Wolters Kluwer

Reference: page 96

Wolters Kluwer operates a two-tier board structure under Dutch law: an Executive Board and a Supervisory Board. Responsibilities for impacts, risks and opportunities (IROs) sit in each board's By-Laws and Terms of Reference; the Executive Board must weigh sustainability effects on people and the environment when developing strategy, and holds collective responsibility for sustainability matters, with the CFO responsible for sustainability data reporting. The Supervisory Board's By-Laws require it to consider the company's societal and environmental impact; the Audit Committee oversees ESG-related controls and the limited assurance process, and the Selection and Remuneration Committee oversees sustainability elements of Executive Board remuneration.

The Corporate Sustainability team, led by the SVP General Counsel & Company Secretary (sustainability specialists) and the SVP Finance, Budgeting & Reporting (accounting/reporting specialists), gives periodic updates to the Executive Board, Supervisory Board and Audit Committee, and coordinates with functional SMEs who own policies, actions and targets for specific IROs and report to Executive Board members. A reporting-line table maps named functions (e.g., CEO of Global Business Services for climate and cybersecurity; Chief HR Officer for DEIB and well-being; EVP & General Counsel for data privacy) to their IRO responsibilities.

Reference: page 97

The Executive Board, Supervisory Board and its committees are informed about material IROs and related policies, actions, metrics and targets by the responsible functions or their delegates, typically one to four times a year. A table lists 2025 topics addressed by each body. The Executive Board covered: real estate rationalization and office-footprint targets and GHG progress including SBTi validation of long-term/net-zero targets; the global pay equity project and belonging initiatives, including approval of the 'Impact' recognition platform; the well-being calendar and approval of the 'Work From Anywhere' program; skills-powered talent initiatives and the Circle Mentoring Program; data privacy/cybersecurity training completion; findings from the third-party supplier sustainability assessment; and approval of the updated SpeakUp Policy. The Supervisory Board was informed on SBTi target validation, engagement/belonging results, talent succession, supplier assessment findings and cybersecurity. The Audit Committee was informed on the DMA outcome and SpeakUp; the Selection and Remuneration Committee approved non-financial STIP measures for climate, DEIB and data privacy.

Reference: page 97

The Supervisory Board executes the remuneration policy on the Selection and Remuneration Committee's advice. The Remuneration report sets out how Executive Board pay incorporates sustainability-related performance and what proportion of variable pay depends on sustainability targets. Climate considerations are factored into target selection: the 2025 non-financial performance measures for the short-term incentive plan (STIP) again included the target on percentage reduction in office footprint, described as one of the key drivers of the scope 1 and 2 GHG emissions reduction. The STIP offers cash incentives against a mix of financial and non-financial measures set at the start of each year. Wolters Kluwer states it will continue to evaluate relevant climate-related STIP measures as its GHG emissions reporting evolves.

Reference: page 98

Wolters Kluwer describes due diligence as an iterative process of identifying, preventing, mitigating, remediating and communicating impacts on people and the environment, carried out through its double materiality assessment, including stakeholder consultation and desk research on publicly available sector information. Its approach references the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. In 2025 the company states it strengthened due diligence by gaining more concrete insight into the inherent sustainability risks of key suppliers, and began assessing higher-risk strategic suppliers on environmental, labor and human rights, ethics and sustainable procurement issues. A table maps the core elements of due diligence (embedding in governance/strategy, engaging stakeholders, identifying/assessing negative impacts, taking action, tracking effectiveness) to the relevant ESRS 2 and topical disclosures.

Reference: page 98

Sustainability-statement controls sit in an Internal Control Framework for Sustainability Reporting (ICSR), distinct from but designed similarly to the financial ICFR, with ESRS disclosures mapped to corresponding controls. Functional sustainability topic owners are assigned, and Internal Audit has audited both environmental and social reporting processes and will continue periodic thematic reviews; a sustainability reporting manual supports compliance and standardization. Sustainability topics, compliance and risks are discussed periodically in the Corporate Risk Committee, which in 2025 added a new risk on non-financial reporting to the company's risk universe, with outcomes reported to the Executive Board. ICSR controls are under review and being updated from internal/external feedback; controls over the DMA process are in design review and effectiveness testing, with results reported to functional management and internal/external auditors. The company notes that some sustainability data remains subject to judgments and estimates as controls continue to mature.

Reference: page 99

Wolters Kluwer is a global provider of information, software solutions and services for professionals in healthcare, tax and accounting, financial and corporate compliance, legal and regulatory, and corporate performance and ESG, combining domain knowledge with workflow automation. Delivery depends on third-party suppliers such as cloud providers, data centers, software developers and back-office processors. The company flags sector-specific sustainability matters affecting its business model: competition for specialized technical talent; growing reliance on external partners raising data-privacy, cybersecurity and reliability risk; opportunities from cloud-based, AI-powered solutions improving customer efficiency and scalability; and rising energy consumption and GHG emissions from digital infrastructure including data centers. The DMA evaluated how these sector-specific IROs relate to the business model and value chain. As in FY2024, the revenue breakdown by ESRS sector is deferred because EFRAG's SEC1 sector-classification standard remains in draft.

Reference: page 99

Wolters Kluwer engages stakeholders across its businesses under a Board-adopted Stakeholder Engagement Policy, prioritizing groups by relevance to the business and the potential impact of its activities on them. As part of the double materiality assessment, the company analyzed key stakeholders' views to understand its impacts on them. A table (pages 100-101) sets out engagement channels, purposes and outcomes for stakeholder groups including industry associations, academic and research institutions, civil society/non-profit organizations, and governments and regulators – covering methods such as association memberships, university research collaborations, non-profit partnerships (e.g., the Princess Maxima Centre) and engagement with EU-designated notified bodies on product-compliance requirements. Business and functional leaders are informed of stakeholder views relevant to their areas, and the Executive Board and Supervisory Board are kept informed for alignment and decision-making.

Reference: page 102

The double materiality assessment identified eight material topics, presented with type of IRO, value chain location and time horizon: climate change (actual negative impact); DEIB, training and skills development and work-life balance (each an actual positive impact and opportunity, under Own workforce); labor and human rights of workers in the value chain (potential negative impact); access to quality information (actual positive impact and opportunity, under Consumers/end-users); corporate culture (actual positive impact and opportunity); and data privacy (potential negative impact), an entity-specific topic categorized under Governance (G1) alongside cybersecurity. The material ESRS standards are E1, S1, S2, S4 and G1. A resilience analysis using ESRS time horizons and internal SME input found that, despite three material negative impacts (climate change, value-chain labor/human rights, data privacy), risk-management practices (cybersecurity, supply-chain risk management, climate resilience/business continuity) mean these do not pose a material risk. The company has not yet quantified the financial impact of material opportunities.

Reference: page 104

Material IROs are identified through a double materiality assessment (DMA) using a six-step process: (1) review business activities and engage key stakeholders – including investor meetings, employee surveys and SME interviews; (2) outline relevant sustainability matters from ESRS 1 Appendix A, informed by sector standards, ESG ratings and peer reports; (3) identify actual/potential IROs across the value chain via desk research, SME consultation, customer/supplier sustainability questionnaires and office-location analysis; (4) assess IROs by severity (scale, scope, irremediability) for impacts and magnitude of financial effects for risks/opportunities, with likelihood factored in except for potential negative human-rights impacts, where severity takes precedence; (5) prioritize using defined high/medium/low thresholds, clustering similar IROs; and (6) validate the ranking with investor representatives, the external auditor, senior staff and the Executive/Supervisory Boards. An initial DMA ran in 2023 and was refined in 2024; in 2025 the company validated the prior outcome and confirmed no changes to its material IROs. 2025 DMA actions included biodiversity and water-stress screening of offices and benchmarking against 10 peers.

Reference: page 105

After determining material IROs, Wolters Kluwer assessed the materiality of each ESRS data point against them through a qualitative assessment considering relevance to the company, its business and key stakeholders. The Reference table sets out the full list of ESRS disclosure requirements complied with following the DMA outcome, cross-referencing each disclosed topic to the page in the sustainability statements (and, where applicable, other annual report chapters) and flagging use of the ESRS 1 paragraph 137 phase-in provisions. A separate table lists the data points that derive from other EU legislation, marking each item as either disclosed at a stated page or 'not material to us' – used for EU Taxonomy fossil fuel/chemicals/weapons/tobacco involvement, the E2-E5 environmental legislation items, and several social and governance sub-datapoints (e.g., S1-14 workplace-accident metrics, S3 affected-communities items, G1-4 anti-corruption fines/standards).

Reference: page 107

Wolters Kluwer has developed a transition plan to reduce GHG emissions in line with a pathway to limit global warming to 1.5°C, approved by the Executive Board and Supervisory Board, aligned with the COP21 Paris Agreement; the company is not excluded from the EU Paris-aligned Benchmarks. Near-term GHG reduction targets were validated by the Science Based Targets initiative (SBTi) in 2023; in 2025 the scope 1 and 2 near-term ambition was raised from 50% to 60% by 2030, and new long-term targets, including net-zero by 2050, were introduced and SBTi-validated. In 2025 the company gained more concrete insight into upstream supply-chain carbon risk and plans to expand this analysis to key upstream asset locations and new scenarios, intending to strengthen the climate scenario analysis to better understand resilience. The Corporate Sustainability team identifies climate risks, discussed with the Corporate Risk Committee, which monitors material risks and determines company-wide mitigating actions.

Reference: page 107

Back-filled from ESRS 2 SBM-3 and the E1 climate-DMA section, where this content is disclosed in the FY2025 report (pages 106-107). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The DMA did not identify material climate-related risks, only impacts, but a resilience analysis informed by an initial climate scenario analysis was used to identify potential physical and transition risks over short, medium and long time horizons. Two scenarios were used: Business As Usual and 1.5 degrees warming, applying Relative Concentration Pathways (RCP) scenarios from the IPCC for physical risk and World Energy Outlook (WEO) scenarios from the IEA for transition risk – the report does not name specific numbered pathways (e.g., no RCP8.5 or a named IEA scenario) or state global-average-temperature projections, an omission against the fuller ¶17 requirements. Physical risks identified: disruption to employees, damage to offices/warehouses/servers, water shortage, and supplier delivery disruption. Transition risks: reputational risk from missing emissions targets, and misalignment with customer demand for climate-enabling products. Scope is not stated beyond "our value chain"; timing is undated, though described as "initial," with strengthening planned.

Reference: page 102

Back-filled from ESRS 2 SBM-3 (pages 102-103), cross-referring to the E1-specific resilience discussion (pages 106-107). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company's resilience analysis, conducted as part of the DMA using ESRS time horizons and qualitative input from internal SMEs, concluded that despite three material negative impacts (climate change, value-chain labor/human rights, data privacy), the strategy and business model remain resilient: risk-management practices (cybersecurity and data-privacy measures, supply-chain risk management, climate resilience and business continuity programs) mean these impacts and dependencies do not pose a material risk. For climate specifically, the resilience analysis also drew on the initial climate scenario analysis (see E1-2) and on the risk-control and business-continuity management program; based on this, plus the ongoing Business Continuity and Incident Management Program, the company expects its strategy and business model to be prepared for the identified climate-related risks. No uncertainty ranges or specific capital-redeployment analysis are disclosed. The company states it will expand supply-chain risk insight and strengthen the scenario analysis in future years.

Reference: page 108

Wolters Kluwer's Environmental Policy, approved by the Executive Board and applying to all controlled divisions and entities, aims to minimize the negative environmental impact of operations and comply with applicable environmental law. It addresses climate change mitigation, energy efficiency and renewable energy deployment, covering energy, water, paper and other natural resource consumption and waste production. Suppliers are required, via the Supplier Code of Conduct, to commit to the same environmental standards on contract signing and renewal, work toward science-based emissions targets, and report progress. Climate-change resilience and adaptation is informed by internal Global Business Continuity Management Standards, including guidance on managing incidents from extreme weather; the company notes it discloses resilience/adaptation policies and actions for completeness even though only climate mitigation is assessed as a material impact. The Environmental Policy and Supplier Code of Conduct are published on the company website.

Reference: page 109

Climate mitigation actions fall into three areas. Office decarbonization: the real estate rationalization program (closures/consolidations) and sustainability criteria embedded in office selection, lease renewal and renovation (environmental certificates, LED lighting, transport proximity); in 2025 six leased offices switched to renewable electricity and Renewable Energy Certificates (RECs) were purchased covering all U.S. offices' 2025 consumption. Reducing business-travel emissions: a Business Travel Policy favoring virtual meetings, restricting business/first-class air travel, and a booking tool displaying flight CO2 and monthly emissions summaries. Supply-chain decarbonization: in 2025 all vendor-management-system suppliers were screened for carbon risk via EcoVadis, finding none at high/very-high risk; 50 suppliers were assessed in depth, of which 48 manage GHG emissions, 38 have credible reduction targets and 31 hold SBTi-validated targets. No significant incremental CapEx/OpEx tied to mitigation was identified. Climate resilience/adaptation runs through business continuity, incident and IT disaster recovery programs aligned to BCI and ISO 22301 standards, with annual risk assessments covering flooding and weather zones.

Reference: page 110

Wolters Kluwer's SBTi-approved near-term 2030 targets (2019 base year) are a 60% reduction in absolute scope 1 and 2 GHG emissions (raised from 50% in 2025) and a 30% reduction in absolute scope 3 emissions, covering scope 3.1, 3.2, 3.4, 3.6 and 3.7. The long-term 2050 target is a 90% reduction across scopes 1, 2 and 3 from 2019, reaching net-zero by neutralizing the residual (maximum 10%) with high-quality carbon removals. An annual office-footprint reduction target (part of non-financial STIP measures) aimed for a 5-6% cut in 2025 and achieved 8%. As of 2025, scope 1 and 2 emissions were down 80% since 2019, meaning the near-term target was achieved five years ahead of schedule; scope 3 emissions were down 17% since 2019, representing 57% of the scope 3 near-term target. Base-year emissions are not restated for 2020-2025 acquisitions/divestments the company deems immaterial (under 5% variation, per SBTi methodology).

Reference: page 112

Energy consumption covers owned and leased offices; 75% was confirmed via meter readings, provider reports or landlord confirmations for 2025, with the remainder estimated/extrapolated using documented methods (prior-year Q4 data for some large offices, pro-rata extrapolation for partial-year data, and regional/country peer-office extrapolation for offices with no data). Total energy consumption fell to 34,715 MWh (2024: 39,166; 2023: 43,399), of which consumption from fossil sources was 15,778 MWh (45%), from nuclear sources 312 MWh (1%), and renewable energy consumption rose to 18,625 MWh (54%), up from 20% in 2024, driven by the switch of six leased offices to renewable contracts and RECs covering all U.S. offices for the full year. Total energy production (mainly rooftop solar) was negligible. The decrease in overall consumption reflects reduced square meterage and energy-saving measures. Wolters Kluwer has no own operations in high climate impact sectors.

Reference: page 113

Gross GHG emissions for 2025 (tCO2e): scope 1: 2,077 (down 1% YoY); scope 2 market-based: 1,921 (down 75%); scope 3: 245,580 (down 9%), of which purchased goods and services (3.1) 205,029, capital goods (3.2) 2,015, upstream transport/distribution (3.4) 11,968, business travel (3.6) 14,175 (down 57% on temporary travel limits), employee commuting (3.7) 7,839, and use of sold products (3.11) 4,554 (up 13% on cloud-user growth, tracked separately from the scope 3 reduction target). Total gross GHG emissions (market-based): 249,578, down 11% year-on-year; location-based total 256,141. GHG intensity: 41 tCO2e per million euros of revenue (market-based), down from 47 in 2024. Scope 3.1-3.4 declines reflect lower supplier spend; cloud/data-center services are ~9% of scope 3.1 and disclosed separately as material. Methodology detail (pages 115-118) covers scope-specific conversion factors (US EPA, UK Defra, IEA) and a supplier-emissions spend-based method; several immaterial scope 3 categories (3.3, 3.5, 3.9, 3.12, 3.13, 3.15) are screened out as together under 5% of the total, and 3.8, 3.10, 3.14 are not applicable.

Reference: page 108

Wolters Kluwer states it prioritizes direct emissions reduction efforts and does not engage in GHG removals, carbon credits, or carbon pricing mechanisms. It continues to monitor developments in carbon removals and storage as part of its long-term net-zero plan, which will require neutralizing residual emissions. No internal carbon pricing scheme is described as being applied to internal decision-making, capital allocation or product costing.

Reference: page 120

Own-workforce policies address the material sub-topics: DEIB, training and skills development, and work-life balance. The Code of Business Ethics sets ethical standards, including equal-opportunity and non-discrimination commitments (covering race, religion, sex, age, national origin, sexual orientation, gender identity, disability and other protected statuses), applied to recruitment, hiring, training, compensation, promotion and discipline, and further detailed in the DEIB Policy and Human Rights Policy; equal-opportunity coverage also extends informally to political opinion, national extraction and social origin. The SpeakUp Policy lets the workforce raise concerns about suspected misconduct. All these policies are Executive Board-approved, reviewed annually, and made available in multiple languages via intranet and the company website, reinforced through training. The company supports human rights per the UN Declaration, ILO core standards, UN Guiding Principles and OECD Guidelines, is a UN Global Compact and Women's Empowerment Principles signatory, and states it has no operations at risk of forced, compulsory or child labor.

Reference: page 120

Wolters Kluwer runs an annual Engagement & Belonging survey – its primary formal feedback channel on growth, management support and belonging, with 2025 improvements to survey analytics – plus onboarding and exit surveys, manager check-ins, and ad hoc focus groups, polls and pulse surveys. Bi-annual all-employee townhalls and quarterly business-line/function townhalls, supported by intranet and messaging platforms, provide large-scale communication. The company regularly engages the European Work Council (EWC) on strategic and organizational matters; 2025 topics included survey results, career-opportunity initiatives, the 'Work from Anywhere' program, flexible work, pay transparency, and SpeakUp channels. Regular interaction is also maintained with local work councils in European countries. The global Talent Management team and HR business partners lead engagement, and the Chief Human Resources Officer holds ultimate responsibility for workforce engagement.

Reference: page 120

Wolters Kluwer does not present a standalone 'raise concerns' section in the FY2025 statement, but the substance is covered under adjacent disclosures. The SpeakUp Policy (S1-1, page 120) lets the workforce raise concerns about suspected misconduct or violations of the Code, other policies or applicable law. Under Incidents and complaints (S1-17, page 129), the company states it "maintains a culture of open communication and a safe environment where everyone is encouraged to raise concerns," operated through the global SpeakUp system (external provider, available 24/7, anonymous option, multi-language) or directly to HR via the global HR system, tracked in an employee relations case management system; legal claims and disputes, including pre-litigation employment claims, are tracked in an electronic matter management system through to disposition. No dedicated remediation-outcomes description (e.g., time-to-resolution) is given beyond volume metrics reported under S1-17.

Reference: page 121

Actions span three material sub-topics. DEIB: a dedicated HR specialist team; in 2025 engagement and belonging were united under one organizational structure with a new dedicated leadership role; the Global Career Framework (reviewed annually) and bias-checked job postings; inclusive-leadership training (91% of 2025 new hires completed it); the new 'Impact' recognition platform (40%+ employee engagement in its first month); three Global Inclusion Networks (Pride, Women's, Multicultural) with a new cross-network leadership team; and the global pay equity program, which cut the adjusted gender pay gap from 3.1% to 1.8% via targeted 2025 market adjustments. Work-life balance: a global well-being program (130+ well-being champions), Global Well-being Day, the 'Let's Move Around the World Challenge,' the Employee Assistance Program, an inclusive leave/benefits portfolio, and the new 'Work From Anywhere' flexible-work program. Training and skills development: annual performance/career development cycles, the 70:20:10 learning model, a 16,000+ course learning platform, GenAI Foundations training (91% completion), the #Grow platform, succession planning, leadership development, and the new 'Circle Mentoring Program' (nine circles, 800+ employees).

Reference: page 124

Three targets. Belonging score: improve year-over-year (typically one point) from a July 2021 baseline of 72, aspiring to the top 25% of Microsoft Glint's global benchmark; the score was maintained in 2025 and is included in the 2024-2026 STIP non-financial measures. Board gender balance: at least 33% male and female representation on the Supervisory and Executive Boards (Dutch-law minimum one-third); the target is met. Female representation in the executive career band: 33% by 2028, set in 2023 from a 31% (2022) baseline; the target was exceeded ahead of schedule in 2025, with an ongoing goal to maintain at least 33%, monitored via monthly HR dashboards.

Reference: page 125

Headcount at December 31, 2025 was 21,066 (2024: 21,635; 2023: 21,438), by gender: female 9,695 (46%), male 11,294 (54%; 2024/2023 comparatives predate the option to select a gender other than male/female), other 7, not disclosed 70. By region: the Netherlands 5%, Europe (ex-Netherlands) 31%, U.S./Canada 42%, Asia Pacific 21%. The U.S. (40%) and India (17%) are the only countries each above 10% of headcount. By contract term: 18,877 permanent, 320 temporary, 1,869 non-guaranteed-hours employees (almost all U.S., customer service/fulfillment/inside sales, averaging 37 scheduled hours/week). Employee turnover was 10.5% (6.8% voluntary, 3.7% non-voluntary), up from 9.5% in 2024. A company-specific metric reports U.S. employee race/ethnicity: White 66%, Asian 13%, Black or African American 7%, Hispanic or Latino 7%, other 2%, unknown/not disclosed 5%.

Reference: page 126

Non-employees (individual contractors and supplier-provided workers primarily engaged in employment activities) are not yet characterized: Wolters Kluwer is finalizing a global system to collect and monitor non-employee characteristics, expected to enable reporting from 2026. The company uses the ESRS 1 paragraph 137 phase-in option for this disclosure and plans to begin reporting the global number of non-employees in the next annual report – unchanged in substance from the FY2024 position.

Reference: page 126

Gender ratio (% female, 2025): total headcount 46%; Supervisory Board 56% (down from 57% in 2024); Executive Board 67% (up from 50%); executives 34%; managers 41%; other employees 47%. By headcount: Supervisory Board 5 female/4 male; Executive Board 2 female/1 male; executives 103 female/198 male. By age (2025): under 30, 12% (2,509); 30-50, 58% (12,155); over 50, 30% (6,402). Metrics rely on the global HR platform; from 2025 employees can select a gender other than male/female. The related persons-with-disabilities and non-employee diversity datapoints continue to use phase-in (transitional) provisions per ESRS 1 paragraph 137 (see S1-7, S1-12).

Reference: page 127

The disability percentage is derived only from U.S. employees who indicated a disability in the global HR platform; Wolters Kluwer uses the ESRS 1 paragraph 137 phase-in option to allow more time to refine data collection for non-U.S. employees before extending the metric company-wide. % of U.S. employees with disabilities: 12% in 2025 (2024: 9%; 2023: 2%), with the 2024 increase attributed to an enhanced reporting process.

Reference: page 127

All employees join an annual global performance-management process; 97% participated in performance and career development reviews in 2025 (2024: 88%). Training activity is tracked in the global HR/learning platform, excluding mandatory compliance training; a new external-training feature added in 2025 lets employees log self-study/outside courses, included in the metric from 2025. Average training hours per employee: 8 (2024: 8; 2023: 5), by category: executives 5, managers 11, other employees 8. Wolters Kluwer uses the ESRS 1 paragraph 137 phase-in option for this metric.

Reference: page 128

Family-related leave (maternity, paternity, parental, caregivers') is reported only for U.S. employees, using the ESRS 1 paragraph 137 phase-in option; the company plans to extend reporting to the full workforce. 100% of U.S. employees were entitled to family-related leave in 2025 (unchanged since 2023); 7% took it in 2025 (2024: 4%; 2023: 6%), split female 9%, male 5%. Data is sourced from the global HR system plus a third-party leave administrator for a small share of U.S. employees.

Reference: page 128

Wolters Kluwer's second global pay equity analysis (data as of November 1, 2025, covering 20,595 positions) found an unadjusted gender pay-gap ratio of 12.9% (2024: 14.8%) and an adjusted gender pay-gap ratio of 1.8% (2024: 3.1%), the latter remaining below the company's long-term 5% threshold. From 2025, employees able to select a gender other than male/female are grouped as 'non-females' for the ratio calculation. The annual total remuneration ratio was 107.7 (2024: 106.8) – the highest-paid individual's (the CEO's) pay versus median employee pay, excluding the CEO – which differs from the IFRS-based CEO pay ratio in the Remuneration report mainly due to median-versus-average and ESRS's exclusion of social security benefits. Employees from the divested FRR business (announced July 21, 2025) are excluded from the 2025 analysis.

Reference: page 129

The workforce can raise concerns about suspected Code, policy or legal violations via multiple channels under the Code of Business Ethics and SpeakUp Policy, including the global SpeakUp system and HR, tracked via an employee relations case management system; legal claims/litigation, including pre-litigation employment claims, are tracked through an electronic matter management system. 2025: 113 complaints and 17 incidents of discrimination/harassment (2024: 62 and 5 respectively); no fines, penalties or compensation for damages, and no severe human rights incidents, were reported in either year. Of the 130 total 2025 complaints/incidents, 82 came via SpeakUp (2024: 37), an increase the company attributes partly to a 2025 SpeakUp communication campaign and enhanced intranet/internet information that raised awareness and trust in the process.

Reference: page 131

The Supplier Code of Conduct covers environmental, social and business-conduct standards for all suppliers, partners and third parties, is embedded in standard supplier contract templates, and is Executive Board-approved; suppliers must certify compliance with it or an equivalent standard. Its human/labor-rights commitments require suppliers to respect internationally recognized human rights, prohibit and remediate forced/bonded/prison/military/compulsory and child labor, ensure equal treatment and equal pay, comply with wage/hour/benefits law, and provide safe, hygienic workplaces, aligned with the UN Declaration, UN Guiding Principles, OECD Guidelines and ILO Core Labor Standards; no non-respect cases were reported to the company in 2025. It is one mechanism of the internal Supply Chain Risk Management (SCRM) Standard, which the company plans to review in coming years for human/environmental due-diligence guidance.

Reference: page 132

Wolters Kluwer does not have processes for engaging directly with value-chain workers, but gains insight into supply-chain human-rights and labor conditions through proxies such as sector studies and initiatives. In 2025 the company began integrating preliminary insights from EcoVadis, its new third-party supplier sustainability assessment tool, covering how key suppliers manage labor and human-rights, ethics, sustainable-procurement and environmental risks.

Reference: page 132

Under the Supplier Code of Conduct, workers in the supply chain can raise questions or concerns in line with the Wolters Kluwer SpeakUp Policy; suppliers must not tolerate retaliation against good-faith reporters. In 2025 the SpeakUp program was expanded to cover suppliers' workers, improving accessibility and awareness across the value chain. As part of the 2025 EcoVadis assessment, suppliers report whether they have grievance mechanisms; 46 of 50 assessed suppliers confirmed having them, indicating suppliers' workers generally have internal channels alongside SpeakUp access. The company will continue monitoring supplier performance on this indicator.

Reference: page 132

In 2025 Wolters Kluwer adopted EcoVadis as its supplier sustainability assessment tool. Inherent-risk screening found most suppliers at low/very-low labor and human-rights risk; 50 suppliers with the highest environmental/social risk (balanced against financial thresholds) were selected for the deeper EcoVadis Ratings assessment, which found most have policies and actions on grievance mechanisms, working conditions, and preventing child labor, forced labor and trafficking. In 2026 the company will invite more suppliers to participate. Actions sit with Strategic Sourcing and Procurement Operations, partnered with Corporate Sustainability; the broader Supply Chain Risk Management (SCRM) program covers risk assessment, due diligence, monitoring and remediation/termination processes, repeated every one to three years by risk tier. The company states it has not yet measured the effectiveness of these actions and, having identified no material actual impacts, has no remediation processes in place.

Reference: page 132

Wolters Kluwer currently does not have targets regarding value-chain workers. As it improves visibility into supply-chain labor and human-rights conditions through the EcoVadis-based supplier sustainability assessment program launched in 2025, and as due diligence matures, the company states it will evaluate in coming years whether setting specific, measurable goals for this topic is appropriate. This remains substantively unchanged from the FY2024 position, where the same absence of targets was reported.

Reference: page 134

The Code of Business Ethics commits to editorial independence and reliable, high-quality content from legal, market and professional sources, prioritizing impartiality and avoiding bias, defamation or conflicts of interest; recognized external experts and editors with full decision-making independence support this. Business units also maintain tailored editorial policies suited to their user groups and content types. In 2025 Wolters Kluwer introduced a company-wide AI Policy, overseen by the AI Governance Committee, covering responsible AI development/use, risk-management procedures and regulatory compliance, alongside its existing AI Principles (privacy/security, transparency/explainability, governance/accountability, fairness, human-focused design). All are Executive Board-approved and published on the company website.

Reference: page 134

Wolters Kluwer gathers end-user feedback through user research, interviews and persona studies (including on-site observation by some product teams), beta testing of new products/enhancements with small customer groups, and structured channels – advisory boards, UX interviews, feature/satisfaction surveys, prioritization platforms and usage analytics. Net Promoter Score (NPS) surveys track satisfaction, feeding development plans; customer-service interactions provide further feedback. Customer-centric problem solving anchors AI development from the outset. Broader dialogue occurs through annual user group conferences, industry summits and regional forums; insights and their business implications are regularly communicated to senior leaders across customer-facing divisions.

Reference: page 134

Product teams run continuous initiatives to maintain access to quality information: external experts and quality-assurance testing at release; the Digital eXperience Group's Centers of Excellence in AI, quality engineering, UX and customer research; 11% of annual revenues reinvested in innovation and product development; the Global Innovation Awards, Code Games and localized product versions; and, in 2025, a new AI Governance Committee and AI Working Group overseeing use-case risk assessments, plus the proprietary, model-agnostic GenAI-Enablement Platform with an 'expert-in-the-loop' human-oversight approach. Solutions carry certifications including ISO 9001, ISO/IEC 27001 and SOC 2 Type 2 (the GenAI platform is also SOC 2 Type 1/2 certified), maintained through regular internal and third-party compliance reviews. Effectiveness is evaluated via quality-analyst testing, engagement, renewal rates, revenue growth, product-experience platforms and third-party surveys.

Reference: page 135

While individual business units may set internal targets, Wolters Kluwer states its end-user-related processes and policies are highly elaborated and continuously reviewed and updated, with business units using varied methods to evaluate effectiveness of their actions. For this reason the company does not consider it necessary to have external targets related to end-users at this time – unchanged from the FY2024 position.

Reference: page 137

The Code of Business Ethics, published internally and externally in multiple languages, sets ethical standards on discrimination/harassment, anti-bribery/anti-corruption and fair competition; all employees complete a Code course in the mandatory Annual Compliance Training Program and certify they have read it. Concerns about unethical conduct are raised via the global SpeakUp system (24/7, multilingual, anonymous option) under a zero-tolerance-for-retaliation policy aligned with the EU Whistleblower Directive. A global Anti-Bribery and Anti-Corruption Policy applies zero tolerance to bribery, backed by training, an annual compliance risk assessment, and anti-bribery due-diligence screening of partners/suppliers; no policy violations were detected in 2025. Culture is monitored via the annual Engagement & Belonging survey, SpeakUp data and internal audits. Separately, data privacy (a company-specific negative-impact topic combined with cybersecurity) is governed by a Global Data Privacy Policy (GDPR-aligned baseline) and a security program anchored on NIST CSF and ISO 27001, with a cross-functional Incident Response Team, a Data Privacy Incident Management Plan, mandatory annual training, and over 119 attestations/certifications (SOC 1/2, HITRUST, FedRAMP, CSA STAR, MSDPR); cybersecurity is overseen by a three-tiered structure led by the Chief Information Security Officer.

Reference: page 139

Back-filled from the business conduct chapter, where targets are addressed under the heading 'Targets related to corporate culture and data privacy' rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Wolters Kluwer sets three measurable targets under its G1 material topics: (1) improve the employee engagement score year-over-year (typically one point) from an October 2021 baseline of 76, aspiring to Microsoft Glint's top-25% global benchmark – the 2025 score of 78 held flat and remains 3 points below that benchmark; (2) 100% of active employees complete the Annual Compliance Training Program (covering the Code of Business Ethics, data privacy and cybersecurity) – 99% completed it in 2025 (unchanged from 2024/2023); and (3) maintain an indexed cybersecurity maturity score above the high-tech industry benchmark – the 2025 score of 115.0 held flat versus 2024. No target specifically addresses corruption or bribery incident rates; effectiveness there is tracked instead through the annual compliance risk assessment and anti-bribery due-diligence screening described under G1-1.