Wolters Kluwer

Reference: page 95

Wolters Kluwer operates under a two-tier board structure in line with Dutch law, comprising an Executive Board and a Supervisory Board. The responsibilities of both boards and their committees for impacts, risks, and opportunities (IROs) are set out in their respective By-Laws and Terms of Reference. The By-Laws of the Executive Board require that, when developing strategy, the board considers the company's sustainability impact, including effects on people and the environment, and that the company maintains an outline policy for effective dialogue with stakeholders. Under Dutch law the Executive Board has collective responsibility, though certain duties are allocated to the CEO and CFO, with the CFO responsible for sustainability data reporting and compliance with sustainability regulations.

The Supervisory Board By-Laws require it to take into account the impact of the company's actions on people and the environment and to weigh the interests of stakeholders. Key sustainability/ESG focus points of the Audit Committee are set out in its Terms of Reference, and the Selection and Remuneration Committee has oversight of the remuneration policy for the Executive Board, including its sustainability elements.

The Executive Board oversees the governance processes, controls, and procedures used to monitor and manage IROs. The Corporate Sustainability team provides periodic updates to the Executive Board, Supervisory Board, and Audit Committee on sustainability/ESG matters. It is led by the Senior Vice President and General Counsel (reporting to the CEO), supported by accounting and reporting specialists led by the Senior Vice President Finance, Budgeting & Reporting (reporting to the CFO). The team centrally coordinates sustainability efforts, ensures regulatory compliance, and partners with internal subject matter experts (SMEs) who set policies and targets on specific IROs and report into Executive Board members.

The disclosure includes tables mapping reporting lines and responsibilities for specific topics. Functions reporting to the CEO and Chair of the Executive Board include the CEO of Global Business Services (climate change across scopes, supply chain human and labor rights, business travel, cybersecurity), the Chief Human Resources Officer (DEIB, well-being, talent management, employee engagement, flexible work), the CEOs of operating divisions (access to quality information, corporate policy execution), and the SVP General Counsel and Company Secretary (corporate governance and ESG regulations). Functions reporting to the CFO include the EVP & General Counsel (data privacy, ethics and compliance), the VP Internal Control (Internal Control Framework for Sustainability Reporting), and the SVP Finance, Budgeting & Reporting (quantitative sustainability reporting). Group and individual meetings between the Executive Board and these functions give the boards visibility on the availability of required sustainability skills and expertise.

Reference: page 96

The Executive Board, the Supervisory Board, and its committees are informed about material impacts, risks, opportunities, and the related policies, actions, metrics, and targets by the functions responsible for each topic (as set out in the reporting-line tables), or by their delegates and teams. This information is typically provided one to four times a year, but more frequently as needed.

The disclosure includes a table summarizing the material topics discussed or addressed by each body in 2024. The Executive Board addressed:

• Climate change: updates on the real estate rationalization program, approval of a target to reduce the office footprint, progress on GHG emissions reduction targets, and approval of the net-zero GHG emissions reduction target.
• DEIB: updates on inclusion and belonging initiatives (belonging score, inclusive leadership training, global inclusion networks) and the outcome of the global pay equity analysis.
• Work-life balance: updates on the well-being program, pension progress and benefits, and approval of the Working Together flexible work model.
• Training and skills development: updates on skills-based talent management and the skills taxonomy.
• Data privacy: approval of the Global Data Privacy Policy and a cybersecurity program update.
• Human and labor rights of workers in the supply chain: approval of a new supplier sustainability assessment tool.
• Corporate culture: updates on the SpeakUp (whistleblowing) program and the employee engagement score.

The Supervisory Board (together with the Executive Board) was informed on climate change, DEIB, training and skills development, and supply chain human and labor rights. The Audit Committee was informed on climate change, supply chain human and labor rights, and corporate culture (including the SpeakUp program). The Selection and Remuneration Committee reviewed the non-financial performance measures of the short-term incentive plan covering climate change, DEIB, and data privacy.

Reference: page 96

The Supervisory Board is responsible for executing the remuneration policy, based on advice from the Selection and Remuneration Committee. The company's Remuneration report sets out the key elements of the Executive Board remuneration policy, including sustainability-related performance and the proportion of variable remuneration that depends on sustainability-related targets.

Climate considerations are factored into the selection of sustainability-related targets. In 2024, a new target on the percentage reduction in the office footprint was added to the non-financial performance measures for the short-term incentive plan (STIP). This measure is one of the key drivers of the reduction in scope 1 and 2 GHG emissions. The STIP offers cash incentives for achieving specific annual targets across a set of financial and non-financial performance measures, which are determined at the start of each year.

The company states it will continue to evaluate relevant climate-related STIP measures as it evolves its GHG emissions reporting. Further detail is provided in the Remuneration report sections on remuneration targets linked to strategic goals, the 2024 STIP, and payouts for performance against 2024 STIP targets.

Reference: page 97

Wolters Kluwer describes due diligence as an iterative process involving the identification, prevention, mitigation, remediation, and communication of impacts on people and the environment. Its approach to human rights and environmental due diligence involves the ongoing analysis of actual and potential impacts of its business activities, conducted as part of the double materiality assessment (DMA). This includes consultations with stakeholders and desk research on publicly available information relevant to its sector.

The company references the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises as the frameworks underpinning its due diligence. It acknowledges the importance of conducting this due diligence and states that in 2025 it aims to enhance the process by gaining more concrete insights into its value chain.

The disclosure includes a table mapping the core elements of due diligence to where they are addressed in the sustainability statements:

• Embedding due diligence in governance, strategy, and business model: ESRS 2 GOV-2, GOV-3, and SBM-3.
• Engaging with affected stakeholders: ESRS 2 GOV-2, SBM-2, IRO-1, plus ESRS E1, S1-2, S2-2, and S4-2.
• Identifying and assessing negative impacts on people and the environment: ESRS 2 IRO-1 and SBM-3.
• Taking actions to address negative impacts: ESRS E1-1, E1-3, S1-4, S2-4, and S4-4.
• Tracking the effectiveness of efforts: ESRS E1-4, E1-5, E1-6, several S1 disclosures (S1-5, S1-6, S1-7, S1-9, S1-12, S1-13, S1-15, S1-16, S1-17), other own-workforce company-specific metrics, S2-5, S4-4, G1, and corporate culture and data privacy company-specific metrics.

Reference: page 97

Internal controls related to the sustainability statements have been implemented in an Internal Control Framework for Sustainability Reporting (ICSR), specific to material data points and differentiating between environmental, social, and governance topics. Functional sustainability topic owners have been assigned, and Internal Audit will periodically perform thematic reviews on sustainability topics. The company has developed a sustainability reporting manual.

Sustainability-related reporting topics, compliance, and risks are periodically discussed in the Corporate Risk Committee, with outcomes reported to the Executive Board. Further steps to integrate sustainability reporting controls into the ICSR are planned for 2025. The company recognizes the importance of formalizing and embedding controls over the double materiality assessment (DMA) process and is taking additional steps to implement new sustainability-related controls following the conclusion of the DMA results. These controls will be tested for design and effectiveness, with results reported on the relevant internal control dashboards to functional management, internal and external auditors, the Executive Board, and the Audit Committee.

The company notes that the accuracy and completeness of some sustainability data is subject to judgments and estimates. As 2024 is the first year of reporting under ESRS, the internal control processes over this data are still maturing.

Reference: page 98

Wolters Kluwer is a global provider of information solutions, software, and services. Its customers are professionals across sectors including health, tax & accounting, finance, compliance, legal, and ESG, served through expert solutions that combine deep domain knowledge with technology to deliver content and workflow automation. The company's mission is to empower professional customers with the information, software solutions, and services they need to make critical decisions, supporting its purpose to help protect people's health and prosperity and contribute to a safe and just society.

The company serves several key markets: Health (clinical technology and solutions), Tax & Accounting, Financial & Corporate Compliance, Legal & Regulatory, and Corporate Performance & ESG (enterprise software for financial and sustainability performance and risk management). Over recent decades the business model evolved from a publishing company into a global provider of information, software solutions, and services, with the core now being cloud-based expert solutions, including the deployment of artificial intelligence and other advanced technologies. A small print portfolio remains for certain customer segments.

The disclosure presents a business model inputs and outputs overview for 2024:

• Human capital: efforts, skills, and talent of 21,600 employees, producing 2.4bn euro in salaries and benefits plus skills and career development.
• Technology and IP: global brand and software and content IP, generating 5.9bn euro in revenues from decision-enabling solutions for customers.
• Suppliers and partners: services, content, and goods from thousands of select vendors, with 2.1bn euro in operating costs on third-party content, goods, and services.
• Financial capital: 1.5bn euro equity capital and 4.1bn euro gross debt capital, delivering a 26.5% total shareholder return and 34m euro net interest paid to bondholders and banks.
• Natural resources: energy consumption along the value chain, with outputs including 318m euro of income taxes paid and products that protect health and prosperity.

The breakdown of total revenue by significant ESRS sector is not disclosed because the ESRS sector classification standard remains in draft by EFRAG; the company will disclose this once an application date is set. The disclosure applies the phase-in transitional provision for SBM-1 paragraphs 40(b) and (c).

Reference: page 99

Wolters Kluwer operates in more than 40 countries and serves customers in more than 180 countries, as part of a global value chain in which customers and suppliers are key partners. For delivery of its solutions, the company depends on third-party suppliers including providers of cloud services, outsourced and offshored data center services, software development and maintenance, back-office transaction processing, and content services. It has been migrating customers and applications to the cloud, allowing it to decommission on-premise servers and bringing improved cybersecurity, mobility, availability, and standardization. With increasing use of cloud hosting, the company considers environmental impacts connected to third-party data centers (energy, water, land use, and electronic waste) and the social impact on local communities, though its initial due diligence based on available information did not reveal material impacts or risks related to this topic.

The company actively engages in stakeholder dialogue across all business activities, in accordance with its Stakeholder Engagement Policy. The form of dialogue depends on the topic and the stakeholders involved, since not every stakeholder is equally relevant to every aspect of strategy. As part of the double materiality assessment, the views of key stakeholders were analyzed to understand their perspectives in terms of the company's material impacts, risks, and opportunities.

Stakeholder views inform strategy and the business model in varying ways:

• Employees: insights help enhance DEIB efforts, well-being policies, and career development, supporting talent attraction and retention.
• Customers and end-users: their input drives continuous improvement of products and services, ensuring quality, actionable, and reliable information.
• Investors: provide insights into market positioning and improvement areas.
• Suppliers: contribute through R&D and product development partnerships.
• Governments, regulators, industry associations, and research and academic institutions: contribute to product development, market strategies, and compliance.

Senior management of divisions and functional areas are involved in understanding the interests and views of specific stakeholder groups, with employee perspectives gathered through annual surveys, focus groups, and other initiatives shared with HR executives and cascaded to divisional leadership. The Executive Board and Supervisory Board and its committees are kept informed about stakeholder views by the Corporate Sustainability team and relevant functional leaders. The company is committed to respecting human rights, including data privacy, for customers, employees, and where applicable suppliers and their workers. For value chain workers, insights are gathered through the supply chain risk management program and the materiality assessment; under the transitional provision of the ESRS, the company will implement additional initiatives to obtain further insights into the interests and views of this group.

Reference: page 103

The company's double materiality assessment (DMA) identified eight material topics. Notably, the assessment found no material risks, only material impacts and opportunities. The material topics and their IRO types are:

• Climate change: negative impact (energy use results in CO2e emissions across scopes 1, 2, and 3, negatively impacting the environment; reduction is challenging due to dependency on external parties, particularly significant upstream supplier emissions).
• Diversity, equity, inclusion, and belonging (DEIB): positive impact and opportunity (under Own workforce).
• Training and skills development: positive impact and opportunity (under Own workforce).
• Work-life balance: positive impact and opportunity (under Own workforce).
• Labor and human rights of workers in the value chain: negative impact (direct suppliers' workers may potentially lack sufficient equal opportunities, wages, secure jobs, work-life balance, and health and safety protection).
• Access to quality information: positive impact and opportunity (under Consumers and end-users; quality, actionable, reliable information enables customers to make optimal decisions).
• Corporate culture: positive impact and opportunity (under Business conduct).
• Data privacy: negative impact (company-specific; protection of personal data could be impacted by data privacy or cybersecurity incidents).

The material ESRS standards are E1, S1, S2, S4, and G1, plus company-specific topics for access to quality information and data privacy. For data privacy the company adopted an entity-specific approach, combining it with cybersecurity and categorizing it under Governance Disclosures (G1). For some IROs, additional entity-specific metrics are used.

In determining its material IROs, the company conducted a resilience analysis using the ESRS time horizons, based on qualitative input from internal SMEs and a review of existing mitigating measures (its risk management framework and policies). The analysis concluded that despite the three material negative impacts (climate change, value chain labor and human rights, and data privacy), the strategy and business model are sufficiently positioned so that these do not pose a material risk to the business, mainly due to risk management practices including comprehensive cybersecurity and data privacy measures, climate change adaptation, and business continuity programs. For climate change, a preliminary climate-scenario analysis was also used.

The majority of material impacts are positive and present opportunities for growth and improvement, aligning with the company's strategy and values. While the DMA involved a qualitative analysis of the financial effects of material opportunities, the company has not yet quantified their financial impact and has not identified material opportunities that could significantly affect the reported values of assets and liabilities within the next annual reporting period. All material IROs are expected to have significant effects across the short, medium, and long term. The new three-year company strategy remains focused on delivering quality information and innovative expert solutions and fostering a great place to work. The DMA is an iterative process and the resulting material IROs are subject to change. This disclosure applies the phase-in transitional provision for SBM-3 paragraph 48(e).

Reference: page 104

The material IROs were identified through a double materiality assessment (DMA) using a six-step process. In 2024, the company built on its initial 2023 DMA to complete a comprehensive assessment. The full list of sustainability matters from ESRS 1 Appendix A was used as the basis, supplemented by analysis of business activities, operations, value chain, stakeholder interests, sector-specific reporting standards (GRI and SASB), ESG ratings, and peer company reports.

The six steps are:

• Step 1 - Review business activities and engage key stakeholders: reviewing business activities and office locations, identifying key upstream suppliers with heightened environmental and social risks (data centers, IT hardware, print providers, IT services, outsourcing, consulting), and identifying and prioritizing key stakeholders. Stakeholder views were gathered through proxies such as interviews with internal SMEs, sector studies, and the annual Engagement & Belonging survey; nature was also considered a key stakeholder.
• Step 2 - Outline relevant sustainability matters: short-listing relevant matters from the ESRS 1 list.
• Step 3 - Identify relevant impacts, risks, and opportunities: identifying actual and potential IROs across the value chain via desk research, internal SME consultation, and the employee survey. Value chain insights were obtained primarily from in-house and public information under the CSRD transitional provision. Higher-risk industries were researched, and topics linked to energy (E1), pollution (E2), water (E3), biodiversity (E4), and resource use and circular economy (E5) were assessed. Due to the nature of the business and urban office locations, the company found limited impact on pollution, water, biodiversity, and resource use, no dependencies on biodiversity or ecosystems, and identified no affected communities, so no related consultations were conducted. Climate-related IROs were identified by screening all scope 3 categories under the GHG Protocol and building an inventory of scope 1, 2, and material scope 3 emissions. The DMA did not identify assets or activities incompatible with a transition to a climate-neutral economy.
• Step 4 - Assess relevant impacts, risks, and opportunities: scoring IROs against predetermined parameters of impact and financial materiality, transforming qualitative assessments into quantitative scores with input from internal SMEs (HR, Privacy, Global Law and Compliance, Procurement). Impact materiality was assessed via severity (scale, scope, and, for negative impacts, irremediability), with likelihood also assessed for potential impacts. For potential negative human rights impacts, severity takes precedence over likelihood (likelihood was disregarded). Financial materiality was determined by the magnitude of financial effects (effect on resources and reliance on relationships), multiplied by the likelihood the risk or opportunity materializes.
• Step 5 - Prioritize material impacts, risks, and opportunities: developing thresholds to classify IROs as high, medium, or low; thresholds differed for positive and negative impacts and for financial versus impact materiality. Clustered IROs with high scores were deemed material.
• Step 6 - Validate material impacts, risks, and opportunities: validating the ranking and final list with internal SMEs and senior staff across functions (Global Business Services, Internal Audit, Treasury, Risk Management, Global Brand, Communications & Digital Marketing, Strategy) and customer-focused divisions. The DMA results were presented to and approved by the Executive and Supervisory Boards.

The company notes the DMA will be refined in coming years through benchmarking, broader due diligence, and deeper stakeholder engagement. The latest annual risk assessment was taken into account but the DMA is not yet fully integrated into the overall risk management process; currently the DMA and risk assessment serve as mutual inputs, with plans to evaluate further integration.

Reference: page 106

After identifying its material IROs, Wolters Kluwer assessed the materiality of each ESRS data point in relation to those IROs. Through a qualitative assessment and stakeholder engagement (as detailed in IRO-1, step 1), and considering parameters such as relevance to the company and its business, it determined the material information to be disclosed, which is presented in the subsequent chapters on environmental, social, and governance disclosures.

Reflecting the outcome of the DMA, the sustainability statements cover ESRS 2 (General Disclosures), ESRS E1 (Climate change, including E1-1 through E1-6), ESRS S1 (Own workforce), ESRS S2 (Workers in the value chain), ESRS S4 (Consumers and end-users), ESRS G1-1 (Business conduct, corporate culture), and company-specific data privacy disclosures.

Several disclosure requirements are treated as not material, including E1-7 and E1-9, and the entirety of ESRS E2 (pollution), E3 (water and marine resources), E4 (biodiversity and ecosystems), E5 (resource use and circular economy), and S3 (affected communities). The full list of ESRS disclosure requirements complied with following the DMA is provided in the company's Reference table, and the full list of data points deriving from other EU legislation is disclosed separately.

The company applies the phase-in transitional provision in ESRS 1 paragraph 137 for certain data points, namely SBM-1 paragraphs 40(b) and (c); SBM-3 paragraph 48(e); S1-7 paragraphs 55(a), (b), (c) and 57; S1-9 paragraph 66(a); S1-12 paragraph 77; and S1-13 paragraph 83(b). It also applies the ESRS 1 paragraph 133 transitional provision, which limits value chain information to information available in-house during the first three years of reporting, with appropriate references made throughout the statements.

Reference: page 108

Wolters Kluwer has developed a transition plan to reduce GHG emissions in line with a pathway to limit global warming to 1.5C, approved by the Executive Board and Supervisory Board. The plan is aligned with the COP21 Paris Agreement and the COP27 Sharm el-Sheikh Implementation Plan.

Key points:

• Not excluded from the EU Paris-aligned Benchmarks.
• Near-term targets validated by the Science Based Targets initiative (SBTi) in 2023. In January 2025, WK increased the ambition of its scope 1 and 2 near-term targets following successful office decarbonization, and submitted this update for SBTi validation.
• Long-term target: reach net-zero by 2050, submitted to the SBTi for validation.
• Decarbonization levers cover scope 1 and 2 (office footprint reduction, renewable electricity, energy efficiency) and scope 3 (supply chain decarbonization, business travel, employee commuting).
• Levers are integrated into existing strategies such as the Corporate Real Estate and Facilities program, supplier management, and flexible work.
• WK does not currently engage in carbon credit or carbon pricing mechanisms, but may in future consider carbon offsetting such as Energy Attribute Certificates (EACs) to neutralize residual emissions.

Reference: page 110

Wolters Kluwer has adopted an Environmental Policy to manage environmental matters, including climate change impacts. Its objective is to minimize the negative impact of operations on the environment and to comply with applicable local and international environmental laws.

Key points:

• Approved by the Executive Board; applies to all divisions, business units, and operating companies controlled by the company; available on the company website.
• Observes the three United Nations Global Compact environmental principles: support a precautionary approach, promote greater environmental responsibility, and encourage development and diffusion of environmentally friendly technologies.
• Addresses climate change mitigation, energy efficiency, and renewable energy deployment, covering consumption of energy, water, paper and other natural resources, and waste production.
• Commitments extended to suppliers through the Supplier Code of Conduct.
• Climate change adaptation is informed by internal Global Business Continuity Management Standards, including guidance on incident management arising from extreme weather events.

Reference: page 110

In line with its transition plan, Wolters Kluwer's climate change mitigation actions relate to three focus areas.

• Office decarbonization: Optimizing the real estate portfolio through office closures and consolidation and improving energy efficiency. In 2024, WK switched to renewable electricity contracts for two of its largest owned offices and installs motion-sensor LED lighting during lease renewals or renovations. New offices require LEED, BREEAM, or DGNB certificates and proximity to public transport.
• Reducing emissions from business travel: A business travel policy encourages virtual meetings, restricts business class air travel, and the travel booking tool displays CO2 emissions of each flight option.
• Supply chain decarbonization: WK updated its due diligence questionnaire on climate matters, generated an inventory of largest suppliers by spend with their scope 1, 2 and upstream scope 3 emissions, developed a carbon scorecard, and selected a supplier sustainability assessment tool for implementation in 2025.

WK has not identified significant monetary amounts of CapEx or OpEx that are incremental and directly contributing to climate change mitigation.

Climate change adaptation is driven by business continuity, incident, and IT disaster recovery programs, developed in line with industry standards such as BCI Good Practice Guidelines and ISO 22301, and follows the company-wide PEAR (People, Environment, Assets, Reputation) approach.

Reference: page 112

Wolters Kluwer has set GHG emission reduction targets and operational real estate targets.

Near-term science-based targets (from a 2019 base year, to 2030):

• 60% reduction in absolute scope 1 and 2 GHG emissions by 2030 (increased from 50% following successful office decarbonization; the updated scope 1 and 2 target was submitted to the SBTi at the beginning of 2025 and is pending validation).
• 30% reduction in absolute scope 3 GHG emissions by 2030 (validated by the SBTi).

Long-term (net-zero) target:

• Reduce absolute scope 1, 2 and 3 GHG emissions 90% by 2050 from a 2019 base year, with a residual 10% to be neutralized with high quality carbon removals. Submitted to the SBTi for validation (pending).

The scope 3 target includes scope 3.1, 3.2, 3.4, 3.6 and 3.7.

Progress against near-term targets:

• 83% of the scope 1 and 2 near-term target achieved.
• 29% of the scope 3 near-term target achieved.
• Scope 1 and 2 emissions reduced 50% since 2019; scope 3 emissions reduced 9% since 2019.
• Scope 1 and 2 emissions for 2024 are ahead of plan; scope 3 emissions are behind plan.

Real estate / office footprint target:

• Annual office footprint reduction target, part of the short-term incentive plan (STIP) non-financial measures. In 2024, WK aimed for a 6% reduction and achieved a 9% organic reduction, contributing to an 11% decrease in scope 1 and 2 emissions between 2023 and 2024.

Reference: page 114

Energy consumption of own operations relates to owned and leased offices. For 2024, 74% of energy consumption in MWh was confirmed; the remainder was estimated or extrapolated.

Energy consumption (in MWh):

• Consumption from fossil sources: 29,823 (76% of total)
• Consumption from nuclear sources: 1,660 (4% of total)
• Renewable energy consumption: 7,683 (20% of total)
• Total energy consumption: 39,166 MWh (down from 43,399 in 2023 and 47,880 in 2022)

Renewable energy consumption (in MWh):

• Consumption from purchased or acquired renewable sources: 7,675
• Consumption of self-generated non-fuel renewable energy: 8
• Total renewable energy consumption: 7,683

Energy production: Total energy production of 8 MWh (primarily solar panels on office roofs).

In 2024, energy consumption decreased due to a reduction in square meters and energy-saving measures. WK did not purchase Energy Attribute Certificates (EACs) and does not have own operations in high climate impact sectors.

Reference: page 115

Wolters Kluwer's emissions are dominated by upstream scope 3 from suppliers, which account for approximately 80% of total GHG emissions (purchased goods and services alone is about 75% of total emissions).

Gross GHG emissions for 2024 (in tCO2e):

• Scope 1 (direct emissions): 2,101
• Scope 2 (market-based): 7,760
• Sub-total scope 1 + 2 (market-based): 9,861
• Scope 2 (location-based): 10,179
• Sub-total scope 1 + 2 (location-based): 12,280
• Sub-total scope 3: 269,596
  • Scope 3.1 purchased goods and services: 211,031 (of which cloud computing and data center services: 25,811)
  • Scope 3.2 capital goods: 1,955
  • Scope 3.4 upstream transportation and distribution: 11,900
  • Scope 3.6 business travel: 32,593
  • Scope 3.7 employee commuting: 8,099
  • Scope 3.11 use of sold products: 4,018
• Total gross GHG emissions (market-based scope 2): 279,457
• Total gross GHG emissions (location-based scope 2): 281,876

GHG emissions intensity (2024): 47 tCO2e per million euros of revenue (market-based scope 2); 48 (location-based scope 2), on revenues of 5,916 million euros.

None of WK's scope 1 emissions are from regulated emission trading schemes. Several scope 3 categories (3.3, 3.5, 3.9, 3.12, 3.13, 3.15) were excluded as individually insignificant (together under 5% of total scope 3), and scope 3.8, 3.10 and 3.14 are not applicable.

Reference: page 110

Wolters Kluwer states that it prioritizes direct emissions reduction efforts and does not currently engage in carbon credit or carbon pricing mechanisms. The company notes it may in future consider utilizing carbon offsetting mechanisms such as Energy Attribute Certificates (EACs), and continues to monitor developments related to climate offsetting as part of its long-term plan to achieve net-zero. WK does not apply an internal carbon pricing scheme.

Reference: page 121

Wolters Kluwer has several policies addressing its material own-workforce matters: DEIB (diversity, equity, inclusion and belonging), training and skills development, and well-being.

• The Code of Business Ethics (Code) sets the ethical standards underpinning company decisions and actions. It is approved and adopted by the Executive Board and reviewed annually, and covers policies on material workforce impacts.
• The equal opportunity policy (in the Code) provides for an inclusive culture and merit-based employment decisions, with no discrimination on grounds such as race, color, religion, sex, age, national origin, sexual orientation, gender identity, ethnicity, disability, or veteran status. It covers recruitment, hiring, training, compensation, promotion, performance assessment, and disciplinary action. It is further detailed in the DEIB Policy and Human Rights Policy, and extends to political opinion, national extraction, and social origin.
• The SpeakUp Policy enables the workforce to raise concerns about suspected misconduct (violations of the Code, other policies, or applicable laws).
• Policies are made available to the workforce in various languages via a dedicated intranet page and the company website, and the workforce is made aware through regular training and communication.

Wolters Kluwer supports human rights as set out in the Universal Declaration of Human Rights, the core ILO standards, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. It is a signatory of the UN Global Compact and the UN Women's Empowerment Principles. The Human Rights Policy addresses commitments to prevent modern slavery and human trafficking. The company states it does not have operations at risk of incidents of forced, compulsory, or child labor.

Reference: page 122

Wolters Kluwer has several mechanisms to engage with its workforce and monitor employee attitudes:

• The annual Engagement & Belonging survey gauges employee sentiment on growth and development opportunities, management support, and sense of inclusion and belonging. Improvement areas are identified and action plans implemented.
• Targeted surveys during onboarding and exit, plus ad hoc focus groups, polls, and pulse surveys.
• Bi-annual all-employee townhalls and quarterly townhalls for specific business lines and functions, supported by intranet and internal messaging platforms.

The company engages regularly with the European Work Council (EWC) on strategic and organizational matters, providing a structured forum for dialogue between central management and employee representatives across European countries. Topics discussed with the EWC in 2024 included results of the Engagement & Belonging survey, initiatives to improve engagement and career opportunities, flexible work arrangements, pay transparency and fair compensation, and promotion of SpeakUp channels. The company also maintains regular interactions with local work councils in European countries.

The global Talent Management team and HR business partners focus on attracting, developing, and retaining the workforce, with an employee listening function collecting and analyzing feedback. The Chief Human Resources Officer has ultimate responsibility for engagement with the workforce.

Reference: page 122

Wolters Kluwer promotes an open and inclusive environment where everyone can voice concerns. The workforce can raise concerns or ask questions through various channels:

• Direct manager
• Human Resources
• Senior management
• The SpeakUp system

A dedicated intranet page provides information about these channels and the process, and the workforce is made aware of them through training and communication activities.

The Human Resources function offers expert guidance focused on a respectful and equitable workplace, handling matters such as performance management, corrective action, conflict resolution, investigations into policy violations, discrimination and harassment allegations, and religious or medical accommodations.

All concerns raised and addressed through these channels are tracked and monitored. As part of the annual Engagement & Belonging survey, the company gauges employees' trust in speaking their minds.

Reference: page 123

Actions cover the three material sub-topics: DEIB, training and skills development, and work-life balance.

Diversity, equity, inclusion and belonging (DEIB)

• A dedicated HR team of specialists in compensation, benefits, well-being, and recognition supports implementation across HR processes.
• The Global Career Framework defines roles and responsibilities, includes base pay structures, and is reviewed annually; managers are trained on it.
• Job postings are screened to be free from biased language and to appeal to a broad range of candidates.
• Learning programs for all employees on inclusive behaviors, mitigating bias, and allyship; managers receive inclusive leadership training.
• A global accessibility resource site provides tools for inclusive technology use and content.
• Three Global Inclusion Networks (Pride, Women's, and Multicultural) are employee-led networks advancing inclusion and cultural awareness; the company partnered with a non-profit foundation supporting LGBTQ+ people in workplaces.
• Equal pay for equal work: in 2024 the company partnered with external experts on a comprehensive global pay study covering all employees worldwide, examining all fixed and variable pay components and benefits, to identify and address gender pay gaps. It reports both unadjusted and adjusted gender pay-gap ratios and is developing a phased plan to monitor and manage pay equity.

Work-life balance

• A global well-being program managed by a global team of benefits and well-being experts, supported by 100+ well-being champions.
• In 2024, a Global Well-being Week (including the "Let's Walk Around The World" challenge) and World Mental Health Day activities.
• A global Employee Assistance Program (EAP) providing confidential counselling and resilience, fitness, nutrition, and mindfulness tools.
• Comprehensive benefits including family planning (parental leave, adoption assistance, fertility coverage, childcare support); in 2024 the company introduced menopause benefits and hosted a panel on parenting options.
• Flexible work arrangements (flexible hours, partial work from home), comprehensive paid time-off (maternity, paternity, adoption, and carers' leave), and a volunteer time-off program.

Training and skills development

• A global Learning and Development team plus dedicated talent partners in each division.
• Progress toward becoming a skills-powered organization with targeted learning paths and career navigation resources.
• A performance management process for all employees with annual goals, check-ins, and reviews.
• A career development process where employees annually update their talent profile, using a career planning tool and leadership competency assessment, supported by an internal #Grow site.
• Enhanced succession planning to build a pool of high-potential successors for critical roles.
• A 70:20:10 learning model (70% on the job, 20% informal, 10% formal) delivered via a global learning platform with self-paced courses on more than 16,000 training topics.
• Leadership development offerings for all people managers, expanded in 2024 with audience segmentation, blended and AI-native digital learning, and a flash mentoring program extended to all non-executive people managers.

Reference: page 125

Wolters Kluwer set the following targets after evaluating the organization against market benchmarks:

• Belonging score: aim to improve the belonging score year-over-year, typically by one point. The baseline (72) was established in July 2021. The aspiration is to reach the top 25% of the global benchmark for belonging (per Microsoft Glint's analysis). The score was maintained in 2024. The target is included in the non-financial performance measures for the 2023, 2024, and 2025 short-term incentive plans.
• Male/female representation on the Supervisory Board and Executive Board: target of at least 33% male and female representation on both boards (Dutch law requires at least one-third).
• Female representation in the executive career band (management positions): target to achieve 33% female representation by 2028, set in 2023, with a baseline of 31% in 2022. The company achieved this target in 2024. Progress is monitored by the HR Leadership team and executive leadership using monthly dashboards.

Reference: page 126

All figures are reported in headcount at December 31. Headcount data is sourced from the global human resources management platform. Currently employees can only specify male or female; those who did not select or disclose a gender are reported as 'not disclosed'.

Total headcount at December 31, 2024: 21,635 (2023: 21,438; 2022: 20,511).

Headcount by gender (2024):

• Female: 9,831 (46%)
• Male: 11,558 (53%)
• Not disclosed: 246 (1%)

Headcount by region (2024):

• The Netherlands: 1,180 (5%)
• Europe (excluding the Netherlands): 6,934 (32%)
• U.S. and Canada: 8,979 (42%)
• Asia Pacific: 4,455 (21%)
• Rest of the world: 87 (0%)

By country, the U.S. (8,588; 40%) and India (3,527; 16%) are the only two countries each representing at least 10% of employees.

Headcount by contract term (December 31, 2024):

• Permanent employees: 19,531 (Female 8,500; Male 10,815; Not disclosed 216)
• Temporary employees: 294 (Female 148; Male 122; Not disclosed 24)
• Non-guaranteed hours employees: 1,810 (Female 1,183; Male 621; Not disclosed 6) The split between permanent and temporary employees is only reported from 2024, so no comparative is provided. Non-guaranteed hours employees are almost all in the U.S. (customer service, fulfillment, inside sales) and on average worked 36 hours per week in 2024.

Employee turnover (2024): 2,043 employees left (excluding divested operations); total turnover 9.5% (voluntary 6.6%, non-voluntary 2.9%).

A company-specific metric on race/ethnicity of U.S. employees (Total U.S. headcount 8,588) is also disclosed: White 5,761 (67%), Asian 1,149 (14%), Black or African American 631 (7%), Hispanic or Latino 552 (6%), other races/ethnicities 178 (2%), unknown or not disclosed 317 (4%).

Reference: page 127

Non-employees are individual contractors and people provided by suppliers primarily engaged in employment activities.

At present, Wolters Kluwer does not have a system in place to collect and monitor the characteristics of non-employees in its own workforce. It aims to conclude implementation of such a system in 2025. The company makes use of the phase-in (transitional) option for this disclosure and plans to start reporting the global number of non-employees in the next annual report.

Reference: page 127

Diversity metrics are reported in headcount at December 31, based on the global human resources management platform. 'Executives' are employees in the executive career band (excluding the Executive Board); 'Managers' are employees with one or more direct reports (excluding the Executive Board and executives).

Gender ratio, % female (2024):

• Total headcount: 46%
• Executive Board: 50%
• Executives: 34%
• Managers: 40%
• Other employees: 46%
• Supervisory Board: 57% (Supervisory Board members are not employees)

Headcount by employee category and gender (2024):

• Supervisory Board: Female 4, Male 3
• Executive Board: Female 1, Male 1
• Executives: Female 102, Male 200, Not disclosed 0

Headcount by age group (2024):

• Under 30: 2,897 (14%)
• 30-50: 12,410 (57%)
• Over 50: 6,328 (29%)
• Total: 21,635

The related Persons-with-disabilities and non-employee diversity datapoints rely on phase-in (transitional) provisions (see S1-7 and S1-12).

Reference: page 128

The disability percentage is derived from U.S. employees who indicated a disability in the global human resources management platform. Wolters Kluwer makes use of the phase-in (transitional) option for this metric to allow more time to enhance and refine data collection for non-U.S. employees, and will start reporting the disability percentage for all employees in the next annual report.

Persons with disabilities in the U.S.:

• % of U.S. employees with disabilities (2024): 9% (2023: 2%; 2022: 2%)

The material increase in 2024 is attributed to the implementation of an enhanced reporting process.

Reference: page 128

All employees participate in a global, annual performance management process. Training activity and time are captured in the learning platform (mandatory compliance training is excluded; external training, self-study, and other events are not captured). Wolters Kluwer makes use of the phase-in (transitional) option for the training-hours metric and plans to start reporting full training hours, including those occurring outside the learning platform, in the next annual report.

Performance review:

• % of employees who participated in performance and career development reviews (2024): 96% (2023: 97%)
• By gender (2024): Female 96%, Male 97%, Not disclosed 62%
• By category (2024): Executives 98%, Managers 98%, Other employees 96%

Training:

• % of employees that utilized internal training content in the learning platform (2024): 88% (2023: 97%)
• Average number of training hours per employee (2024): 8 (2023: 5)
• Training hours by gender (2024): Female 9, Male 8, Not disclosed 6
• Training hours by category (2024): Executives 8, Managers 12, Other employees 8

No 2022 comparatives are reported because a different methodology was previously applied.

Reference: page 129

Family-related leave is reported per ESRS definitions (maternity, paternity, parental, and caregivers' leave). Data is derived from the global human resources management system plus a third-party program for a small part of U.S. employees. Wolters Kluwer makes use of the phase-in (transitional) option for this metric and currently only reports on U.S. employees; it plans to start reporting work-life balance metrics for the full workforce in the next annual report.

Family-related leave in the U.S.:

• % of employees entitled to take family-related leave at December 31 (2024): 100% (2023: 100%; 2022: 100%)
• % of employees that took family-related leave in the year (2024): 4% (2023: 6%)
• By gender (2024): Female 5%, Male 3%, Not disclosed 4%

No 2022 comparative is reported for leave taken because a different definition was previously applied.

Reference: page 130

Wolters Kluwer conducted its first global pay equity analysis to determine any gender pay gap, covering all 20,000+ employees and all fixed and variable pay components plus other benefits. The analysis was conducted by an internal HR specialist team in partnership with an external global consulting firm, with data collected as of November 1, 2024, covering 21,555 positions.

Remuneration metrics (2024):

• Unadjusted gender pay-gap ratio: 14.8% (the average pay difference between females and non-females without accounting for compensable factors)
• Adjusted gender pay-gap ratio: 3.1% (after accounting for compensable factors such as job level, location, and experience; this is below the anticipated long-term threshold of 5%)
• Annual total remuneration ratio: 106.8 (the ratio of the highest paid individual, the CEO, to the median annual total remuneration of all employees excluding the highest-paid individual)

These are new metrics in the 2024 Annual Report, so no comparatives are reported. Non-females represent less than 1% of employees. The annual total remuneration ratio differs from the IFRS-based CEO pay ratio in the Remuneration report, mainly due to the use of a median versus an average and the exclusion of social security benefits under the ESRS methodology.

Reference: page 130

Wolters Kluwer maintains a culture of open communication and a safe environment where everyone is encouraged to raise concerns. In accordance with the Code of Business Ethics and SpeakUp Policy, the workforce can raise concerns through multiple channels about suspected misconduct (violations of the Code, other policies, or applicable laws).

The number of complaints filed through channels for the own workforce to raise concerns includes complaints filed through the SpeakUp system or to HR (for example through the global HR system or directly to an HR representative), excluding incidents of discrimination and harassment, which are separately captured in a table on the following page. Globally, the company uses an employee relations case management platform to track complaints reported to HR.

Wolters Kluwer has processes to ensure timely reporting of all threatened or actual legal claims, litigation, and alternative dispute resolution proceedings, including pre-litigation employment claims globally, tracked by the litigation team in an electronic matter management system through the life cycle of each matter.

Reported metrics for 2024 (a new metric set, so no comparatives):

• Number of complaints: 62
• Number of incidents of discrimination, including harassment: 5
• Fines, penalties, and compensation for damages: none reported

Of the 67 complaints and incidents of discrimination (including harassment) in total, 37 were derived from the SpeakUp system. Substantiated or partly substantiated discrimination or harassment complaints are excluded from the complaints count and captured separately.

Reference: page 132

Wolters Kluwer's operations depend on upstream suppliers and their workers for cloud services, outsourced and offshored data center services, software development and maintenance, back-office transaction processing, and content services. The material topic is Labor and human rights of workers in the value chain (a negative impact).

Supplier Code of Conduct. This is WK's central policy. It outlines the environmental, social, and business conduct standards for all suppliers, business partners, agents, resellers, and third parties providing products or services to WK. It supplements WK's Code of Business Ethics. Human and labor rights commitments included in the code require suppliers to:

• Support and respect internationally recognized human rights in dealing with employees, clients, suppliers, shareholders, and communities
• Prohibit, prevent, mitigate, and remediate any form of human trafficking, slavery, servitude, or forced, bonded, prison, military, or compulsory labor, and prohibit child labor, consistent with International Labor Organization and UN Global Compact definitions and all child labor laws
• Ensure equal treatment and reward, including equal pay for equal work, non-discrimination in hiring and employment, and a diverse and inclusive work environment
• Comply with all applicable wage, hour, and benefits laws, paying fair wages and benefits in line with industry standards
• Provide a safe, hygienic, and healthy workplace in compliance with applicable laws

The Supplier Code of Conduct is aligned with the UN Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the ILO Core Labor Standards. In 2024, no cases of non-respect of these standards or principles were brought to the company's attention.

The Supplier Code of Conduct is one mechanism of WK's Supply Chain Risk Management (SCRM) Program, guided by the internal SCRM Standard, which outlines WK's approach to risk assessments, due diligence, and supplier monitoring. WK plans to review the SCRM Standard in coming years to account for guidance on human and environmental due diligence.

WK notes it has not yet obtained full insight into the human rights and labor conditions of supply chain workers; based on available information it has not detected risks related to human rights, child labor, or forced labor, though it does not exclude that in certain sectors and geographies workers may lack equal opportunities, adequate wages, secure jobs, work-life balance, or health and safety protection. In 2024 WK initiated development of a supplier sustainability assessment strategy and uses the ESRS transitional provision allowing value chain information to be limited to in-house and publicly available data for the first three years.

Reference: page 133

In its double materiality assessment, Wolters Kluwer engaged in a preliminary scoping exercise to identify areas of heightened risk of severe impacts, based on proxies such as sector studies and initiatives.

Over the next few years WK plans to conduct a more thorough mapping of its value chain and improve its understanding of the actual and potential human and labor rights issues affecting value chain workers. As it gains more visibility and begins to assess suppliers' policies and practices related to their own workforce, WK states it will develop relevant processes to engage with these stakeholders about impacts. Direct engagement processes with value chain workers are therefore still being developed.

Reference: page 133

Wolters Kluwer's Supplier Code of Conduct provides that workers in WK's supply chain can raise questions or concerns to their usual Wolters Kluwer contact or by contacting the Wolters Kluwer Ethics & Compliance team. The code includes a zero-tolerance stance to retaliation against anyone raising a concern in good faith.

The channel to raise concerns described in the Supplier Code of Conduct is available to these workers on WK's website. WK states it intends to enhance the accessibility of, and information on, this channel and related processes for value chain workers. Wolters Kluwer will review and consider all concerns raised and will investigate and respond as appropriate. Concerns raised to the Ethics & Compliance team are centrally tracked and monitored through the SpeakUp system (see Business conduct, ESRS G1).

Reference: page 133

Wolters Kluwer's Supply Chain Risk Management (SCRM) Program ensures third-party relationships are evaluated and monitored throughout their duration to mitigate risks. Its main elements are an inherent risk assessment, due diligence, contract negotiation, continuous monitoring, reporting, and processes for remediation and termination.

As part of due diligence, suppliers are asked to provide information on areas including cybersecurity and data privacy, business continuity, anti-bribery and anti-corruption, employee hiring and termination practices, and maturity in environmental reporting and decarbonization. Based on a supplier's assigned inherent risk classification, due diligence is repeated every one to three years.

WK requires suppliers to adhere to its Supplier Code of Conduct or to their own equivalent standard covering areas such as human rights, labor conditions, anti-bribery, and the environment; where a supplier uses its own standard it is asked to confirm adherence to each covered area. Wolters Kluwer has not been made aware of, or received any reports of, significant human rights issues or incidents.

In 2024, WK began a new supplier sustainability engagement strategy, including selecting a supplier sustainability assessment tool that will form the basis of its human rights due diligence and supplier engagement strategy. This is intended to give visibility of potential social impacts in the value chain and to support alignment with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines. WK expects to report on these actions and initial findings in its next annual report. The actions are managed by a dedicated team within the global sourcing and procurement organization in partnership with the Corporate Sustainability team.

Reference: page 133

Wolters Kluwer currently does not have targets regarding workers in the value chain. As it improves visibility of its value chain through a strengthened human rights due diligence and supplier engagement strategy, WK will evaluate in the coming years whether setting specific goals is appropriate.

Reference: page 134

Wolters Kluwer notes that consumers are not relevant to its value chain; its products and services are designed for business or professional purposes, not personal use. This section therefore focuses exclusively on end-users, defined as individuals who receive the benefit of WK's products or services through their use by WK's customers (for example medical patients, clients of accounting firms, small businesses, or individuals served by WK's customers).

The material topic is Access to quality information (a positive impact and opportunity). Providing high-quality, reliable, and actionable solutions to customers to benefit their end-users is a fundamental aspect of WK's strategy and business model. WK's mission is to help customers make critical decisions every day by offering expert solutions that combine deep domain knowledge with specialized technology and services. (The material impact of data privacy on direct customers and relevant end-users is reported separately under the Data privacy company-specific topic in the governance section.)

Policies:

• Code of Business Ethics, which includes WK's global Editorial Policy, supports the objective of providing high-quality products and services. It commits WK to delivering high-quality solutions and content based on interpretation, best practice, analysis, and guidance relating to legal, market, and other sources; to be impartial and accurately reflect the legal, financial, health, and professional landscape and significant variations of opinion; and to actively avoid bias, defamation, and conflict of interest. The Code is available on WK's website.
• AI Principles. AI is used in products where it benefits human experts in complex professional fields; WK relies on its AI Principles to ensure products and services are based on trust, transparency, and responsibility. The AI Principles are available on WK's website.
• Tailored business-unit policies. Because user groups and content differ across divisions, business units often follow tailored policies guiding product development. As an example, the clinical decision tool UpToDate has its own regularly reviewed, interdisciplinary editorial policy created and maintained by physician editorial leadership, editorial operations leadership, and legal counsel, with specific policies for conflicts of interest, linking, grading, and off-label drug use; this editorial policy is integral to ensuring high-quality content and maintaining medical accreditation.

Reference: page 135

Providing quality information through its products and services is fundamental to Wolters Kluwer's purpose and to maintaining customer and end-user trust. WK actively engages with customers to gather feedback and incorporate it into product development.

• User research and direct feedback: contextual research, user interviews, and persona research; some product teams visit customers on-site to observe product usage in real-world settings.
• Beta testing: small customer groups test new products and significant enhancements; feedback is collected through advisory boards, user experience interviews, in-app requests, and surveys on features, functionality, and satisfaction.
• Customer feedback and engagement platforms are used to systematically gather and prioritize feedback for data-driven decisions; for certain solutions WK tracks and reviews in-product usage data to understand user workflows and behavior.
• Conferences and forums: annual user group conferences, regional forums, and industry summits provide direct feedback from a wider range of customers and end-users.
• Center of Excellence for UX and CX within the centralized development organization (DXG) helps WK understand customer needs at a granular level.
• Customer service teams regularly interact with clients to answer questions and gather feedback; WK uses Net Promoter Score (NPS) surveys to track satisfaction and product performance, feeding results into product development.

By collecting and acting on feedback through these channels, WK aims to ensure products evolve to meet customer needs and enable better outcomes for end-users such as clients or patients.

Reference: page 135

The continuous enrichment of solutions is central to Wolters Kluwer's product development. Dedicated product teams take actions throughout the year to improve content and workflows, ensuring customers have access to quality information. The activities below were compiled from analysis of six featured solutions across WK's five customer-facing divisions:

• External experts: WK commissions third-party experts for professional insights and to perform quality assurance as part of standard product release testing.
• Editorial independence: editors are allowed independence in decision-making, free from external pressure, to foster a free exchange of ideas.
• Content validation and data integrity: content-based solutions go through a rigorous multi-step process for accuracy and relevance; all content is obtained from authoritative sources, with data integrity ensured through validation workflows and audit trails.
• Investing in solutions: WK spends more than 10% of revenues on product development each year.
• User testing and feedback: internal user testing, pilot and beta testing, and usage tracking for many solutions.
• Continuous innovation: driving UX and CX as a discipline, plus formal employee programs such as the Global Innovation Awards and Code Games, and value-creation projects related to strategy and market research.
• Focus on AI-powered solutions: a large portion of digital revenues derive from products with embedded AI. In 2024 WK integrated AI-driven decision support tools into health software solutions such as Lexidrug and UpToDate, and built out a generative AI ecosystem enabling development teams to integrate emerging capabilities.
• Tailored, actionable insights: launching localized versions of solutions to help professionals work efficiently and comply with relevant regulations.
• Certifications and compliance: many solutions are certified or adhere to standards such as ISO 9001, ISO/IEC 27001, and SOC 2 Type II, with regular audits and compliance reviews.

Effectiveness of these actions is evaluated using methods including quality analyst testing, usage tracking, product experience platforms, NPS surveys and in-app NPS scoring, third-party market and industry surveys, and routine customer interviews about their experience and interface changes.

Reference: page 135

While individual business units may have internal targets, Wolters Kluwer states its processes and policies are highly elaborated and continuously reviewed and updated, and that business units use various methods to evaluate the effectiveness of their actions and initiatives. For this reason, WK does not consider it necessary to have external targets related to end-users at this point in time.

Reference: page 136

Wolters Kluwer's company values and ethical standards underpin how it interacts with employees, customers, suppliers, partners, and society. WK's only material governance topic is corporate culture, alongside the company-specific data privacy topic.

Code of Business Ethics and corporate culture

• The Code of Business Ethics (Code) sets the ethical standards that form the basis for WK's decisions and actions and provides guidance on living the company values. It covers topics such as discrimination and harassment, anti-bribery and anti-corruption, and conflicts of interest, several detailed further in standalone policies. The Code is published on internal and external websites in various languages.
• WK fosters corporate culture by incorporating values and ethical standards into day-to-day work through communication and training. The Annual Compliance Training program, mandatory for all employees, includes a course on the Code; employees certify they have read and understood it.

Channels for raising concerns

• The Code and SpeakUp Policy describe how the workforce can raise concerns. The global SpeakUp system, operated through an external provider, offers a confidential channel available 24/7 for reporting in employees' own language, with an anonymous option.
• The SpeakUp Policy includes zero-tolerance for retaliation, protecting anyone who raises a concern or participates in an investigation in good faith, in accordance with the EU Directive for the Protection of Whistleblowers. Concerns are promptly assessed and, where appropriate, assigned to an impartial and competent internal investigator. Information on SpeakUp is provided via a dedicated intranet page, communication campaigns, and training within the Annual Compliance Training program.

Anti-bribery and anti-corruption

• WK has a zero-tolerance policy towards bribery and corruption. Its global Anti-Bribery and Anti-Corruption Policy prohibits offering, soliciting, giving, or receiving bribes. WK trains all employees on bribery and corruption plus role-based training for specific groups, regularly communicates its policies, and conducts an annual compliance risk assessment that includes bribery and corruption. Functions most at risk include business units using third-party representatives that interact with government officials or located in higher-corruption-risk countries (per Corruption Perceptions Index scores).
• High standards of integrity and legal compliance also apply to business partners through the Supplier Code of Conduct; WK conducts anti-bribery due diligence screening of partners and suppliers. In 2024, WK did not detect any violations of its Anti-Bribery and Anti-Corruption Policy.

WK monitors corporate culture through its annual Engagement & Belonging survey, the SpeakUp program, and internal audits, which also help measure the effectiveness of the Code and SpeakUp program.

Data privacy (company-specific material topic)

Data privacy is a company-specific material topic with a negative impact (risk of data privacy and cybersecurity incidents). As a data-driven digital company, personal information resides in WK's products; customers rely on WK to deliver platforms and services safely and reliably while safeguarding their data. In case of privacy or security incidents, the privacy rights of end-users could be negatively impacted. Cybersecurity is described as a critical component of WK's business model and strategy, supported by a robust security program.

• Policies related to data privacy: A Global Data Privacy Policy sets the data privacy principles WK adheres to when processing personal data, serving as a global baseline across divisions, business units, and countries and reflecting adherence to the highest standards including the EU General Data Protection Regulation. Additional privacy policies cover specific functional areas or locations, and standards for processing personal data are included in third-party (vendor) contracts. Specific policies govern use of workforce personal data, with mechanisms for employees to exercise data privacy rights; employee privacy policies are provided and acknowledged on hire and on material change. WK communicates privacy practices to customers and clients of customers, notifies of incidents per legal/regulatory/contractual requirements, and lets individuals ask questions or exercise privacy rights via a website form. WK plans 2025 enhancements to strengthen its data privacy posture.
• Policies related to cybersecurity: The Code of Business Ethics includes a policy on responsible and secure use of company technology and systems, detailed further in an Acceptable Use Policy and other security policies within a comprehensive security program. The program is anchored by policies, standards, and controls aligned with industry best practices such as the NIST Cybersecurity Framework (NIST CSF) and ISO 27001, designed to protect data and maintain confidentiality, integrity, and availability. All security policies and standards undergo regular review, updates, and approvals.
• Actions related to data privacy: Robust incident management procedures address security incidents and unauthorized acquisition, use, or disclosure of personal data. A cross-functional global Information Technology Security Incident Response Team plans, assesses, enforces, documents, and remediates incidents; a channel exists for employees to report data privacy incidents, managed under a Data Privacy Incident Management Plan. Regular training and awareness programs, including mandatory cybersecurity and data privacy courses in the Annual Compliance Training Program, foster a culture of security and privacy.
• Actions related to cybersecurity: WK performs regular information security risk assessments; the program is assessed annually by an independent third party, yielding a cybersecurity maturity score that since 2020 has been based on the NIST CSF risk-based model. WK has achieved over 85 attestations and certifications for select systems, applications, and services, most notably SOC 1 Type 1, SOC 2 Type 2, HITRUST, FedRAMP, CSA STAR, and MSDPR, and some locations and products have attained ISO 27001 certification.
• Cybersecurity governance structure: The security program has a three-tiered management structure overseen by a Leadership Security Council of senior executives, with the Chief Information Security Officer leading the Technology Security Council responsible for managing and monitoring the overall program and managing the overarching security strategy and IT security risk, supported by dedicated taskforce groups.
• Targets and metrics: WK has targets to advance corporate culture and data privacy. It targets continuous improvement of the employee engagement score (typically by one point year-over-year; baseline 76 set October 2021), aspiring to reach the top 25% of the global Microsoft Glint benchmark. It targets 100% of active employees completing the Annual Compliance Training (which includes courses on the Code of Business Ethics, data privacy, and cybersecurity). It targets maintaining an indexed cybersecurity maturity score above the high-tech benchmark. Reported metrics: percentage of employees completing Annual Compliance Training was 99% (2024, 2023, 2022); employee engagement score was 78 (2024 and 2023; 77 in 2022); indexed cybersecurity maturity score rose to 115.0 in 2024 (from 113.8 in 2023 and 110.0 in 2022), exceeding the target of 110 by 5%.