 years
• A streamlined work organization including an updated onboarding process, using employee feedback to prevent departures within the first 6 months

Employee development:

• Internal trainings via the WP Academy (e.g. communication, leadership)
• Ongoing improvement of manager competencies

In 2024, Wirtualna Polska Media carried out a group layoff. To minimize negative impact, each affected employee was offered additional compensation beyond legal/contractual requirements, consultation on their further professional path, and psychological care where needed.

Reference: page 156

Under the Wirtualna Polska Holding Group 2022-2030 Sustainable Development Strategy, the following workforce-related targets are set:

Work environment respecting equality and diversity:

• 2025 target: Reduce GPGR to 10%; diversity indicator in supervisory bodies (women on Supervisory Boards and Management Boards) min. 30%
• 2030 ambition: GPGR at 0%; maintain min. 30% women

Well-being of employees:

• 2025 target: examine program performance via pulse-check; include all companies in the program; establish metrics
• 2030 ambition: 70% in satisfaction survey; employee turnover no more than 20% (unwanted departures max. 7%)

Competitive working conditions fostering development:

• 2025 target: decrease turnover of employees with seniority up to 2 years by 5 percentage points; maintain turnover of employees aged 45+ at baseline level
• 2030 ambition: turnover of employees with seniority up to 2 years no more than 7%; maintain turnover of employees aged 45+ at baseline

Effective ethics management model (organization):

• Every year, 100% of reported violations handled per procedure and deadlines; 100% of employees trained over the past 2 years

Effective ethics management model (relations):

• Develop the Code and Statement of Compliance: 80% of business partners (2023: wakacje.pl and WPM); regularly update and communicate the ethics management system

Strategy goals are monitored at least once a year. In 2025 the Group plans to settle the 2022-2030 strategy and begin preparing a comprehensive 2025-2030 strategy. The Group notes that during the reported year it was adjusting policies to ESRS and MDR-T requirements, so not all targets meet the listed requirements.

Reference: page 156

Data are reported as headcount (not FTEs) as at 31 December 2024, covering only persons under employment contracts.

Headcount under employment contracts by gender (2024):

• Female: 1303
• Male: 813
• Other: 0
• Not disclosed: 0
• Total: 2116

The Group has a greater percentage of women employed under employment contracts than men.

Breakdown by country (2024):

• Poland: 1688
• Hungary: 226
• Czech Republic: 94
• Romania: 86
• Lithuania: 16
• Croatia: 6

9 out of 16 reporting companies operate in Poland.

Breakdown by contract type (2024) [Female / Male / Others / Not reported / Total]:

• Headcount under employment contracts: 1303 / 813 / 0 / 0 / 2116
• Permanent employment contracts: 1059 / 675 / 0 / 0 / 1734
• Temporary employment contracts: 244 / 138 / 0 / 0 / 382
• Non-guaranteed hours employees: 49 / 4 / 0 / 0 / 53
• Full time employment contracts: 1244 / 799 / 0 / 0 / 2043
• Part time employment contracts: 59 / 14 / 0 / 0 / 73

Job security and flexibility: 82% of employees are employed on a permanent basis; 3.4% work part-time.

Turnover: Over the course of 2024, 566 people left the Group; the turnover rate in 2024 was 26.75%, calculated as the ratio of people who left relative to the workforce. No deaths at work or occupational diseases were recorded, and 2 people retired.

Employees are mapped to position levels using the WtW methodology (EX top management; M supervision/management with M1-M4; P specialists; U business support; T technical support; S customer service and sales).

Reference: page 160

In 2024, there were no trade unions in the companies of the Wirtualna Polska Group, and none of the companies covered by the report are subject to a collective bargaining agreement. Selected Group companies have an Employee Council.

Social dialogue - percentage of employees under employment contracts represented by the Employee Council (EEA only, in countries where the undertaking employs >50 employees making up >10% of the total):

• 0-19%: Hungary
• 80-100%: Poland

In two of six countries, Poland and Hungary, over 50 employees make up more than 10% of the total workforce, so only these countries are included in the social dialogue information.

Reference: page 161

Headcount under employment contracts by age and gender as at 31 December 2024 [Female / Male / Other / Not reported]:

• Age over 50: 44 / 32 / 0 / 0
• Age 30-50: 843 / 512 / 0 / 0
• Age below 30: 416 / 269 / 0 / 0

Women on boards: In 2024, the share of women on boards of directors and supervisory boards was 33% (target: keep above 30%). The diversity indicator in supervisory bodies is the percentage of women in the Supervisory Board and Board of Directors of Wirtualna Polska Holding.

Top management: total of 30 people, of whom 19 (reported as 30%) are women and 44 (reported as 70%) are men, classified to this level per the S1-6 methodology.

Reference: page 161

All employees of the Wirtualna Polska Holding Group earn wages above the level of adequate wages.

Percentage of employees under employment contracts earning below the set level of adequate wages (2024):

• Poland: 0
• Hungary: 0
• Czech Republic: 0
• Romania: 0
• Lithuania: 0
• Croatia: 0

The Group does not employ anyone for less than the minimum wage.

Reference: page 162

Occupational health and safety statistics for the Wirtualna Polska Holding Group (2024).

Own workforce accidents (2024):

• Minor accidents: 4
• Serious accidents: 0
• Fatal accidents: 0
• Mass accidents: 0
• Total number of accidents: 4

Accidents involving people under contracts other than employment contracts: all categories 0 (total 0).

Accidents involving people employed by subcontractors working on the undertaking's site: all categories 0 (total 0).

The Group recorded no fatalities. Accidents at work are defined by suddenness, external cause, injury or death, and work-relatedness, and may include events during business travel or travel between the headquarters and workplace.

Note: the number of days lost is not disclosed; it is omitted under the ESRS 1 Appendix C transitional provisions.

Reference: page 163

The Gender Pay Gap shows the difference in average total compensation of female versus male employees as a percentage of average male total compensation, covering employees under employment contracts and (for certain foreign companies) HPP, DPP and DPC. Total compensation comprises base pay as at 31 December 2024, fixed position-related allowances and professional fees, cash allowances paid in 2024 (bonuses, commissions, overtime), and benefits in kind.

Headline metrics (2024):

• CEO Pay Ratio: 40.85
• Gender Pay Gap: 22.69%

The Gender Pay Gap is largely influenced by the employment structure in specific countries, especially foreign operations.

Gender Pay Gap details by level (2024):

Average gross hourly wage:

• Senior management (Management Board of each company): 29.47%
• Managers and leaders: 7.95%
• Other employees: 18.99%

Average gross hourly wage + fixed allowances:

• Senior management: 29.47%
• Managers and leaders: 7.95%
• Other employees: 18.99%

Average gross hourly wage + variable allowances:

• Senior management: 20.26%
• Managers and leaders: 10.47%
• Other employees: 19.97%

Reference: page 164

In 2024, the Wirtualna Polska Holding Group did not identify any cases of discrimination or complaints. There were also no incidents related to respect of human rights concerning the undertaking's workforce in the reporting period. Information on the complaint and incident reporting mechanisms is provided in disclosure S1-3.

Reference: page 166

The Wirtualna Polska Group notes that its consumer and end-user policies were originally developed for internal purposes and, in many cases, predate the ESRS and do not yet fully meet the MDR requirements. The Group plans to assess whether and how these policies will be adjusted.

Key policies and frameworks include:

• Code of Journalistic Ethics: applies to all journalists and aims to ensure reliability and independence of materials, combat disinformation, and protect confidential sources. Journalists must familiarize themselves with the Code during onboarding, and a journalistic ethics officer addresses any ethical violations. It applies to companies operating in Poland and is made available internally through the #mojemiejsce platform.
• Cybersecurity measures: because the Group operates mainly online, cybersecurity is a priority. A dedicated Security Operations Center (SOC) monitors systems, performs tests and audits, develops procedures, and responds to incidents, cooperating with bodies such as CERT Poland. Procedures cover crisis management, incident notification, WarRoom creation, Reason for Outage (RFO) reporting, and remediation. In 2024 the Group recorded more than 3 thousand alerts that were analyzed, leading to the elimination of hundreds of vulnerabilities.
• Personal Data Protection Policy and a Privacy Policy addressed to customers and users: these regulate personal data processing, data security, exercising data subject rights, technical and organizational safeguards, and risk estimation. A Personal Data Protection Officer has been appointed, and the Personal Data Security and Protection Department (DBiODO) handles compliance, monitoring, and customer requests. Security measures follow ISO/IEC 27000-series standards.

The Group reports that in 2024 there were 686 privacy-related requests submitted, with complaints remaining at a minimum level, and no administrative proceedings ending in fines or court decisions concerning customers' privacy. The privacy policy is publicly available at https://holding.wp.pl/poufnosc.

Reference: page 170

The Wirtualna Polska Group engages with consumers and end-users through several recurring processes designed to understand satisfaction and expectations.

• Net Promoter Score (NPS) surveys: conducted regularly to measure customer loyalty and gauge satisfaction with service security and information quality. The WP Research and Analysis department analyses user ratings and presents results to area managers to improve services and published content.
• Opinion and rating system: after content is published on Wirtualna Polska platforms, users can leave feedback and rate text quality, allowing the Group to monitor satisfaction and address needs on an ongoing basis.
• Image research: helps define key parameters of the Group's image, including perceptions of service security, information quality, and social inclusion.
• Social inclusion initiatives: such as content tailored to people with disabilities and social campaigns addressed to marginalized groups.
• Online data and feedback analytics: analytical tools track user interactions with online content and collect feedback through comments and ratings to deepen understanding of user expectations and satisfaction.

Reference: page 171

The Wirtualna Polska Group provides Customer Service Offices that respond to user needs, including reported cybersecurity incidents, enabling the Group to quickly identify and address potential security issues and gather opinions on customer service quality. The Group notes that there is no direct formal evaluation process in place to determine whether consumers and end-users are aware of the opportunity to voice their concerns and to what extent these are being addressed.

In 2023, Wirtualna Polska began a project to collect and respond to user feedback more thoroughly, creating a new position of a User Rights Advocate with defined roles and responsibilities, including analyzing user behavior to identify areas for improvement and collecting customer feedback. In 2024, the first recommendations developed by the User Rights Advocate were implemented on Wirtualna Polska Media sites.

The Office of the User Rights Advocate created the Code of User Rights, a set of rules and guidelines intended to ensure transparency, fairness, and full respect in relations between Wirtualna Polska and its users, and to make the organization aware of what a good user experience is and what rights users have.

Reference: page 171

In 2023, Wirtualna Polska developed the Code of Responsible Advertising, which guides its day-to-day media activities. Under its Review Principle, a committee was established to review advertising for compliance with the Code's principles, comprising the Editor in Chief, the Head of the Legal Department, the Head of the Advertising Department, and the Ethics and Standards Editor. The committee analyses questionable advertisements, decides whether to publish them, and responds to reports on campaigns and creations on an ongoing basis.

Several regulatory matters involving the Office of Competition and Consumer Protection (UOKiK) are reported:

• In December 2023, the UOKiK President imposed a fine of PLN 1.06 million on Wakacje.pl S.A., a subsidiary, over differences between prices displayed in search results for tourist events and final prices. Wakacje.pl S.A. disagrees with the UOKiK President's arguments, stating that as a travel agent it displays prices provided by tour operators without changing them, and has filed an appeal. The decision is not final.
• In December 2022, the UOKiK President launched a procedure regarding the labeling of advertising materials on Wirtualna Polska Media S.A. websites. The company stated its labeling is in line with common market practices and expressed full readiness for dialogue and the development of new standards. The outcome was not yet known as of the report's publication date.
• A further proceeding concerns advertising for the Pilot WP service provided by Netwizor Spolka z o.o. (now Audioteka Group Spolka z o.o.). The Group ceased publishing the advertising campaign that raised concerns and carried out a free access campaign for those who purchased packages during the broadcast period. The outcome was not yet known as of the report's publication date.

The company conducts intensive dialogue with tour operators regarding these matters.

Reference: page 172

User-related objectives have been set as part of the Wirtualna Polska Holding 2022-2030 Sustainable Development Strategy, grouped under two themes.

We care about media ethics:

• Ensuring non-exclusionary language on its portals. The 2025 target is creating, implementing, and regularly training 100% of journalists on guidelines for using non-exclusionary language; the 2030 ambition is exerting significant influence on the development of standards for non-discriminatory communication.
• Ensuring the highest standards of information reliability. The 2025 target is conducting a fact-check project; the 2030 ambition is offering users only thoroughly verified information.

We care about the users:

• Being a safe place online. The 2025 target includes permanent implementation of the Stop-Hate program, launching educational activities on online hate, promotion of comments by logged-in and credible users, and tools improving comment quality; the 2030 ambition is minimizing hate on the Group's websites.
• Maintaining a high level of user data protection. The 2025 target is maintaining high availability of WPH services; the 2030 ambition is ensuring the highest standard of service security and supporting users in keeping themselves safe.
• Fighting against digital exclusion. The 2025 target is implementing a program for the elderly and developing best practices; the 2030 ambition is enabling secure online access for the digitally excluded.

The Group notes that in the reported year it was in the process of adjusting its policies to the requirements of the ESRS and MDR-T, so not all issues meet the listed requirements.

Reference: page 173

The Wirtualna Polska Holding Group promotes ethical conduct and attaches importance to the guidelines, indications, and case law of the Office of Competition and Consumer Protection (UOKiK). To prevent undesirable conduct and discrimination, it undertakes activities such as mandatory Code of Ethics training for all Group employees, Diversity Months with online training, principles to counteract undesirable conduct, and manager training in labor law, communication, anti-mobbing measures, diversity, and equity.

The documents presenting the Group's business ethics commitments include the Code of Ethics, the Code of Journalistic Ethics, the Sustainable Development Strategy, and the Code of Responsible Advertising, developed with the involvement of stakeholders and top governing bodies. The Code of Ethics is the foundation for all policies, procedures, and internal rules, applies to all geographic areas in which the Group operates, and is an updated and expanded version of the previous Compass of Ethics. Mr. Tomasz Siemieniec was appointed Ethics Ombudsman of the Group. The Code describes guiding values (honesty and openness, energy and engagement, creativity, effectiveness of actions, team work) and sets out corporate principles covering integrity and legal compliance, business ethics, care for employees, environmental protection, cooperation with local communities, and diversity.

The Code sets out employees' key rights and responsibilities and lays down rules for reporting irregularities, including anonymously. Anti-corruption measures are regulated within the Code, and the Group follows the Best Practice for Listed Companies on conflict of interest management and corruption prevention. Suspicions of non-compliance, including corruption, can be reported via a dedicated e-mail address or directly to the Management Board or Supervisory Board. Mandatory Code of Ethics training is part of onboarding, with plans for an annual reminder. The Code in Polish is available at https://holding.wpcdn.pl/uploader/Kodeks-etyki-Wirtualnej-Polski-Holding.pdf.

At the corporate governance level, the role of governing bodies, including the ESG oversight structure, is described in the ESRS 2 GOV-1 disclosure, and the process to identify and assess material business conduct impacts, risks, and opportunities is described in the ESRS 2 IRO-1 section.

Reference: page 175

The Wirtualna Polska Holding Group's policy to prevent late payment, especially to small and medium enterprises, is based on several key principles: dedicated cash flow management departments that monitor and control the flow of funds; full document circulation within the accounting and financial system to ensure transparency and control; a minimum of two payment sessions per week to optimize timeliness; and delay analysis, under which the Group analyses and explains payment delays to improve payment policies. The Group adapts its approach to supplier relations based on market factors such as size, competition, and transaction risk level, with the Code of Ethics describing basic supplier relation principles common to all entities.

The Group introduced a Supplier Code of Conduct, adopted by the Management Board in December 2024, which sets ethical and regulatory standards in relations with business partners and serves as a foundation for long-term cooperation based on ethics, sustainable development, and protection of human rights and the environment. The Code is in line with international guidelines such as the UN Global Compact and the OECD Guidelines and defines key requirements including compliance with anti-corruption regulations, avoidance of conflicts of interest, and enabling monitoring of compliance.

The Code addresses the challenge of limited supplier compliance monitoring, noting that the lack of appropriate tools and procedures can lead to the risk of fraud or non-compliance with ethical standards. Its adoption represents a first step toward introducing control, evaluation, and monitoring mechanisms, which are still being built. The Code will be gradually implemented in relations with suppliers who undertake to comply with it and is available at https://holding.wp.pl/compliance.

Reference: page 176

The Wirtualna Polska Holding Group's anti-corruption measures are regulated in the Code of Ethics. The Group follows the Best Practice for Listed Companies regarding conflict of interest management and corruption prevention, and continuously monitors guidelines, recommendations, and case law of the Office of Competition and Consumer Protection (UOKiK).

The Group takes ongoing measures to familiarize employees with anti-corruption policies and procedures. By the end of 2024, it adopted an Anti-Corruption Policy, with all companies in the group planned to adopt the policy and begin training employees in 2025. The Group is also in the process of identifying functions exposed to the risk of corruption and bribery. All Group employees are required to attend Code of Ethics training, which emphasizes the principle of zero tolerance for unlawful, including corrupt, conduct, and members of governing bodies have been informed as part of the consultation and implementation of the Code.

If any suspicion of corruption or bribery arises, an independent investigation team will be set up, with its composition selected to avoid pressures or personal or business dependencies between those involved. Where necessary, the team will include people from other departments reporting to the parent company (Wirtualna Polska Holding) or, if appropriate, independent external bodies.

Reference: page 176

The Wirtualna Polska Group did not identify any incidents or convictions relating to the violation of anti-corruption law in 2024.

Consistent with this, the Group reports that in 2024 no confirmed cases of corruption were recorded, meaning there was no need to take any legal actions in this respect, and there were no public court cases regarding corruption or bribery, nor any convictions or fines for anti-corruption violations.