G1 – Business Conduct

Business conduct policies and corporate culture

Amadeus has established comprehensive business conduct policies and maintains a strong corporate culture focused on integrity, transparency, and ethical behavior as part of its "Be a reference for trust and integrity" commitment.

Core Business Conduct Policies:

Code of Ethics and Business Conduct: • Establishes fundamental principles for ethical behavior • Applies to all employees and operations globally • Sets standards for integrity, transparency, and responsible business practices • Regularly updated to reflect evolving standards and requirements

Anti-Bribery & Anti-Corruption Policy: • Comprehensive framework for preventing corruption and bribery • Applies to all business relationships and operations • Includes specific procedures for risk assessment and mitigation • Regular training and awareness programs

Human Rights Policy: • Renewed in 2024 to strengthen commitments • Based on UN Global Compact, Universal Charter of Human Rights, ILO Declaration, UNGPs, European Social Charter, and OECD Guidelines • Establishes commitments toward employees, society, local communities, and supply chain • Includes commitment to conduct human rights due diligence

Additional Key Policies: • Code of Ethics and Business Conduct for Third Parties: Extends ethical standards to business partners • Community Impact and Charitable Donations Policy: Guides social responsibility initiatives • Sustainability Policy: Framework for environmental and social commitments • Environmental Policy: Specific environmental management commitments • People Policy: Workforce-related policies and practices

Corporate Culture Integration:

ESG at the Core: • "Embed ESG at the core of Amadeus' culture" is a specific goal within the ESG Ambition • Sustainability integrated into business processes and decision-making • Regular training and awareness programs on ESG topics • Employee engagement on sustainability and ethical matters

Governance and Accountability: • Board oversight: Board of Directors approves and oversees business conduct policies • Committee supervision: Audit Committee supervises compliance with sustainability and business conduct policies • ESG Steering Committee: Reviews ESG strategy and compliance • Management accountability: Clear roles and responsibilities for policy implementation

Training and Awareness: • Regular training programs on ethics, compliance, and sustainability • Cybersecurity training completion tracked as performance metric • Online training on Speak Up Channel procedures • Board training: Including CSRD, AI, and Cybersecurity sessions in 2024

Culture Measurement and Monitoring: • Employee engagement surveys to assess culture effectiveness • Speak Up Channel for reporting concerns and violations • Regular monitoring of policy compliance and culture indicators • Continuous improvement based on feedback and best practices

Stakeholder Integration: Business conduct culture extends to: • Supply chain: Through third-party codes of conduct and ESG questionnaires • Customers: Through service delivery standards and ethical practices • Communities: Through community impact and social responsibility initiatives • Industry: Through participation in industry associations and collaborative initiatives

2024 Performance: • No human rights violations recorded through Speak Up Channel • Continued strengthening of policies and procedures • Enhanced stakeholder engagement processes • Integration of business conduct into sustainability reporting

Amadeus' business conduct policies and corporate culture reflect the company's commitment to maintaining the highest standards of ethics, integrity, and transparency across all operations and relationships.

Business conduct policies and corporate culture

Governance priorities

Being an ethical and fair player within its sphere of influence through maintaining the highest standards in corporate governance and business conduct.

Creating value for clients and partners through innovative and secured solutions to navigate the digital space.

CSR key figures - Governance

Sustainability leadership

Atos SE achieved the following sustainability recognitions:

EcoVadis: 80/100, Top 1%, "Platinum" EcoVadis Medal for its commitment to CSR and sustainability for 5th consecutive year (Sep 2024)

S&P Global Corporate Sustainability Assessment (CSA): 74/100, Top 5%, in the S&P Global Sustainability Yearbook for 12 years in a row (February 5, 2025)

MSCI: 5.5/10, Top 26%, Atos awarded the "A" rating by Morgan Stanley Capital International (MSCI) in its July 2024 update

ISS ESG: 64/100, Top 10%, Remains awarded prime status based on the esg corporate rating letter grade meeting or exceeding the industry-specific prime threshold defined by ISS ESG's industry classification matrix.

CDP: "B" List, Atos awarded "B" score on the CDP Climate Change 2024 List

ESG scores: Atos scoring is excellent in Environmental (82 points), Social (69) and governance (69) as of July 2024

As an international chemical company, we will continue to operate in markets and countries with different requirements and conditions. We are guided by our values and our global standards in order to act responsibly and secure our license to operate. The main guidelines are summarized primarily in our BASF policies on compliance, human rights, labor and social standards and in the Supplier Code of Conduct.

With our CORE values, we combine economic success with the creation of value for the environment and society and stand for respectful interaction with each other and with our customers and partners:

C – creative: We make great products and solutions for our customers. This is why we embrace bold ideas and give them space to grow. We act with optimism and inspire one another.

O – open: We value diversity, in people, opinions and experience. This is why we foster feedback based on honesty, respect and mutual trust. We learn from setbacks.

R – responsible: We value the health and safety of people above all else. We make sustainability part of every decision. We are committed to strict compliance and environmental standards.

E – entrepreneurial: We focus on our customers, as individuals and as a company. We seize opportunities and think ahead. We take ownership and embrace personal accountability.

Corporate Culture and Values: The fundamental values of Bechtle have remained unchanged for decades. They are mentioned in the corporate philosophy, which is part of every employment contract. The four defining values are: • Integrity • Perseverance • Reliability • Enthusiasm

These basic values constitute a central element of our corporate culture. Together with our internal management principles, our Code of Conduct, the Vision 2030 and the Bechtle Sustainability and Climate Protection Strategy 2030, these values support our long-term strategic objectives. They provide all employees and other stakeholders with guidance on efficient and sustainable corporate management and control. Entrepreneurial thinking and behaviour are also a fundamental part of our culture: Employees at Bechtle are given entrepreneurial responsibility at a very early stage – this is both a promise and an obligation.

These values are supported by our brand essence, i.e. what defines the Bechtle brand. Our claim "Zukunftsstark" is at the heart of this, flanked by the attributes: • connected • experienced • entrepreneurial

Management and Organization: The Executive Board regularly consulted the legal and compliance department as well as group controlling and actively used the risk management system.

Risk Management, Compliance, CTO and Marketing are the joint responsibility of the entire Executive Board.

Business conduct policies and corporate culture

Purpose, Vision, Mission and Values:

Our purpose is to build with ambition a sustainable future for generations to come.

Our vision is to be a driving force in shaping a sustainable future for the building industry, delivering tangible value through innovation and agility.

Our Mission is to generate value for our stakeholders through a sustainable growth path, achieved by focusing on product leadership, the pursuit of excellence and operating efficiency. We want to contribute to the development of essential infrastructure and to a more sustainable building industry, minimizing our environmental footprint, promoting circular economy principles, and actively working towards a carbon-neutral future.

Core Values:

• SUSTAINABILITY: We are committed to environmentally responsible practices and strive to minimize our impact on the planet.
• DYNAMISM: We embrace change and are constantly seeking ways to improve and innovate.
• QUALITY: We are dedicated to providing high-quality products and services that meet the highest industry standards.
• VALUE OF PEOPLE: We believe that our people are our greatest asset. We are dedicated to respecting human rights, promoting equal opportunities, and fostering their health, safety, well-being, development, and growth.
• DIVERSITY AND INCLUSION: We value and celebrate the unique perspectives and contributions of all our stakeholder (employees, customers, local communities, unions, etc.).

Governance and Ethics:

• The Board approved the policy for the regulation of lobbying activities and political contribution, the Audit Manual and the Internal Audit Charter, and updated the procedure for handling and disseminating inside information and the Internal Dealing Code.
• Our motto "Concretely Dynamic" embodies our dedication to delivering tangible results and our commitment to innovation and adaptability.
• Social responsibility: the Group emphasizes ethical business practices, workplace safety and positive engagement with local communities.

Business conduct policies and corporate culture

Corporate Culture Foundation

Crayon's corporate culture is built on four core values based on our Nordic heritage:

Business Ethics and Integrity Policies

ISO 37001 Certification

• Global certification for our anti-bribery and corruption management system
• Systematic approach to preventing, detecting and addressing bribery and corruption
• Regular audits and compliance monitoring across 46 countries

Integrity Framework

• Crayon Integrity Handbook outlining expected behaviors for all employees
• Clear guidelines on ethical conduct in business relationships
• Zero tolerance approach to corruption and unethical business practices

Corporate Governance Policies

Governance Framework

Crayon considers good corporate governance to be a prerequisite for value creation, trustworthiness and access to capital. Our governance approach includes:

• Board oversight with independent directors and audit committee
• Clear division of responsibilities between board and executive management
• Regular risk assessment and internal controls
• Transparent reporting and stakeholder communication

Compliance Management

• Compliance with legislation and regulations across Crayon Group
• Norwegian Code of Practice for Corporate Governance adherence
• Securities trading regulations and insider trading policies
• Local regulatory compliance in all 46 operating countries

Business Conduct Implementation

ESG Integration

Business ethics and integrity is identified as one of our key focus areas under the Governance pillar of our ESG strategy, with the vision "To infuse honest and ethical conduct into everything we do."

Risk Management

• Systematic management of risk in all parts of the business
• Enterprise risk management as a governance focus area
• Regular review of risk profiles by the Board of Directors

Employee Standards

• Trust desk for integrity-related concerns
• Whistleblower channel for confidential reporting
• Training and awareness on business ethics and integrity
• Anti-discrimination policies and inclusive workplace practices

International Standards Alignment

United Nations Global Compact

As a signatory since 2020, we embrace the 10 principles covering:

• Human rights support and respect
• Labour standards including freedom of association
• Environmental responsibility
• Anti-corruption including working against all forms of corruption

External Validation

• Ecovadis score: 72% in 2024 (silver medal, top 15% of evaluated companies)
• CDP climate disclosure: B- score in 2024
• Regular ESG platform participation for accountability

Data Privacy and Information Security

Data Protection Policies

• Zero data breaches reported in 2024
• Data privacy and information security as a governance focus area
• Compliance with applicable data protection regulations across operating jurisdictions

Information Security Management

• Systematic approach to protecting customer and business information
• Regular security assessments and improvements
• Employee training on data security and privacy requirements

Responsible AI Governance

Responsible AI is identified as one of our top three strategic priorities for 2025, demonstrating our commitment to ethical technology practices:

• Featured in United Nations Gen AI for Global Goals report for responsible AI practices
• Development of AI governance frameworks
• Ethical considerations in AI solution development and deployment

Stakeholder Trust and Transparency

Our approach to business conduct emphasizes:

• Transparent communication with investors, customers, and stakeholders
• Ethical business relationships with partners and suppliers
• Accountability for actions and decisions
• Continuous improvement in governance and ethical practices

This comprehensive approach to business conduct and corporate culture ensures that Crayon operates with integrity while building trust with all stakeholders across our global operations in 46 countries.

Business ethics are an integral part of conducting business in a global world with many stakeholders. We continuously expand and improve the Group's business ethics programme to reflect our all-important commitment to a high level of business ethics, including our Code of Conduct, a global whistleblower scheme as well as global policies and guidelines on business ethics.

Code of Conduct training to highly exposed employees: 76% in 2024.

2030 target: Code of conduct training to reach 100% of highly exposed employees.

Whistleblower reports: 87 reports in 2024, compared to 90 in 2023, 47 in 2022, and 48 in 2021.

Inclusion score: 4.27 on a scale of 1-5 in 2024, compared to 4.26 in 2023.

Engagement score: 4.13 on a scale of 1-5 in 2024, compared to 4.11 in 2023, 4.08 in 2022, 4.02 in 2021, and 3.93 in 2020.

Furthermore, our inclusion score reached 4.27 on a scale of 1-5, and in the coming years, we will keep focusing on diversity, equity and inclusion, the target being to take the employee experience of inclusion to be among the top-third of "best in class" by 2030.

Our employees are our most valuable resource, as they are critical to Demant's future success. Therefore, it is essential that we are a great company to work for. In driving this agenda, we firmly believe in a strong culture of inclusion and engagement. We want to ensure that everyone can contribute their strengths, regardless of their background.

Digia's corporate governance principles are integrity, accountability, fairness, and transparency. This means that: • The company complies with applicable legislation and regulations. • When organising, planning, managing and running its business operations, the company abides by the applicable professional requirements that have been generally approved by its Board members, who demonstrate due care and responsibility in performing their duties. • The company is prudent in the management of its capital and assets. • The company's policy is to keep all parties in the market actively, openly and equitably informed of its businesses and operations. • The company's management, administration and personnel are subject to the appropriate internal and external audits and supervision.

Quality and information security are an integral part of Digia's reliable operations. During the fiscal period, we completed the recertification of our ISO 9001 quality certificate without any deviations. In addition, we conducted a follow-up assessment of ISO 27001 information security certification covering previously certified business areas without any deviations.

Digia has been awarded an ISO 9001 quality certificate, which covers Digia Finland Ltd and the Group's shared services. Digia has also been awarded an ISO 27001 security certificate, which covers some of Digia's business areas and locations.

Business conduct policies and corporate culture

Ethical standards and governance As an independent public institution owned by the Danish State, DSB has a special obligation to maintain correctness and the highest ethical standards in our day-to-day operations and the way we operate our business.

Legal framework DSB is managed according to company law rules while being subject to public law rules regarding regulatory tasks. The Public Administration Act and the Danish Act on the Parliamentary Ombudsman apply to cases concerning employees and the railway activities carried out in the context of the provision of negotiated traffic.

Corporate culture development DSB's purpose 'A sustainable way forward with room for all of us' guides the corporate culture. We want to create a culture that makes our employees feel valued, recognised for their efforts, feel that they are being listened to and feel committed.

Five promises as guiding principles We support the strategy through our daily actions. We have therefore formulated five promises which are the guiding principles in our day-to-day work:

1. Customers arrive on time
2. A safe, simple and comfortable journey
3. Reasonable fares for everyone
4. DSB is run responsibly and efficiently
5. A more sustainable journey

The promises create coherence in decisions and daily choices, supporting the execution of our strategy and the realisation of our targets.

Workplace values We balance a will to act and create results with a focus on ensuring a sustainable working life where everyone feels included and valued. We are positive-minded, curious and implement changes with enthusiasm to make DSB better.

Transparency and disclosure DSB discloses information as soon as possible to the Danish Business Authority or other relevant parties on material matters concerning the company which may be assumed to be of importance to DSB's future, owner, business partners, creditors, employees or other stakeholders.

Business conduct policies and corporate culture

Corporate Governance Practices

In the context of implementing a structured and adequate corporate governance system, the Company has implemented specific good corporate governance practices, some of which are over and above those provided by the applicable legislation.

Group Code of Conduct

In the context of the good corporate governance fundamental obligation, the Company has drawn up and adopted since 2011 a Code of Conduct, which has been approved by the Company's BoD. The Code of Conduct summarizes the principles according to which every individual, employee or third party involved in the operation of the Group, as well as every collective body thereof, should act within the framework of their duties. For this reason, the Code constitutes a practical guide of the day-to-day tasks of all employees of the Group, but also of third parties who cooperate with it.

The Group Code of Conduct is posted on the Company's website and its revised version is expected to be applied in 2025, capitalizing the experience from its 14 years of validity and taking into account new legislative developments.

Corporate Governance Policies

The Company has adopted corporate governance policies and procedures, which include:

• The Procedure for handling inside information and properly informing the public, in accordance with the provisions of Regulation (EU)) 596/2014, which includes the appropriate mechanisms and methodologies for the assessment of information so that it may qualify as "inside", the prohibition of abusing or attempting to abuse inside information or recommending to another person to proceed to an abuse of inside information, as well as the prohibition of unlawful disclosure.

• The Procedure for the compliance of persons discharging managerial responsibilities, in accordance with the provisions of article 19 of Regulation (EU) 596/2014, which includes a clear and detailed recording of the requisite notification actions, aiming at strengthening transparency regarding the transactions of management officers and of the persons closely associated therewith and identifying potential risks (abuse, market manipulation, etc.)

• The Policy and Procedure on related party transactions, which sets out the mechanisms for identifying, supervising and approving the transactions in question. In the context of the procedure relevant documents and information concerning related parties are kept and updated. The information on the above transactions among associate companies are included in the report accompanying the Company's financial statements, in order to be disclosed to the shareholders. According to the provisions of L. 4548/2018 (article 99- 101), Company transactions of any kind with parties related to it, are permissible only following approval by the BoD or the General Meeting, as per case, unless they fall under the exceptions stated in the law.

• The Policy and Procedure for preventing and managing conflict of interest situations, which provides for designating the way in which conflict of interest may arise, for receiving reports or clarifying doubts in cases of such (actual or potential) conflict and for taking appropriate measures for managing them.

Whistleblowing Policy

In 2024 the Policy for the protection of persons who report breaches of Union law (Whistleblowing) applied, according to the provisions of the L. 4990/2022, which ratifies the EU Directive 2019/1937.

Policy against Violence and Harassment

According to the provisions of L. 4808/2021, which, inter alia, ratify Convention 190 of the International Labor Organization on eliminating violence and harassment in the world of work and proceeds to adopting relevant measures and provisions, the Policy against Violence and Harassment was put into effect at the Group's companies.

Data Protection

In the context of complying with the Personal Data Protection Regulation, the Company has established a Personal Data Protection Office (PDPO), by appointing a Data Protection Officer (DPO) at a Group level, but also in specific subsidiaries. The PDPO has drawn up the appropriate policies and procedures for the effective protection of the privacy of personal data processed by the Group and ensures their implementation and the provision of support in matters of personal data protection.

DPO is administratively reporting to the Chief Executive Officer and, functionally, to the BoD. By utilizing the experience gained from the 6 – year operation of the Personal Data Protection Office, all the policies for the protection of Personal Data are in the final stage of revision and updating.

Conflict of Interest Management

The BoD members have, by law, a duty of care and loyalty towards the Company. They act with integrity and to the Company's interest and safeguard the confidentiality of the non-publicly available information.

The BoD members have to avoid any situation creating a conflict between their personal interests and those of the Company, not to acquire advantages and personal benefits at the expense of the Company, unless they are authorized by the General Meeting of the Company's shareholders, or the BoD. The BoD members must not be in competition with the Company and must avoid any position or activity creating conflict between their private interests and those of the Company, including participating in the share capital (by a percentage > 0.5%), holding posts in the BoD or the Management of competitive companies.

Bylaws (Internal Regulation)

The Company's Bylaws set out, among others, the powers and responsibilities of the principal job positions promoting the adequate separation of powers within the Company. The approved Bylaws have been posted on the Company's website, in accordance with par. 2 of article 14 of L. 4706/2020.

Furthermore, the companies "HELLENIC FUELS AND LUBRICANTS SINGLE-MEMBER INDUSTRIAL AND COMMERCIAL SOCIETE ANONYME" and "HELLENIC PETROLEUM SINGLE-MEMBER SOCIETE ANONYME REFINING, SUPPLY AND SALES OF OIL PRODUCTS AND PETROCHEMICALS", as key Company subsidiaries, adopted bylaws on 15.7.2021 and 20.1.2022, respectively.

Corporate Governance Code Compliance

The Company has adopted the Hellenic Corporate Governance Code (June 2021 edition) of the Hellenic Corporate Governance Council (HCGC). During 2024, the Company complied with the provisions of the above Code, with minor deviations related to:

• Gradual replacement of Board members (the practice is that terms begin and end simultaneously)
• Recovery provisions for executive remuneration (deemed unnecessary given individual performance assessment)
• Board evaluation timing (deferred due to new Board election in June 2024)

Principles of activity The principles of Komerční banka's activities constitute a part of KB's governance. KB shall respect legal regulations, inclusive of international conventions to which it adheres. In its operations, KB shall respect, among others, the following general principles:

■ KB's activities shall be conducted with respect for fundamental human rights and the rights of workers. No discrimination of any kind with regard to employees, job seekers, customers, business partners, or suppliers shall be permitted. ■ KB shall respect intellectual property rights, and special emphasis shall be placed upon the honouring of software product licences. ■ KB shall respect the rules of economic competition in its activities and, especially, in its contacts with the representatives and employees of other banks and financial institutions. ■ KB shall comply with the rules for disclosure of information to the shareholders, investors in financial markets, and the general public. KB shall publish the information regarding its current situation and expected development in a timely manner, in an accessible form, sufficiently, and proportionally. ■ KB shall be active in performing its duties in fighting corruption, money laundering, and the financing of terrorism. ■ KB shall respect the privacy of its customers, business partners, and employees. Therefore, it shall request and use only such information about its customers, business partners, and employees as is needed to serve these, to enhance the quality of KB's services, to manage KB's human resources, and to comply with the obligations specified by legal regulations. ■ KB applies recognised and proven principles and procedures of corporate governance (so-called recognised standards) that it has chosen as well as policies that the controlling company, Société Générale, requires to be applied in its subsidiaries. On a standalone basis, KB applies the Code of Corporate Governance that is based upon principles of the Organisation for Economic Co-operation and Development (OECD) and the Guidelines on internal governance of credit institutions issued by the European Banking Authority (EBA Guidelines). ■ KB shall co-operate with the Czech National Bank and other regulatory bodies responsible for supervising KB's activities. It shall provide correct, complete, current, and transparent information about its activities. ■ KB supports the principle of social responsibility. It shall seek to minimise the impact of its activities on the environment and use natural resources and energy in a conservative manner. KB is governed by international conventions to which it has acceded or which were acceded to by the SG Group. ■ KB shall maintain political neutrality. It shall not back any political party or political movement through donations or any other kind of support. ■ KB shall continuously strive for long-term creation of value for its shareholders.

Moreover, KB respects a range of principles relating to specific areas, including principles regarding business conduct, dealing with clients, the management and control system, and remuneration.

Ethical conduct Only by taking an ethical approach to doing business and providing financial services can Komerční banka hope to maintain and even strengthen its market position over the long term. A fundamental prerequisite to successfully developing the company consists in professional conduct and behaviour on the part of its employees, as exemplified in particular by fostering and preserving direct and open relationships with clients and by fortifying mutual trust. Komerční banka expects all its employees to be fully aware of and committed to their obligation to act in accordance with the ethical standards set forth in its Code of Ethics and to endeavour always to adhere to those standards.

Corporate governance Komerční banka acceded to and upholds all the principal standards of the Code of Corporate Governance of the Czech Republic (2018) issued by the Institute of Administrative Bodies on the basis of international standards of corporate governance, in particular the G20/OECD Principles of Corporate Governance from 2015. Komerční banka's Board of Directors applies and develops the aforementioned principles of corporate governance in a spirit of transparency, accountability, and with a view to the long term, and it translates these best practices into its internal procedures and regulations.

Tax policy Komerční banka ensures that all KB Group companies fully respect the tax rules of all countries wherein the Group operates. Within its tax policy, Komerční banka complies with all applicable reporting obligations. Komerční banka does not encourage or promote tax evasion for itself or its clients and refrains from operations whose main purpose is tax-motivated unless this is consistent with the intention of the law.

Komerční banka strictly respects correct tax procedures and maintains open and transparent relations with tax authorities while guarding its good reputation. KB adheres to the SG Group Tax Code of Conduct, and all of KB's employees are obliged to comply with this Code. Tax policy is internally supervised by the Internal Audit arm. External oversight in relation to Czech tax law is performed by the Specialised Tax Office.

Principles of business activities and dealing with clients Business activities of KB Group companies shall be carried out in a transparent, fair, and disciplined manner in compliance with best market practice and be performed within the global framework of Société Générale Group operating rules.

KB shall not participate in transactions which might lead to the breach of any legal regulation or international agreements. KB does not, however, rule out any transaction a priori for geographical or sector reasons if the related risks are duly assessed and managed.

Clients come first. Client relations management is conducted in accordance with the know-your-customer principle and takes into account all aspects of a relationship so that the client's needs will be met under optimal service and cost conditions and at an appropriate professional level in order to promote the client's loyalty and trust in the Bank while respecting the client's legitimate interests.

The level of a client's knowledge and experience with the products and risks associated with a provided product is taken into account in providing advice.

Our fundamental codes – the Code of Conduct and the Supplier Code of Conduct – are derived from the company's corporate vision. These documents apply without exception to all workers and service providers along the value chain. Their purpose is to ensure compliance with laws, standards and policies throughout the company in order to foster a working environment characterised by integrity, respect and fair and responsible conduct. At the same time, the policy documents serve to embed a strong compliance culture within the company, reinforce our values and encourage employees throughout the value chain to report wrongdoing. In the interests of all stakeholders, violations of our codes are systematically investigated and dealt with. All value chain workers and external stakeholders of the Krones Group have various means to be heard in the event of a violation. Besides direct contact with the company, the main point of contact is the Krones Integrity reporting system.

Code of conduct

Subject matter and objectives: General standards under our corporate vision of »Solutions beyond tomorrow« as part of our sustainable corporate strategy

Environmental, Social and Governance aspects:

• Environmental protection and climate change mitigation
• Respect for human rights including human trafficking, prohibition of forced labour and child labour, anti-discrimination, diversity and inclusion
• Anti-corruption, Fraud prevention, Conflicts of interest, Competition, Confidentiality, Privacy, Dangers of digital media

Scope: Own workforce, suppliers and customers; No specific groups – entire workforce

Responsibility: Corporate Governance, Executive Board

Third-party standards and initiatives:

• Sustainable Development Goals (SDGs)
• United Nations Global Compact (UNGC) principles
• Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises
• International Labour Organization (ILO) core labour standards
• Ethical Trading Initiative (ETI) Base Code
• German Supply Chain Due Diligence Act (LkSG)

Communication: Corporate website; internal communication channels such as: SharePoint, Intranet, Executive Board

Business Conduct and Corporate Culture

Anti-corruption certification: Leonardo achieved the target set for 2024 by obtaining the renewal of ISO 37001:2016 certification in July. Annual renewal/maintenance of the ISO 37001:2016 "Anti-Bribery Management System" certification with maintenance targets for 2025 and 2026.

Leadership recognition: Thanks to its model, Leonardo SpA has reached the highest level of Transparency International's Defence Companies Index on Anti-Corruption and Corporate Transparency (DCI), in addition to having its ISO 37001 certification, the first international standard on anti-corruption management system, confirmed. Leonardo was the first company in the world's top ten in Aerospace, Defence and Security to obtain this certification.

Risk management model: The Group has set out a model of responsible business conduct aimed at preventing, identifying and responding to the risk of corruption. The risk governance model is in line with national and international standards and best practices and is compliant with the Corporate Governance Code for Listed Companies, the Organisational, Management and Control Model and the Group's Anti-Corruption Code.

Training and compliance: Among the key initiatives in 2024, Leonardo continued its efforts to train and raise awareness of trade compliance risks among its employees, involving more than 9,000 employees in more than 15,000 training hours.

In 2012, we adopted the Principles for Sustainable Insurance (PSI) promoted by the United Nations Environment Programme Finance Initiative (UNEPFI), committing to integrate environmental, social, and governance (ESG) issues into our decision-making for the underwriting processes of the Group's insurance operations.

MAPFRE has consistently and decidedly striven from the start to adopt the best corporate governance practices. MAPFRE's good governance practices are oriented toward creating sustained financial and social value over the long-term. The company's objective is to ensure financial stability and safeguard the interests of shareholders, maximizing the positive impact on society as a whole.

MAPFRE is governed by the Recast Text of the Spanish Companies Act and has a series of Institutional, Business and Organizational Principles in place that have been approved by the Board of Directors of MAPFRE S.A., which, together with its Bylaws, the Annual General Meeting's Regulations, and the Board of Directors' Regulations, define the structure, composition and functions of each of its governing bodies and make up the minimum mandatory compliance framework for all of the companies in the MAPFRE Group and their respective governing bodies. In addition, MAPFRE has a group of corporate policies and standards that complement its governance system.

Regarding the Spanish National Securities and Exchange Commission (CNMV) Good Governance Code of Listed Companies as of December 31, 2024, MAPFRE complies fully with 90.62% and fully or partially with 96.87% of the recommendations.

To implement MTG's sustainability strategy all studios must adhere to our policy framework and ensure that all employees participate in training courses for our core policies: the Code of Conduct, Anti-Corruption Policy and Whistleblower Policy.

Policy Framework: Anti-Corruption Policy, Code of Conduct, Whistleblower Policy

During 2025, we will adopt and roll out a Responsible Marketing Policy for the group to address the identified risks and opportunities in connection to our players.

Neste's Code of Conduct provides the framework for our global business operations and is a key element of our compliance program. We are committed to high ethical standards and conduct our business in compliance with applicable laws and regulations. This means acting transparently, responsibly, with integrity and in accordance with our values.

Our culture is based on our values – we care, we have courage, we cooperate. It fosters belonging and encourages conscious decision-making daily. We embrace diversity, equity and inclusion.

Neste's compliance policies, principles and standards are updated regularly and form the basis of our compliance program. They are implemented through communication and training.

Business Conduct and Corporate Culture

Hydro's values of care, courage and collaboration, reflect how the company aims at interacting with its employees, local communities, customers and suppliers.

Care

We act with respect for people and the environment, and place safety at the heart of our operations.

Courage

We break new ground and take measured risks with agility, accountability, and foresight.

Collaboration

We work as partners internally and externally to unite competencies and create win-win opportunities.

Novabase Group, as a company working within the information technologies sector, is guided by solid ethical principles based on integrity, transparency and corporate responsibility.

All Group policies incorporate and demand a high standard of environmental, social and ethical conduct founded on policies, codes and practices that are recognized by the market and aligned with legislation applicable where the company is present.

The Board of Directors annually reviews the policies that are in effect and they are adjusted if need be.

Cabinet Resolution no. 37/2021 of 6 April approved the National Anti-Corruption Strategy 2020-2024, which calls on all the sectors, including the private business sector, to take part in the collective effort to prevent corruption, focused essentially on preventing corruptive phenomena.

According to this strategy, businesses must accept the central nature of their role in promoting and defending ethics in the relationships between the public and private sectors and in the commercial relationships within the private sector, where corruption also takes place.

Adoption and implementation of compliance programs by businesses has been considered a path toward greater engagement by the private sector in combatting corruption and preventing practices that run counter to company standards, that go against the company or use the company by not adopting such programs.

In accordance with the General Corruption Prevention Regime, Novabase has adopted and implemented a Standards Compliance Program in order to prevent, detect and penalize acts of corruption and related offences that are committed against or via the entity. This regime includes:

i. Plan for the Prevention of Risks of Corruption and Related Offences; ii. Code of Conduct; iii. Training Program; and iv. Reporting Channel.

i. Plan for the Prevention of Risks of Corruption and Related Offences

Novabase, aware of the risks, even if they are only potential, has used the Plan for the Prevention of Risks of Corruption and Related Offences to identify them within the specific eco-system where Novabase operates and address them by implementing a business culture that is based on core values of legality, loyalty, trust and ethics. Novabase approved the plan in 2021 and published it on the website.

ii. Code of Conduct

The Code of Conduct describes the behaviours, principles and values that everyone should adopt when performing their professional duties, namely: acting with integrity, adopting ethical and correct behaviour, repudiating all acts of corruption or related offences, taking informed decisions and complying with legal and regulatory obligations.

The Code of Conduct is directed at everyone who works with or for Novabase, namely employees, subcontracted persons, suppliers and partners.

Novabase has implemented a process throughout the Group with the aim of ensur

Business conduct policies and corporate culture

Code of Ethics and cultural foundation

Our approach is rooted in our culture and values, encouraging our employees to always act with integrity. We have a Code of Ethics, which is a fundamental part of the terms of employment for all employees of Novartis globally. It has been developed with our employees and is anchored in behavioral and decision science.

The Code of Ethics sets out commitments that are applicable across our business. It applies to all employees, and we further clarify our expectations through a suite of internal policies and controls.

Comprehensive policy framework

We have established comprehensive policies covering:

Anti-corruption and anti-bribery

Novartis does not tolerate any form of bribery, undue influence and/or corruption. Our Doing Business Ethically and Conflict of Interest policies outline these expectations for all employees. We also clearly set out our standards in our Code of Ethics.

Data and technology ethics

We have an Ethical use of Data & Technology Policy that, together with the AI Risk & Compliance Management Framework, contributes to the responsible use of AI across Novartis.

Trade sanctions and export controls

In early 2024, we launched our updated Trade Sanctions and Export Controls Guideline and implemented associated internal controls.

Anti-fraud commitment

In July 2024, we introduced the Anti-Fraud Policy to reinforce our commitment not to tolerate any form of fraud.

Training and cultural reinforcement

We conduct mandatory annual training for all employees on our Code of Ethics. Internal online tools, such as our Ethical Decision Explorer, have been designed to help employees navigate ethical dilemmas.

In 2024, the annual Code of Ethics training achieved a completion rate of 98.3%.

Regular assessment and improvement

We conduct a global Ethics Survey on a regular basis to measure our progress in embedding our Code across the organization and strengthening our ethical culture. We use insights it provides to drive conversations at global and local levels and take action where needed.

International commitments

We adhere to industry codes and are informed by the United Nations (UN) Convention Against Corruption and the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials. We are a signatory to the UN Global Compact (UNGC).

Ethics and compliance

In Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme.

Data privacy is a key component in our ethical principles, ensuring guardrails are in place to manage and mitigate risks, thus safeguarding our patients and society at large.

We have also adopted a set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. We have initiated building our AI Ethics & Compliance framework, incorporating elements such as principles, requirements and risk assessments, as well as building AI literacy training and capabilities.

You can read more about these principles, in accordance with the Danish Financial Statements Act Section 99d, at: www.novonordisk.com/data-privacy-and-user-rights/data-ethics.html.

Corporate culture foundation

We employ a distinctive, systematic approach known as facilitation – value audits – to ensure that all employees adhere to these Essentials. The foundation of our commitment to supporting the wellbeing and development of our employees is the Novo Nordisk Way; a set of guiding principles constituting the core of our identity and operations.

Our OMV Values "We care | We're curious | We progress" were introduced in 2023 and guide us on our path to a more sustainable future.

Our Code of Conduct was updated to align with our Strategy 2030 and new regulatory requirements, such as supply chain due diligence and sustainability management best practices. We strengthened our existing commitments, particularly related to climate change and human rights, and introduced new ones to address emerging material topics like biodiversity, ecosystems, and the rights and welfare of workers in our value chain. These commitments are fundamental to our operations and continued success.

Every individual deserves a professional, safe, and inclusive work environment, free from discrimination or harassment. Our SpeakUp Channel, which we launched in October 2024, offers our employees and our value chain workers a safe, anonymous way to report work-related grievances through our OMV Integrity Platform. Through this, we aim to identify and rectify work-related misconduct, fostering a culture of transparency, accountability and trust.

Qt Group's Code of Conduct governs various aspects of business conduct and ethical behavior. The Code of Conduct promotes corporate culture among all employees and sets requirements for ethical business practices. It addresses equality, diversity, and anti-discrimination principles, ensuring that all employees are given equal opportunities for personal growth and career development regardless of gender, age, ethnicity, disabilities, nationality, sexual orientation, religious beliefs, political affiliations, marital or economic status, or position within the company. Qt does not tolerate sexual, physical, and psychological violence and harassment or any form of discrimination, abuse, intimidation and workplace bullying.

The Code of Conduct also includes provisions related to business ethics, including principles regarding corruption and bribery prevention. All suspected incidents of misconduct are investigated and actively addressed through Qt's whistleblowing channel, which allows for anonymous reporting of violations.

Discrimination is prevented primarily by educating employees on the Code of Conduct and the whistleblowing channel, and by providing training to managers. The recruitment team and managers are instructed to interview candidates based on each applicant's competence. Managers are responsible for ensuring that employees are treated equally.

Qt also carries out an annual job satisfaction survey and, in 2024, the survey was amended to include a question on whether employees have experienced harassment at the workplace. The survey results are used to create an action plan for addressing areas that require further development.

Randstad's business conduct policies and corporate culture are built on strong foundational values and comprehensive governance frameworks.

Core Values: Established in the company's early days, Randstad's core values represent the foundation of its culture and guide every decision and action:

• To know: Being experts who understand clients, talent, suppliers and business partners
• To serve: Succeeding through excellent service, exceeding core requirements
• To trust: Being respectful, valuing relationships and treating people well
• Striving for perfection: Always seeking to improve and innovate
• Simultaneous promotion of all interests: Seeing the bigger picture and taking social responsibility seriously

Business Principles Framework: All Randstad employees are familiarized with business principles and policies as part of the onboarding program. The company tracks understanding of business principles with a score of 8.4 in 2024 (2023: 8.5).

Human Rights and Ethical Standards: As a signatory to the UN Global Compact, Randstad upholds its Ten Principles on human rights, labor rights, environmental protection, and anti-corruption. The Human Rights Policy defines responsibilities and expectations for employees and external stakeholders regarding human rights issues.

Compliance and Training: All new hires receive information related to the Human Rights Policy in their induction program, and all employees must complete mandatory compliance and refresher training in human rights and business principles.

Equity and Inclusion Culture: Randstad is strongly committed to equity, supported by a global Equity Committee. The company's Equity Policy states its approach to being an inclusive workplace where everyone can thrive while bringing their best selves to work. Six global Business Resource Groups provide spaces for employees to connect, collaborate, and drive equity and belonging.

Integrity in Operations: The company brings integrity and expertise to each engagement through commitment to high standards of business ethics. Client data is handled securely with privacy kept to the forefront, in line with Data Security and Privacy policies.

Continuous Improvement Culture: The culture emphasizes continuous innovation and excellence. The company operates at the intersection of real conversation and technology, using the best that technology has to offer while maintaining focus on human relationships and service excellence.

Social Responsibility: The culture embeds social responsibility as a core principle, with the company seeing its business as needing to benefit society as a whole. This is reflected in the simultaneous promotion of all interests principle and the commitment to contributing positively to global societal needs.

Business conduct policies would be contained in the Sustainability Statement (pages 64-172). However, the company has a Code of Conduct with zero-tolerance approach to illegality. Corporate culture is built on four values: innovation, openness, pragmatism and performance.

Business Conduct Policies and Corporate Culture

Code of Conduct: Our commitment to sustainable healthcare is embodied in the Roche Group Code of Conduct. Roche employees must ensure that all access programmes comply with relevant laws, regulations and industry codes, and that they engage transparently and responsibly with various stakeholders to facilitate access to our products and services.

Ethical Business Practices: We reject all forms of corrupt business behaviour and we are committed to upholding high standards of business ethics and operating with integrity across our business. We rely on our comprehensive compliance management programme to achieve this.

Corporate Culture Values: Corporate culture has been identified as one of our material governance subtopics. Our culture is built around our purpose: doing now what patients need next. We are passionate about transforming patients' lives. We are courageous in both decision and action. And we believe that good business means a better world.

Integrity and Transparency: Our policies offer guidance on ethical collaboration with a range of stakeholder groups, including patients and patient organisations, healthcare professionals, healthcare organisations and government officials. We conduct all work with integrity and transparency so that we do not unduly influence stakeholders.

Collaborative Principles: The Roche Group Code of Conduct, Roche's Position on Partnering with Patient Communities and the Roche Directive on Collaborating with Patient Groups and Patients establish guiding principles that govern the actions of all our employees. These documents embody our commitment to mutual value and respect, integrity, equity, independence and transparency.

Business ethics and corporate culture

We uphold the highest standards of integrity. Our robust compliance and integrity programme is designed to monitor employee behaviour and effectively mitigate compliance and integrity risks. Our Ethics Annual Plan details new developments and preventive measures, including the promotion of ethical behaviour and evaluation of our culture. In line with our corporate strategy, we are also pioneering a vision for sector-wide integrity and social safety in aviation.

Business Conduct and Corporate Culture

Values and Culture

At Saab, we are guided by three core values: Trust, Drive, and Expertise. These values reflect our commitment to reliability, driving change, working efficiently, and continuously learning and collaborating. They are the foundation of our ambition to be a preferred employer, creating a workplace where talent thrives and contributes to the shared success.

UN Global Compact Commitment

Saab is a dedicated member of UN Global Compact since 2011 and pledge to follow its ten principles on human rights, labour, environment and anti-corruption.

Business and Human Rights

Saab recognises the responsibility that comes with developing and selling advanced security and military equipment. Our commitment to respecting human rights involves every stage of our value chain, from sourcing materials and sub-systems, to delivering products and services. This commitment is rooted in our values and aligns with international frameworks, such as the UN Global Compact and the UN Guiding Principles on Business and Human Rights.

Responsible Sales Framework

Saab has implemented a robust Responsible Sales Policy together with a Group-wide framework that guides our due diligence process and ensures responsible decision-making throughout the sales cycle. This framework complements existing national export controls and bridges gaps between international legislations, allowing us to uphold international sustainability standards and national security interests.

Our Responsible Sales framework incorporates a risk screening process for all new business opportunities. High-risk opportunities, identified through a combination of factors, undergo a comprehensive due diligence process. This process involves identifying potential adverse impacts, evaluating potential mitigation strategies and making informed decisions about whether to proceed with the sale.

YOUNITED Corporate Mission

Under its "Salzgitter AG 2030" strategy, the Salzgitter Group has positioned itself to meet the challenges of the future. In our YOUNITED mission statement, we have formulated our understanding of ourselves based on the three pillars of Goals, Paths, Values. A review of the mission in the reporting year produced clear evidence that YOUNITED and its values are instrumental in assisting us to achieve our new strategic goals.

In addition, in the context of an "upgrade" in 2023, ten corporate culture levers were identified that translate our values into specific measures and activities. The four levers of greatest relevance were prioritized for the purpose of evolving our corporate culture: "Focusing on the Customer", "Enabling Agility", "Taking Responsibility" and "Demonstrating and Recognizing Performance".

Compliance Management

The compliance management system and investigated compliance activities are regularly debated at the Supervisory Board plenum's autumn meeting, prepared beforehand by the Audit Committee's in-depth deliberations on this topic. The head of the Group's Legal Department generally reports to the full Supervisory Board and the head of the Group's Compliance Management to the Audit Committee.

Business conduct policies and corporate culture

Corporate Culture as Strategic Asset: Siili has identified its "strong and unique corporate culture" as a positive impact across its entire value chain (upstream, own operations, and downstream) through its double materiality analysis. This corporate culture is supported by corporate governance, policies and processes.

Key focus areas based on double material analysis - GOVERNANCE

• Ensure good governance
• Company culture (including Code of Conduct, compliance and ethics, HR)

Key targets

• 0 security incidents
• 0 Code of Conduct breaches

Code of Conduct and Ethics: Siili's operations are based on responsible and ethical conduct and compliance with laws forming the foundation of the business. The Board of Directors adopts Siili's Code of Conduct steering company activities and detailed instructions based on it.

The Company's operating procedures are based on Siili's Code of Conduct and policies adopted by the Board of Directors. The Code of Conduct includes provisions related to:

• Human rights and non-discrimination
• Equal treatment of all employees
• Ethical business practices
• Compliance with applicable laws and regulations
• Anti-corruption and anti-bribery measures

Corporate Governance Framework: Siili's corporate governance is based on:

• Legislation in force in Finland
• Rules and regulations issued for listed companies by Nasdaq Helsinki
• Finnish Financial Supervisory Authority (FIN-FSA) regulations
• Siili's Articles of Association
• Finnish Corporate Governance Code for listed companies

Governance principles: Siili's governance and control are rooted in:

• Honesty: Transparent and truthful business conduct
• Accountability: Clear responsibility for decisions and actions
• Equality: Fair treatment of all stakeholders
• Transparency: Open communication and reporting

Strategic Culture Development: One of Siili's three strategic priorities is to be a "Community of top talent" which includes:

• Strengthening corporate culture
• Continuous learning opportunities
• Being the most desirable community among digital development professionals
• Focus on employee well-being and development

Culture measurement and monitoring:

• Regular employee satisfaction surveys
• Employee Net Promoter Score (eNPS) target of 65 by 2028
• Employee engagement score target of 75 for 2025
• Recognition: 10th place in Young Professional Attraction Index survey by Academic Work in 2024

Risk management: Siili has established targets for zero security incidents and zero Code of Conduct breaches, demonstrating its commitment to maintaining high standards of business conduct and corporate culture.

The company's culture and business conduct policies will continue to be developed and monitored as part of the sustainability program implementation in 2025.

Safety and integrity guide every action we take – it is our common fundamental commitment.

Our new Purpose-driven culture is clearly driving our organization forward. In 2024 we defined our new culture with teams across the globe, with overall almost 3,000 people contributing to our new Culture and Beliefs program, focusing on three core behaviors – focus, ownership, and collaboration.

A key enabler of success is our new culture featuring our core beliefs and behaviors to support change, helping us to put in place good practices that make Solvay more sustainable, resilient, and cost‑competitive. Through these shared behaviors, we will embrace a mindset of continuous improvement and unlock the potential of every project.

Our three Core Beliefs and their associated Behaviors reflect how we act at Solvay, and are critical to our success as an essential company. In shaping our new Solvay identity, we have created a unique, shared Culture that will help us unlock the potential of every project and deliver on our strategy.

Business Ethics and Corporate Culture

Ethical Conduct Pillar:

Uphold the highest ethical standards in every facet of our business: • Ensure responsible solutions, protect privacy and safeguard solid cybersecurity across all operations • Foster responsible use of AI

Code of Conduct and Ethics:

The Audit and Risk Committee assesses compliance with legislation, official regulations and the company's Code of Conduct.

Values and Culture:

We strongly rely on our core values of openness, trust and diversity at all times. As a concrete example, we continue to leverage the flexible hybrid ways of working co-created with our employees in 2021.

Responsible AI:

We also take highly seriously the ethical considerations embedded in the development and utilization of technology, including AI. During 2024, our annual training for employees included a new module on Responsible AI. We remain committed to keeping ourselves at the forefront of technology adoption, also with respect to our responsible approach.

Foster responsible use of AI is a key commitment under our Ethical conduct pillar.

Business conduct policies and corporate culture

Corporate values and culture At TKH, we develop our technologies in a sustainable and socially responsible manner, using the expertise of our talented people. We conduct our business with honesty, integrity, accountability, and transparency.

Our core values:

We are aspirational

• The commitment to go beyond the norm
• Focused on driving success, with the vision to open new possibilities and unlock sustainable value for stakeholders

We are empowered

• The freedom to make great things happen
• Encourage entrepreneurial mindset, trusting the talent and passion of our people to take initiative and deliver innovation

We are motivated

• The ambition to deliver sustainable success
• More than an innovator, we are a long-term partner motivated by and committed to the best interests of customers, planet, and future generations

We are customer-focused

• The vision to help our customers thrive
• Close partnerships that help deliver technology that helps customers boost efficiency, achieve ambitions, and maintain success

Corporate culture framework

• Decentralized operating model encouraging entrepreneurship and winning culture
• Strong capitalization on new business opportunities
• High-performance execution with short lines of communication
• Management development programs and inspiring environment
• Diverse workforce promoting innovation and excellence

Ethical business conduct

• Commitment to conducting business with honesty and integrity
• Accountability and transparency in all business operations
• Compliance with all relevant legislation and regulations
• Integration of ethical considerations in decision-making processes

Governance and oversight

• Clear governance structure with defined roles and responsibilities
• Regular monitoring of corporate culture and business conduct
• Integration of values into performance management and compensation systems
• Continuous reinforcement of ethical standards throughout the organization

Stakeholder engagement

• Commitment to creating value for all stakeholders including shareholders, employees, customers, and society
• Transparent communication and open dialogue with stakeholders
• Integration of stakeholder interests in strategic planning and decision-making
• Regular assessment of stakeholder satisfaction and engagement

Continuous improvement

• Regular review and reinforcement of corporate values and culture
• Adaptation of business conduct policies to meet evolving standards
• Integration of feedback and learning into cultural development
• Alignment of corporate culture with strategic objectives and sustainability goals

Tryg focuses on managing the company in accordance with the principles of good corporate governance and generally complies with the Danish recommendations prepared by the Committee on Corporate Governance. At tryg.com, Tryg has published its statutory corporate governance report based on the 'comply-or-explain' principle for each individual recommendation.

Tryg has adopted a number of policies describing the relationship between different stakeholders. A number of internal guidelines ensure that the disclosure of price-sensitive information complies with legislation and stock exchange codes of conduct.

The company acknowledges that the taxes paid are a significant contribution to sustainable societies in the countries where business is conducted. Tryg Group is a transparent and responsible tax payer, and the tax governance and key tax compliance focus is ensuring that all taxes paid are fair and in accordance with legislation.

Tax Governance: The tax governance approach is embedded in the Tryg Tax Policy inspired by GRI Sustainability Reporting standard #207 regarding tax. The Tax Policy governs all entities in the Tryg Group, all taxes paid by the Tryg Group and, to the extent possible, also investments made by Tryg Group.

The Tryg Tax Policy is overseen by the Chair of the Tryg Risk Committee and reviewed and approved annually by the Executive Board and the Supervisory Board of Tryg. The approach to tax risk management is aligned with the Tryg Group's risk management and actively monitored to ensure that tax positions are within strategic and business objectives.

Total tax contribution: Tryg Group paid a total tax contribution to tax authorities of DKK 6,041m in 2024. Corporate income tax amounted to DKK 1,488m, corresponding to an effective tax rate for Tryg Group of 24%.

The Group maintains business conduct policies and corporate culture focused on innovation, with a long-term approach, providing stimulating working environments where each individual is respected, promoting team diversity, developing autonomy, encouraging efficient cooperation, and paying particular attention to individual and collective well-being.

Business conduct policies and corporate culture

Purpose of the Company

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

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

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

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

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

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

Multifaceted Performance Framework

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

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

Ethics and Integrity

2024 Results:

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

Governance Structure

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

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

Skills Matrix of Directors:

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

Board Committees:

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

Management Structure

Executive Committee Composition:

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

Corporate Culture and Values

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

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

Management of Purpose Implementation

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

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

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

Management of relationships with suppliers

Amadeus maintains comprehensive supplier management practices to ensure ethical business conduct and sustainability standards throughout its supply chain.

Supplier Landscape:

Key Supplier Categories: • Consulting and marketing services • Hardware vendors (servers and technology equipment) • Software vendors • Data cloud providers

Supplier Concentration: • 50 key vendors account for more than 64% of global spend • Fairly stable vendor concentration providing supply chain stability • Focus on strategic relationships with major suppliers

Supplier Management Framework:

Core Policies and Standards: • Code of Ethics and Business Conduct for Third Parties: Sets out commitments that business partners must make in terms of human rights and environment • Group Purchasing Policy: Establishes procurement principles and procedures • Human Rights Policy: Includes obligations applying directly to business partners • Anti-Bribery and Anti-corruption Policy: Extends to supplier relationships • Environmental Policy: Includes supplier environmental obligations

Due Diligence and Assessment: • ESG questionnaire: Used to assess suppliers on sustainability practices • Risk assessment processes: According to Due Diligence procedures • Assessment criteria: Include ESG practices, human rights, environmental, and anti-corruption aspects • Exclusion capability: Suppliers can be excluded for unsatisfactory ESG responses • Ongoing monitoring: Regular review of supplier performance and compliance

Engagement Mechanisms:

Communication Channels: • Direct contact through Amadeus Corporate Purchasing department • Local teams across offices worldwide for regional supplier management • Amadeus Vendor Portal: Platform for supplier information and communication • Speak Up Channel: Available for suppliers to raise concerns

Engagement Purposes: • Identify candidates for strategic relationships • Facilitate communication with potential vendors • Ensure suppliers meet firm-wide quality, management and safety standards • Comply with Amadeus' sustainability principles • Protect human and labor rights of workers • Support decarbonization of the activity chain

Risk Management and Monitoring:

Third-Party Risk Assessment: • Current tools for conducting due diligence on potential suppliers • Ongoing monitoring and sanctions screening • Human rights risk assessment for high-risk suppliers • Enhanced processes being developed to regularly analyze human rights and environmental issues

Control Measures: • Prevention measures: Through internal rules and policies • Detection procedures: For identifying breaches and non-compliance • Mitigation strategies: Based on risk assessment and due diligence • Regular review: Of supplier performance and compliance

Outcomes and Benefits:

Supplier Standards Improvement: • Enhanced supplier standards including ESG criteria • Increased awareness in the industry about sustainability importance • Identification of potential risks and areas for improvement • Streamlined supplier expectations and requirements

Strategic Relationships: • Development of strategic partnerships with key suppliers • Collaborative approach to sustainability improvements • Supply chain resilience and stability • Innovation and continuous improvement initiatives

Integration with Business Strategy: Supplier management supports: • ESG Ambition: Through supply chain sustainability • Risk management: Integration with Enterprise Risk Management framework • Due diligence: Alignment with human rights and environmental due diligence • Value creation: Through strategic supplier partnerships

Continuous Improvement: Amadeus continues to enhance supplier management through: • Process improvements: Regular review and update of procedures • Technology enhancement: Upgrading systems and tools • Stakeholder engagement: Improving communication and collaboration • Best practices adoption: Learning from industry standards and benchmarks

Supplier relationship management is a critical component of Amadeus' broader governance and sustainability strategy, ensuring that ethical business conduct and environmental responsibility extend throughout the company's value chain.

Management of relationships with suppliers

Atos is committed to delivering high value to its networks of suppliers. The Group has built solid governance, using ethics and compliance to drive organizational processes, and business, thereby securing a sustainable supply chain. Atos has put data protection as a key component of its business culture, for both customers, partners and suppliers.

We work with over 70,000 Tier 1 suppliers worldwide. They provide us with important raw materials, chemicals, investment goods and consumables, and perform a range of services.

BASF considers all direct suppliers of the BASF Group in the business year concerned as Tier 1 suppliers. These are suppliers that provide us with raw materials, investment goods, consumables and services.

We are working to further increase sustainability in our supply chains. For the time frame up to 2030, we are working toward ensuring that, annually, 80% of suppliers who underwent a sustainability evaluation during the reporting period, and who had inadequate results in a prior comparable evaluation, improve their sustainability performance.

Management of relationships with suppliers

Supplier Engagement Program

With our Supplier Engagement Program, we are driving the reduction of scope-3-emissions by collaborating with suppliers to develop measures for a net-zero strategy. We are engaging up to 99% of our key suppliers in climate action initiatives.

Supply Chain Digitalization

Additionally, we are digitizing our procurement processes and systems to make purchasing more efficient and effective for both us and our suppliers.

Partnership Approach

Covestro places great importance on strong relationships with customers, suppliers, and partners across the value chain. Through transparent communication, open dialogue, and industry-specific teams, we build trust and strengthen sustainable partnerships.

7 Strong Business Entities ensure optimal alignment of all activities with market demands and customer needs.

Strategic Partnerships

Circular Economy Collaborations:

• Henkel Partnership: Henkel and Covestro are advancing engineered wood adhesives with bio-based raw materials. Using the mass balance approach, over 60 percent of certain adhesive components are derived from renewable resources.
• Deutsche Telekom Partnership: Covestro collaborated with Deutsche Telekom to produce the housing for the TV box and remote control of their MagentaTV One product using Makrolon® RE, a polycarbonate derived from bio-waste attributed via mass balancing.
• Carlisle Partnership: To enhance energy efficiency in buildings, Covestro supplies bio-circular MDI for insulation panels to Carlisle. With a CO2 reduction potential of up to 99 percent compared to conventional, oil-based products.

Raw Material Partnerships:

• Encina Partnership: Starting at the end of 2027, Encina, a producer of ISCC PLUS-certified circular chemicals, will supply Covestro with chemically recycled raw materials. These materials enable the production of more sustainable products with a reduced carbon footprint.

Innovation Partnerships:

• BioBTX Investment: Strategic partnership supporting the construction of the world's first demonstration plant for innovative recycling technology that can process 20 kilotons of plastic waste annually.
• Team Sonnenwagen Sponsorship: For six years, Covestro has supported the Aachen-based team as the main sponsor, but this collaboration is much more than sponsorship: It is a partnership of equals. The upcoming Sonnenwagen 5 will feature at least 7 Covestro materials.

Management of relationships with suppliers

Crayon maintains systematic approaches to managing supplier relationships as part of our business operations and risk management framework.

Supplier Risk Management

Credit Risk and Control

• Group Treasury oversight of credit risk on a centralized level
• Subsidiaries responsibility for performing credit check and control with suppliers
• Systematic evaluation of counterparties and business relationships
• Enforcement of payment terms and conditions with suppliers

Due Diligence Processes

• Credit assessment of potential suppliers and partners
• Risk assessment of business relationships throughout the value chain
• Regular monitoring of supplier financial stability and compliance
• Balanced solutions approach when disputes arise between parties

Strategic Vendor Relationships

Crayon has established strong strategic relationships with all key global software vendors:

Microsoft Partnership

• Global winner Microsoft Scale Solutions (LSP) Partner of the Year in 2024
• Fifth largest global Microsoft partner
• Strong cloud and service capability recognition
• Deep integration with Microsoft's partner incentive programs

AWS Partnership

• Appointed as AWS Authorized Distributor for European Economic Area (including Switzerland) in 2024
• AWS Authorized Distributor in India since 2019
• AWS EMEA Telco Partner of the Year recognition
• Member of AWS Generative AI Partner Innovation Alliance

Other Key Partnerships

• Broadcom Cloud Commerce Manager (CCM) for VMware Cloud Service Provider (VCSP) partners in Asia Pacific
• Global partnership with Google for Cloud AI and security solutions
• Adobe EMEA Best Growth Partner recognition
• Authorized reseller relationships with various technology providers

Supplier Management Policies

Integrity and Compliance Standards

• ISO 37001 Global certification for anti-bribery and corruption management applied to supplier relationships
• Crayon Integrity Handbook guidelines for ethical business relationships
• Zero tolerance approach to corruption in supplier interactions

ESG Integration in Supplier Relations

As part of our ESG strategy, labor and human rights in the value chain is identified as a focus area, indicating our commitment to:

• Monitoring supplier labor practices
• Ensuring ethical standards throughout our supply chain
• Promoting human rights in business relationships

Operational Supplier Management

Payment and Contract Management

• Efficient management of payment terms with suppliers
• Timely and accurate payment processes
• Working capital optimization in supplier relationships
• Contract compliance monitoring and enforcement

Dispute Resolution

• Dialogue-based approach to resolving supplier disputes
• Balanced solutions that consider all parties' interests
• Escalation processes for complex supplier issues
• Legal compliance in all supplier relationship management

Technology Platform Integration

Cloud-iQ Platform

Integration of supplier services through our proprietary platform:

• Microsoft Azure Marketplace integration
• Adobe VIP Marketplace integration with enhanced self-service features
• Multi-vendor software procurement capabilities
• Automated procurement and management tools

Supply Chain Risk Management

As part of our systematic risk management approach:

• Regular assessment of supplier risk profiles
• Diversification of supplier relationships to reduce dependency
• Contingency planning for critical supplier relationships
• Compliance monitoring across global supplier network

Geographic Supplier Management

Global Supplier Network

• Supplier relationships managed across 46 countries of operation
• Local adaptation of supplier management practices
• Cultural sensitivity in international supplier relationships
• Regulatory compliance with local supplier management requirements

Future Supplier Relationship Development

With labor and human rights in the value chain as a focus area in our five-year ESG strategy (2025-2030), we will:

• Enhance due diligence processes for suppliers
• Strengthen ESG criteria in supplier selection and evaluation
• Improve monitoring of supplier sustainability performance
• Develop more detailed supplier codes of conduct and requirements

Our approach to supplier relationship management reflects our commitment to building trusted, ethical, and sustainable business partnerships while managing risks and ensuring value creation for all stakeholders.

Supplier engagement: We launched a new supplier engagement programme in 2024 to collect primary data and set targets for our suppliers to enhance their environmental performance.

Scope 3 emissions reduction: Demant aims to use less climate-intense transport modes to mitigate climate change. This target resulted in a 16% emissions reduction from transportation for Diagnostics in 2024.

Stability in sourcing and delivering high-quality manufactured goods on time is crucial for us to be able to fulfil the commitments we have made to our customers.

Strong relationships with component suppliers [are part of our input/resources].

Our targets are ambitious, not least the targets for our scope 3 emissions that relate to our value chain, so we depend on close collaboration with our suppliers to reach our goals.

Management of relationships with suppliers

Supplier standards and requirements We demand high standards from all our suppliers and business partners. Not only in relation to the goods and services they provide, but also in relation to how they demonstrate social responsibility and treat their employees.

Contractual ethical guidelines Ethical guidelines have been incorporated into our supplier contracts, which demand that suppliers meet occupational health and safety standards, maintain proper pay and working conditions and respect fundamental human rights, to mention just a few requirements.

Human rights and labor standards Our suppliers must respect fundamental human rights, including:

• The prohibition on the use of child labour
• The prohibition on forced labour or the exploitation of involuntary labour
• Proper pay and working conditions
• Occupational health and safety standards

Strategic supplier relationships To ensure stable operations development, DSB invests in cutting-edge IT systems and maintains close relationships with key suppliers for:

• Rolling stock maintenance and supply of spare parts
• Infrastructure collaboration (e.g., with Banedanmark for traffic information)
• Technology solutions to support customer experience

Supplier performance management DSB works closely with suppliers to ensure delivery of goods and services that support the company's sustainability and operational objectives. This includes collaboration on:

• New electric rolling stock delivery and maintenance
• Workshop construction to sustainable standards (DGNB Gold certification)
• Technology development for improved customer solutions

Climate and environmental requirements We demand ambitious climate reduction targets from suppliers as part of our overall strategy to reduce the climate impact of our suppliers and ensure that emissions from all our activities reach net zero by 2050.

Supplier Code of Conduct

Subject matter and objectives: General standards under our corporate vision of »Solutions beyond tomorrow« as part of our sustainable corporate strategy – expectations regarding the ethical, social and environmental responsibility of business partners

Environmental, Social and Governance aspects:

• Environmental protection and climate change mitigation
• Respect for human rights including human trafficking, prohibition of forced labour and child labour, anti-discrimination, diversity and inclusion
• Anti-corruption, Fraud prevention, Conflicts of interest, Competition, Confidentiality, Privacy

Scope: Suppliers

Responsibility: Corporate Governance, Executive Board

Third-party standards and initiatives:

• Guiding Principles on Business and Human Rights
• International Bill of Human Rights
• UK Modern Slavery Act

Communication: Corporate website; internal communication channels such as: SharePoint, Intranet, Executive Board

supplemented by the Supplier Handbook, including ESG requirements

Our upstream value chain includes sourcing high-quality materials and components from trusted suppliers and working with logistics partners to ensure problem-free transportation and timely delivery. Trust-based working relationships with our business partners, risk management and auditing and security measures help to ensure that we can gather, develop and secure the inputs from our business model and supply chain as resiliently as possible.

Stakeholder Interaction with Suppliers

Suppliers: Regular interaction; discussions and collaboration on ESG topics within the supply chain

Examples: Supplier meetings, Business partner due diligence, Audit formats, Sustainability Assessments, Supplier days

Purpose: Compliance with the Supplier Code of Conduct and protection of human rights; decarbonisation of our supply chain

Supplier Relationship Management

Supplier portfolio: More than 11,000 suppliers with 83% of purchases related to domestic markets

Supply chain strategy: Leonardo has been pursuing its policy of strengthening and improving the supply chain for some years, leveraging a transparent and sustainable partnership relationship with the excellences in its Supply Chain, to give rise to a more innovative, integrated and resilient industrial eco-system.

Supplier development: In addition to the programmes already in place or completed (LEAP, ELITE Leonardo Lounge), the Company has defined a set of principles and rules for the assessment of key suppliers, specifically oriented towards the development and growth of the Supply Chain with a view to long-term sustainability (Leonardo Assessment and Development for Sustainability).

Due diligence: The model provides for the responsible management of the supply chain, through the qualification, selection and management of suppliers, as well as the adoption of a risk analysis tool within the scope of due diligence audits within the process of engagement assignation to sales promoters, and other third parties.

ESG integration: 20% (in value) of major new tenders awarded include ESG criteria/requirements with a target of >70% by 2028.

We expect our suppliers and stakeholders to share this commitment. Our ambition is to establish appropriate guidelines and internal structures to ensure that everyone in the group acts responsibly within the scope of their role. We believe that collaborating with our partners and suppliers, and clearly articulating our expectations and future targets will enable us to achieve a more environmentally responsible approach.

We expect our suppliers and business partners to comply with applicable laws and adhere to equivalent ethical business standards, as outlined in our Supplier Code of Conduct.

Neste Supplier Code of Conduct outlines the basic requirements Neste expects its suppliers and their first tier suppliers, contractors and business partners to adhere to and implement throughout their businesses. Neste aims to include Supplier Code of Conduct in the contract terms for suppliers, contractors and other business partners.

All Neste´s renewable raw material suppliers are subject to rigorous sustainability due diligence, as stated in Neste's Supplier Sustainability Approval Principle. In 2024, we conducted a total of 141 sustainability audits.

In 2024, we internally identified gaps in sustainability due diligence within indirect procurement and prioritized key areas for improvement. This included increasing the use of standardized surveys and incorporating sustainability due diligence clauses in more contracts.

Management of Relationships with Suppliers

Hydro works with more than 30,000 suppliers around the world. The company maintains supplier relationships across its global value chain operations in more than 140 locations in 42 countries.

Management of relationships with suppliers

External Partner Risk Management Framework

Our external partner risk management (EPRM) framework enables risk management in a single, mandatory process and system as part of our integrated assurance system. The framework comprises governance, processes and internal controls, and applies a risk-based approach.

Third Party Code requirements

Our EPRM framework is supported by our Third Party Code, which sets out the standards we oblige external partners to comply with, including human rights and environmental sustainability. Our Third Party Code is consistent with the Pharmaceutical Supply Chain Initiative (PSCI) principles for responsible supply-chain management.

Risk-based assessment approach

The due diligence efforts are applied in proportion to the level of identified risk, which is determined by the probability and severity of potential adverse impacts. We carry out risk assessments and selected audits among external partners in various risk areas including human rights; health, safety and environment; labor rights; information security; anti-bribery and corruption, and; business continuity management.

All suppliers are subject to risk assessments when we engage with them and at a regular frequency thereafter. Suppliers flagged for high risk are subject to an onsite audit by our integrated assurance team.

Anti-bribery requirements

Bribery and corruption risks in our supply chain are addressed by our Anti-Bribery Third Party Guideline and Third Party Code. The Code is an integral part of every supplier contract. Our suppliers are regularly surveyed through audits that we commission from external companies, applying a risk-based approach.

Environmental sustainability integration

Contracts that include environmental sustainability criteria now cover 76% of Scope 3 emissions, which represents an increase of 19 ppts versus the previous year. Our sourcing practices have evolved to reflect environmental sustainability criteria consistently.

Supplier capability building

We have introduced an Environmental Sustainability Supplier Playbook, which is designed to provide comprehensive guidance to our suppliers on transitioning to sustainable business models. The playbook has been shared with more than 1,000 suppliers and integrated into the Pharmaceutical Supply Chain Initiative's (PSCI) standard supplier learning plans.

2024 remediation activities

Overall, we identified 2,615 remediation actions with our suppliers. Of these, 302 were associated with human and labor rights. We mandate external parties who pose a risk classified higher than 'low risk' to complete anti-bribery training.

Supply chain management

Key decarbonisation measures include switching to low-carbon materials and feedstock across our production network, shifting our distribution model to low-emissions transportation and supporting our suppliers in transitioning to renewable energy. To date, more than 1,800 suppliers have already committed to make the switch.

Catalent acquisition

Acquisition of Catalent by Novo Holdings and the related acquisition by Novo Nordisk of three manufacturing sites from Novo Holdings completed. A significant milestone in 2024 was the acquisition of three fill-finish sites previously run by the global contract manufacturing and development organisation Catalent Inc. This move will enable us to expand our manufacturing capacity and provide future optionality and flexibility for our existing supply network.

Our Code of Conduct was updated to align with our Strategy 2030 and new regulatory requirements, such as supply chain due diligence and sustainability management best practices. We strengthened our existing commitments, particularly related to climate change and human rights, and introduced new ones to address emerging material topics like biodiversity, ecosystems, and the rights and welfare of workers in our value chain.

See page 153 for management of relationships with suppliers. We have entered volume agreements and source wind turbines from key suppliers in a timely manner to reduce uncertainty, and we have entered into long-term vessel supply contracts. Our process for vetting new suppliers is thorough, and we have strict credit risk policies in place to manage credit and counterparty risks.

Randstad maintains comprehensive policies and practices for managing relationships with suppliers as part of its business conduct framework.

Sustainable Procurement:

• Share of sustainable procurement spend: 50% (2023: 43%), representing a 16% increase
• This demonstrates the company's commitment to working with suppliers who meet sustainability and ethical standards

Supplier Relationship Principles: As part of the core values framework, Randstad applies its principles of 'to know, to serve, to trust' in supplier relationships:

• To know: Being experts who understand suppliers and business partners, recognizing that details often count the most
• To trust: Being respectful, valuing relationships and treating suppliers well
• Simultaneous promotion of all interests: Ensuring supplier relationships benefit society as a whole

Ethical Standards for Suppliers: As a signatory to the UN Global Compact, Randstad upholds its Ten Principles on human rights, labor rights, environmental protection, and anti-corruption in its supplier relationships. The Human Rights Policy defines expectations for external stakeholders, including suppliers, regarding human rights issues.

Business Principles Application: The company's business principles and policies, which all employees are trained on, guide how Randstad manages supplier relationships. This includes maintaining high standards of business ethics and integrity in all supplier engagements.

Procurement Governance: The increase in sustainable procurement spend from 43% to 50% indicates systematic tracking and management of supplier performance against sustainability criteria. This suggests established processes for evaluating and selecting suppliers based on both commercial and sustainability factors.

Global Standards: Randstad's global presence across 39 markets requires consistent supplier management standards that comply with local regulations while maintaining global ethical standards. The company's commitment to human rights and anti-corruption principles extends to its supply chain relationships.

Long-term Partnership Approach: Consistent with the core value of building life-long relationships based on trust, Randstad appears to take a partnership approach to supplier relationships rather than purely transactional relationships, as evidenced by the focus on sustainable procurement practices.

Management of Relationships with Suppliers

Supplier Code of Conduct: We communicate our expectations to suppliers through the Roche Supplier Code of Conduct. This includes comprehensive requirements for working conditions, equal pay for work of equal value, and workplace standards free of harsh treatment, harassment and discrimination.

Supply Chain Risk Management: We assess suppliers failing to provide equal pay for work of equal value and suppliers failing to provide a workplace free of harsh treatment, harassment and discrimination (e.g. particularly towards migrant workers, but also regarding ethnicity, social origin, religion or political beliefs, age, gender, sexual identity or orientation, disability or HIV status).

Due Diligence Process: We conduct due diligence to ensure risks are mitigated and managed throughout our supply chain. This includes assessment of whether there are reasonable grounds to suspect child labour and other human rights impacts in our value chain.

Human Rights in Supply Chain: Roche upholds human rights principles across our own operations and our value chain. We have policies in place as well as a risk management approach to prevent, detect and mitigate risk of potential infringement on human rights and its adverse impacts.

Supplier Compliance Monitoring: We have established processes to monitor supplier compliance with our Code of Conduct requirements and to address any identified issues or non-compliance situations.

Supplier and procurement practices

In 2024, Schiphol was actively integrating quality of work-related minimum requirements and award criteria in tenders for labour-intensive services at the airport, such as cleaning, security and taxi services. Examples of requirements and criteria are attractive and adequate income, predictable work schedules, and working conditions that contribute to safe, healthy and attractive work. Service companies commit to these principles and are assessed in part on quality of work, with the purpose of increasing the attractiveness of working at Schiphol. We also encourage sustainable cooperation with contractors who support our vision of being a socially responsible employer.

Schiphol Group strives for a prudent overall financial policy aimed at maintaining healthy access to financial markets to (partly) finance its ambitious CAPEX portfolio and refinance its current debt position. A strong and stable credit rating is therefore key.

Management of relationships with suppliers

Strategic supplier relationship management TKH maintains comprehensive supplier management processes focused on sustainability, quality, and long-term partnership development.

Supplier assessment and evaluation

• Comprehensive supplier audits to assess sustainability-related risks, including environmental and social impacts
• 78.2% of copper suppliers assessed with 2024 risk management assessment
• Regular evaluation of supplier performance, compliance, and sustainability practices
• Risk-based approach to supplier selection and ongoing management

Sustainability requirements and certification

• 59.0% of Tier-1 copper suppliers certified by The Copper Mark (target > 80%)
• Requirements for suppliers to meet environmental and social standards
• Support for suppliers in achieving sustainability certifications and compliance
• Integration of sustainability criteria in supplier selection and contracting

Active supplier engagement and development

• Active dialogue with strategic suppliers to improve sustainability of their products and processes
• Collaborative improvement programs and technical assistance
• Long-term partnership development focused on mutual value creation
• Regular communication and feedback on performance and expectations

Supply chain risk management

• Systematic assessment of supply chain risks including environmental, social, and operational factors
• Implementation of risk mitigation strategies and contingency planning
• Diversification of supplier base to ensure security of supply
• Regular monitoring of supplier financial stability and operational capability

Raw material sourcing governance

• Responsible sourcing policies for key raw materials including copper
• Assessment of raw material extraction impacts and sourcing risks
• Support for suppliers in implementing responsible mining and sourcing practices
• Integration of raw material sustainability in procurement decisions

Supplier performance monitoring

• Regular performance reviews and scorecards for key suppliers
• Key performance indicators covering quality, delivery, cost, and sustainability
• Corrective action processes for underperforming suppliers
• Recognition and rewards for exceptional supplier performance

Long-term supplier partnerships

• Strategic partnership agreements with key suppliers
• Joint development programs and innovation collaboration
• Investment in supplier capability development and capacity expansion
• Shared value creation through operational excellence and sustainability improvements

Transparency and compliance

• Clear expectations and requirements communicated to all suppliers
• Regular audit and verification of supplier compliance
• Public reporting on supplier management performance and outcomes
• Integration of supplier management in overall sustainability reporting

Continuous improvement

• Regular review and enhancement of supplier management processes
• Benchmarking against industry best practices
• Integration of lessons learned and feedback into supplier relationship management
• Alignment of supplier management with strategic objectives and sustainability goals

Tryg will develop and expand practices for repairs and the recycling of materials through close collaboration with suppliers. The company maintains focus on working with suppliers to implement circular economy initiatives and reduce environmental impact in the claims handling process.

Supplier relationships are integral to Tryg's sustainability efforts, particularly in achieving the target of reducing CO2e emissions by 6% per average claim through increased repairs and use of reused materials in collaboration with suppliers.

The Group maintains lasting win-win relationships with business partners including Tencent, Google, EPIC, Apple, Nintendo, Sony, Microsoft, Amazon, and Disney. The Group has implemented a supplier selection process based on criteria aligned with Duty of Care and Sapin 2 laws as well as environmental criteria, maintaining a responsible supply chain approach.

Prevention and detection of corruption and bribery

Amadeus has established comprehensive systems and procedures to prevent and detect corruption and bribery as part of its commitment to the highest standards of business conduct and integrity.

Anti-Corruption Policy Framework:

Anti-Bribery & Anti-Corruption Policy: • Comprehensive policy framework addressing all forms of corruption and bribery • Applies to all employees, operations, and business relationships globally • Regular updates to reflect evolving regulations and best practices • Integration with broader Code of Ethics and Business Conduct

Policy Extension to Third Parties: • Code of Ethics and Business Conduct for Third Parties: Extends anti-corruption standards to suppliers, vendors, and business partners • Human Rights Policy: Includes fight against corruption and bribery as commitment • Supply chain requirements: Suppliers must comply with anti-corruption principles

Prevention Measures:

Training and Awareness: • Regular training programs on anti-corruption and bribery prevention • Online training provided to employees on ethics and compliance • Awareness activities integrated into broader sustainability and ethics training • Board-level training: Including governance and compliance topics

Risk Assessment and Due Diligence: • Third-party risk assessment: Comprehensive due diligence on suppliers and business partners • Ongoing monitoring: Regular review of business relationships for corruption risks • Sanctions screening: Systematic screening of third parties • Enhanced due diligence: For high-risk relationships and geographies

Internal Controls: • Segregation of duties: In financial and procurement processes • Authorization procedures: Clear approval requirements for transactions • Documentation requirements: Comprehensive record-keeping standards • Regular audits: Internal and external review of compliance systems

Detection Mechanisms:

Speak Up Channel: • Anonymous reporting: Available through corporate website and intranet • Impartial investigation: Managed by Corporate Compliance and Investigations • Multiple reporting options: Direct investigation, external third party, or public authorities • Employee training: On proper use of reporting channels

Monitoring Systems: • Regular compliance monitoring: Systematic review of anti-corruption controls • Transaction monitoring: Review of financial transactions for suspicious activities • Third-party monitoring: Ongoing assessment of business partner compliance • Risk indicator tracking: Monitoring of corruption risk factors

Investigation and Response:

Investigation Procedures: • Corporate Compliance and Investigations: Designated impartial department • Professional investigation: Following established protocols and procedures • External expertise: Engagement of external law firms or consultants when appropriate • Documentation and reporting: Comprehensive investigation records

Remedial Actions: • Disciplinary measures: Appropriate action depending on violation severity • Legal action: When violations warrant legal proceedings • Process improvements: Learning from incidents to strengthen controls • Stakeholder communication: Appropriate disclosure and reporting

Governance and Oversight:

Board Oversight: • Board of Directors: Ultimate responsibility for anti-corruption policies • Audit Committee: Supervises compliance with anti-corruption policies and internal rules of conduct • Risk management: Integration with Enterprise Risk Management framework

Management Accountability: • Executive responsibility: Clear management accountability for compliance • Regular reporting: To Board and Audit Committee on compliance matters • Performance metrics: Integration of compliance performance into management evaluation

Continuous Improvement:

Regular Review and Update: • Policy updates: Regular review and enhancement of anti-corruption policies • Best practices adoption: Learning from industry standards and regulatory developments • System enhancements: Continuous improvement of detection and prevention systems • Training evolution: Regular update of training content and delivery methods

External Engagement: • Industry collaboration: Participation in anti-corruption initiatives • Regulatory cooperation: Engagement with relevant authorities and regulators • Stakeholder communication: Transparent reporting on anti-corruption efforts

Amadeus' comprehensive approach to preventing and detecting corruption and bribery reflects the company's commitment to maintaining the highest standards of integrity and ethical business conduct across all operations and relationships.

The main guidelines are summarized primarily in our BASF policies on compliance, human rights, labor and social standards and in the Supplier Code of Conduct. With appropriate management and monitoring systems, we want to ensure that we act in line with the applicable laws and uphold our responsibility to the environment and society.

Global compliance systems and codes of conduct are implemented to address risks of violation of social and environmental standards.

Prevention and detection of corruption and bribery

Crayon has implemented comprehensive systems and policies to prevent and detect corruption and bribery across all operations.

ISO 37001 Anti-Bribery Management System

Global Certification

• ISO 37001 Global certification for our anti-bribery and corruption management system
• Systematic approach to preventing, detecting and addressing bribery and corruption
• Regular audits and compliance monitoring across 46 countries
• Continuous improvement of anti-corruption controls and procedures

Management System Components

• Risk assessment procedures for corruption and bribery risks
• Due diligence processes for business partners and third parties
• Training and awareness programs for employees
• Monitoring and review mechanisms
• Incident reporting and investigation procedures

Anti-Corruption Policies and Procedures

Zero Tolerance Policy

• Zero tolerance approach to corruption and unethical business practices
• Clear prohibition of all forms of bribery and corruption
• Strict enforcement of anti-corruption policies across global operations

Crayon Integrity Handbook

• Comprehensive guidance on ethical conduct and anti-corruption requirements
• Clear expectations for employee behavior in business relationships
• Specific guidelines on gifts, entertainment, and business courtesies
• Conflict of interest management procedures

Detection and Reporting Mechanisms

Whistleblower Systems

• Whistleblower channel for confidential reporting of corruption concerns
• Anonymous reporting options to protect whistleblowers
• Trust desk for integrity-related concerns including corruption issues
• Multiple reporting channels accessible to all employees across 46 countries

Internal Controls

• Financial controls designed to detect irregular payments or transactions
• Expense monitoring and approval procedures
• Third-party payment verification and authorization processes
• Regular internal audits focusing on corruption risk areas

Risk Assessment and Due Diligence

Business Partner Screening

• Credit check and control processes for business partners
• Due diligence procedures for suppliers, customers, and intermediaries
• Enhanced due diligence for high-risk relationships and jurisdictions
• Ongoing monitoring of business partner relationships

Geographic Risk Management

• Country-specific risk assessment across 46 operating countries
• Local compliance with anti-corruption laws and regulations
• Cultural adaptation of policies while maintaining global standards

Training and Awareness

Employee Training Programs

• Regular anti-corruption training for all employees
• Role-specific training for employees in high-risk positions
• Leadership training on corruption prevention and ethical leadership
• Awareness campaigns to reinforce anti-corruption culture

Communication and Reinforcement

• Regular communication of anti-corruption policies and expectations
• Case studies and examples to illustrate corruption risks and prevention
• Updates on regulatory changes and best practices

Governance and Oversight

Board and Executive Oversight

• Board oversight of anti-corruption programs and performance
• Executive accountability for corruption prevention
• Regular reporting to board on anti-corruption program effectiveness
• Integration with overall enterprise risk management

ESG Integration

Business ethics and integrity is identified as a key focus area under our Governance pillar, with vision "To infuse honest and ethical conduct into everything we do."

International Standards Compliance

United Nations Global Compact

As a signatory since 2020, we are committed to Principle 10: "Businesses should work against corruption in all its forms, including extortion and bribery."

External Recognition

• Ecovadis score of 72% in 2024, earning silver medal and placing in top 15% of evaluated companies
• Recognition for strong anti-corruption and business ethics practices

Performance Monitoring

Key Performance Indicators

• Zero tolerance incidents tracked and reported
• Training completion rates monitored across all regions
• Whistleblower reports investigated and resolved
• Audit findings addressed and remediated

Continuous Improvement

• Regular review of anti-corruption policies and procedures
• Best practice sharing across global operations
• Lessons learned integration from incidents or near-misses
• External benchmarking against industry standards

Crayon's comprehensive approach to corruption and bribery prevention demonstrates our commitment to conducting business with the highest ethical standards while maintaining the trust of stakeholders, customers, and business partners worldwide.

Digia Plc has a whistleblowing channel for reporting suspected cases of bribery and corruption, market abuse, and violation of Digia's insider guidelines. This channel seeks to promote compliance with good governance in the company's routine activities, and to prevent and detect misconduct. It can be used to report market abuse and the violation of operating principles, regulations and instructions, either confirmed or suspected.

Anyone can make an anonymous report using a form that is available on both Digia's intranet and its public website. All reports are directed to Digia's legal unit and the chair of the Audit Committee of the Board of Directors. All reports will be processed confidentially and professionally in accordance with the Personal Data Act, with regard to both the informant and suspect.

The Audit Committee also reviews reports on notifications received through the Whistleblowing channel.

Anti-Corruption and Bribery Prevention

ISO 37001 certification: Leonardo achieved the target set for 2024 by obtaining the renewal of ISO 37001:2016 certification in July. Target for annual renewal/maintenance through 2026.

Industry leadership: Leonardo was the first company in the world's top ten in Aerospace, Defence and Security to obtain this certification. Thanks to its model, Leonardo SpA has reached the highest level of Transparency International's Defence Companies Index on Anti-Corruption and Corporate Transparency (DCI).

Management system: The Group adopts and updates its organisational, control, procedural and training system to ensure fraud risk monitoring and compliance with any and all anti-corruption laws applicable in the domestic and foreign markets in which it operates.

Risk assessment: The model provides for the responsible management of the supply chain, through the qualification, selection and management of suppliers, as well as the adoption of a risk analysis tool within the scope of due diligence audits within the process of engagement assignation to sales promoters, and other third parties.

Training programs: Among the key initiatives in 2024, Leonardo continued its efforts to train and raise awareness of trade compliance risks among its employees, involving more than 9,000 employees in more than 15,000 training hours.

To implement MTG's sustainability strategy all studios must adhere to our policy framework and ensure that all employees participate in training courses for our core policies: the Code of Conduct, Anti-Corruption Policy and Whistleblower Policy.

Our target within "respectful" is to improve our sustainability governance by reducing our ESG risk rating to 10 by 2025. Base year of target is 2022.

Status in 2024: 15.9 is our ESG risk rating, in December 2024.

We constantly develop our compliance program with special efforts in the defined key focus areas: competition law compliance; anti-corruption; trade sanctions; privacy and anti-money laundering.

In 2024, we revised our Anti-Corruption Principle and Trade Sanctions Principle. As part of our continuous training efforts, we revised and issued an Anti-Corruption e-learning course for 3,700 office workers.

To enhance awareness, we issue regular compliance communication via various channels, including our Compliance Hub channel and global intranet. In 2024, this communication covered topics such as anti-corruption, competition law, trade sanctions and gifts and hospitality.

Prevention and Detection of Corruption and Bribery

Hydro has governance and compliance indicators including:

Combat corruption: Target of zero substantiated claims of corruption

Building a culture of integrity and trust:

• Compliance training and tracking performance on integrity culture index
• Compliance awareness and training

Performance Metrics

Prevention and detection of corruption and bribery

Zero tolerance policy

Novartis does not tolerate any form of bribery, undue influence and/or corruption. Our Doing Business Ethically and Conflict of Interest policies outline these expectations for all employees. We also clearly set out our standards in our Code of Ethics.

Risk management framework

Our Doing Business Ethically policy and its supporting handbooks comprise a risk framework covering four requirements: (a) define clear objectives; (b) identify and assess the risk; (c) act appropriately; and (d) monitor, reconcile and learn.

To support implementation across our organization, the process requirements outlined in the supporting activity handbooks have been embedded within our BeSure system platform. This approach ensures that policy, processes and systems are integrated and can be monitored.

Comprehensive compliance system

Our comprehensive compliance management system is aligned with recognized international standards and best practices, and is designed to prevent, detect and correct systemic misconduct. The objective of our compliance management system is to maintain a culture of integrity designed to promote and enable ethical behavior.

Training and awareness

Our annual global compliance e-learning provides content to enable employees to make the right choices in the course of their work, and to perform with integrity. Global mandatory compliance e-learnings are rolled out to employees, including the ECN, and to the Board of Directors.

External contractors, who are hired through a temporary staff agency and supervised day-to-day by a Novartis employee, are also required to take these trainings. We mandate external parties who pose a risk classified higher than 'low risk' to complete anti-bribery training.

Supply chain anti-bribery measures

Bribery and corruption risks in our supply chain are addressed by our Anti-Bribery Third Party Guideline and Third Party Code. The Code is an integral part of every supplier contract.

Detection and monitoring

We have processes — such as Compliance Risk Assessment and Monitoring, Corporate ERC Assurance reviews, internal auditing, and the grievance mechanism — designed to detect and prevent misconduct.

Industry leadership

Working with Norges Bank Investment Management, we helped develop an anti-bribery reporting standard for the pharmaceuticals industry that was issued in 2022. We report against this standard, which is based on principles such as the UN Global Compact and the OECD Guidelines for Multinational Enterprises.

In Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme.

We have also adopted a set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. We have initiated building our AI Ethics & Compliance framework, incorporating elements such as principles, requirements and risk assessments, as well as building AI literacy training and capabilities.

Qt's Code of Conduct includes provisions related to corruption and bribery prevention. The company has established a whistleblowing channel that allows employees and external parties to report suspected misconduct anonymously. All suspected incidents of misconduct, including corruption or bribery, are investigated and actively addressed.

Reports received via the whistleblowing channel are immediately communicated to the General Counsel, the CFO and the SVP, People & Culture, and the processing of all whistleblower reports starts within seven days of the report being made.

The whistleblowing channel is communicated to employees as part of manager briefings, through the intranet and occupational health care, and through shop stewards, in lectures by work ability consultants and on the Qurious e-learning platform.

Discrimination is prevented primarily by educating employees on the Code of Conduct and providing training to managers. All employees are expected to complete mandatory training on the Code of Conduct, and Qt monitors the completion rate of this training.

Randstad has established comprehensive prevention and detection measures for corruption and bribery as part of its business conduct framework.

UN Global Compact Commitment: As a signatory to the UN Global Compact, Randstad upholds its Ten Principles on human rights, labor rights, environmental protection, and anti-corruption. This commitment forms the foundation of the company's anti-corruption approach.

Business Principles and Training: All Randstad employees are familiarized with business principles and policies as part of the onboarding program, which includes anti-corruption training. All employees must complete mandatory compliance and refresher training covering anti-corruption measures.

Human Rights Policy Integration: The Human Rights Policy defines responsibilities and expectations for employees and external stakeholders regarding ethical conduct, which includes anti-corruption measures. This policy aims to prevent violations in operations, services and business relationships.

High Standards of Business Ethics: Randstad brings integrity and expertise to each engagement through its commitment to high standards of business ethics. This commitment is embedded in the company's core values and guides decision-making across all operations.

Compliance Monitoring: The company tracks understanding of business principles with a score of 8.4 in 2024 (2023: 8.5), indicating systematic monitoring of employee awareness of ethical standards and anti-corruption policies.

Misconduct Reporting System: Randstad maintains a comprehensive misconduct reporting system that can capture corruption-related concerns:

• Total number of misconduct complaints: 465 (2023: 400)
• Misconduct complaints (partially) proven: 70 (2023: 51)
• Score awareness of misconduct reporting: 8.4 (2023: 8.6)

Global Implementation: With operations in 39 markets, Randstad applies consistent anti-corruption standards across all jurisdictions while ensuring compliance with local anti-corruption regulations and requirements.

Supply Chain Standards: The company's commitment to sustainable procurement (50% of procurement spend) includes ethical standards that would encompass anti-corruption requirements for suppliers and business partners.

Continuous Improvement: The company's core value of 'striving for perfection' drives continuous improvement in anti-corruption measures and business ethics practices across all operations and relationships.

Prevention and Detection of Corruption and Bribery

Anti-Corruption Commitment: We reject all forms of corrupt business behaviour and we are committed to upholding high standards of business ethics and operating with integrity across our business. We rely on our comprehensive compliance management programme to achieve this.

Risk Recognition: Corrupt business behaviour, such as bribery, unfair advantages, theft, fraud, embezzlement and misuse of company assets, is persistent in today's interconnected and increasingly competitive world. Given the broad scope of Roche's operations worldwide and the different types of relationships with key stakeholders, there is exposure to the risk of corruption and non-compliance.

Compliance Management Programme: We have established a comprehensive compliance management programme to prevent and detect corruption and bribery across our operations. This programme includes policies, training, monitoring and reporting mechanisms.

Stakeholder Engagement Standards: Our policies offer guidance on ethical collaboration with a range of stakeholder groups, including patients and patient organisations, healthcare professionals, healthcare organisations and government officials, ensuring all interactions comply with anti-corruption standards.

Materiality Recognition: Corruption and bribery has been identified as one of our material governance subtopics through our double materiality assessment, reflecting the importance we place on maintaining high ethical standards.

Anti-Corruption and Bribery

Industry-Leading Programme

Saab has an industry-leading anti-bribery and corruption programme. This is identified as one of the key areas within the "Resilient and safe societies" pillar of Saab's sustainability strategy.

Progress Achievement

Saab has reached its targets within all the topics within the strategic focus area "Resilient and safe societies", which includes the anti-corruption programme.

Compliance and Anti-corruption

Tietoevry has also specified its compliance management system, including the compliance organization, steering model, and annual plan for compliance-related activities. The Group Compliance Officer is responsible for maintaining the whistleblowing channel and coordinating investigations as well as ensuring the effectiveness and functionality of the governance model for compliance work.

Governance of risk and compliance:

At Tietoevry, governance, risk, and compliance (GRC) are closely linked and consistently defined corporate policies and rules with proper controls.

The Audit and Risk Committee assesses compliance with legislation, official regulations and the company's Code of Conduct.

Prevention and detection of corruption and bribery

Anti-corruption commitment TKH is committed to conducting business with the highest standards of integrity and ethical behavior. We have zero tolerance for corruption and bribery in all forms.

Corporate culture and integrity

• Commitment to conducting business with honesty, integrity, accountability, and transparency
• Integration of ethical standards into corporate values and culture
• Clear expectations for all employees regarding ethical business conduct
• Regular reinforcement of anti-corruption principles throughout the organization

Governance and oversight

• Executive Board responsibility for implementing anti-corruption policies and procedures
• Supervisory Board oversight of corruption and bribery prevention measures
• Regular monitoring and assessment of corruption risks across operations
• Integration of anti-corruption considerations in business decision-making processes

Risk assessment and management

• Systematic assessment of corruption and bribery risks in business operations
• Regular review of risk exposure in different markets and business activities
• Implementation of risk mitigation measures and controls
• Monitoring of high-risk transactions and relationships

Training and awareness

• Regular training programs on anti-corruption policies and procedures
• Awareness campaigns promoting ethical business conduct
• Specific training for employees in high-risk positions or locations
• Integration of anti-corruption training in employee onboarding programs

Compliance monitoring and controls

• Implementation of internal controls to prevent and detect corruption
• Regular compliance audits and assessments
• Clear procedures for due diligence on business partners and third parties
• Monitoring of financial transactions and business activities for potential corruption indicators

Reporting and investigation procedures

• Clear channels for reporting suspected corruption or bribery
• Confidential reporting mechanisms protecting whistleblowers
• Professional investigation procedures for reported incidents
• Non-retaliation policies protecting employees who report concerns

Third party management

• Due diligence procedures for business partners, agents, and intermediaries
• Contractual requirements for third parties to comply with anti-corruption standards
• Regular monitoring of third party compliance and performance
• Termination procedures for third parties involved in corrupt practices

Continuous improvement

• Regular review and updating of anti-corruption policies and procedures
• Benchmarking against international anti-corruption best practices and standards
• Integration of lessons learned from incidents or near-misses
• Alignment with evolving regulatory requirements and industry standards

The Group has implemented procedures and controls for prevention and detection of corruption and bribery as part of its compliance with Duty of Care and Sapin 2 laws in its supplier selection processes.

Confirmed incidents of corruption or bribery

Amadeus maintains transparent reporting on incidents of corruption or bribery as part of its commitment to integrity and accountability in business conduct.

2024 Performance: Based on the information available in the report, there were no confirmed incidents of corruption or bribery reported during 2024.

Monitoring and Reporting Framework:

Detection Mechanisms: • Speak Up Channel: Primary mechanism for reporting corruption and bribery concerns • Corporate Compliance and Investigations: Impartial department responsible for investigating reports • Regular monitoring: Systematic review of compliance and control systems • Third-party screening: Ongoing assessment of business partner compliance

Investigation Process: When potential incidents are reported: • Professional investigation following established protocols • Engagement of external expertise when appropriate • Comprehensive documentation and analysis • Determination of violations and appropriate response

Response and Remediation: If incidents were confirmed, Amadeus would: • Take appropriate disciplinary or legal action depending on severity • Implement corrective measures and process improvements • Report to relevant authorities as required • Communicate appropriately with stakeholders

Governance Oversight: • Board of Directors: Ultimate oversight of anti-corruption compliance • Audit Committee: Regular supervision of compliance matters • Management reporting: Regular updates on compliance performance • Risk management: Integration with Enterprise Risk Management framework

Prevention Focus: Amadeus maintains strong emphasis on prevention through: • Comprehensive anti-corruption policies and procedures • Regular training and awareness programs • Robust due diligence and risk assessment processes • Strong internal controls and monitoring systems

Transparency and Communication: • Public reporting: Disclosure of corruption and bribery incidents in sustainability reporting • Stakeholder communication: Transparent communication about compliance performance • Continuous improvement: Learning from industry best practices and regulatory developments

Amadeus' approach to reporting confirmed incidents demonstrates the company's commitment to transparency and accountability in maintaining the highest standards of business conduct and integrity.

Incidents of corruption or bribery

2024 Corruption and Bribery Incident Report

Incident Statistics

Based on our comprehensive anti-corruption management system and reporting mechanisms, no incidents of corruption or bribery were reported or identified in 2024.

Reporting and Detection Systems Performance

Whistleblower and Reporting Channels

• 1 grievance mechanism comprising Trust desk and whistleblower channel
• Zero corruption-related reports received through these channels in 2024
• Anonymous reporting capability maintained and accessible to all employees
• Multiple reporting options available across 46 countries of operation

ISO 37001 System Effectiveness

• Global ISO 37001 certification maintained throughout 2024
• Regular monitoring and auditing conducted as part of certified management system
• No corruption incidents identified through systematic monitoring processes
• Compliance verification through external certification audits

Zero Tolerance Policy Implementation

Prevention Effectiveness

• Zero incidents demonstrates effective prevention measures
• Comprehensive policies successfully implemented across global operations
• Training and awareness programs effective in preventing corruption risks
• Strong internal controls functioning as intended

Risk Management Success

• Systematic risk assessment processes identifying and mitigating corruption risks
• Due diligence procedures for business partners preventing high-risk relationships
• Geographic risk management effective across diverse operating environments
• Cultural adaptation of policies successful while maintaining global standards

Investigation and Resolution Procedures

Investigation Capabilities

• Established investigation procedures ready for deployment if needed
• Trained personnel available to conduct corruption-related investigations
• External support available for complex or serious allegations
• Legal compliance procedures in place for reporting and resolution

Remediation Framework

• Clear remediation procedures established for potential future incidents
• Disciplinary measures defined for policy violations
• System improvement processes to address any identified weaknesses
• Stakeholder communication protocols for transparency and accountability

Continuous Monitoring and Improvement

Ongoing Vigilance

• Regular system reviews to maintain corruption prevention effectiveness
• Best practice updates incorporated into policies and procedures
• Employee feedback considered for system improvements
• External benchmark comparisons conducted

ESG Integration Impact

With business ethics and integrity as a focus area under our Governance pillar, our zero-incident performance reflects:

• Strong governance culture embedded throughout the organization
• Effective integration of anti-corruption measures into daily operations
• Leadership commitment to ethical conduct at all levels
• Stakeholder trust maintained through transparent and ethical business practices

External Validation

Third-Party Recognition

• Ecovadis score of 72% (silver medal, top 15% of companies) includes assessment of anti-corruption practices
• United Nations Global Compact participation demonstrates commitment to anti-corruption principles
• No regulatory issues or external investigations related to corruption

Future Commitment

Maintaining Zero Incidents

Our commitment going forward includes:

• Continued vigilance in corruption prevention and detection
• Ongoing investment in training, systems, and controls
• Regular review and improvement of anti-corruption measures
• Transparent reporting of any future incidents should they occur

The zero incidents of corruption or bribery in 2024 reflects the effectiveness of Crayon's comprehensive anti-corruption program and our commitment to conducting business with the highest ethical standards across all 46 countries of operation.

We monitor and track incidents of corruption or bribery through our compliance program and reporting mechanisms. We have established various channels for reporting suspected violations of our anti-corruption policies.

Detailed information on any incidents of corruption or bribery is provided in the Sustainability data package where applicable, in accordance with our reporting principles.

Incidents of Corruption or Bribery

2024 Performance

There was 1 substantiated claim of corruption in 2024, compared to 0 in 2023 and 0 in 2022. This represents a deviation from Hydro's target of zero substantiated claims of corruption.

Incidents of corruption or bribery

Grievance mechanism results

Analysis of results

In 2024, a total of 1,607 allegations of misconduct were handled by the SpeakUp Office, compared with 2,059 in 2023. Of the total allegations in 2024, 946 (59%) were classified as higher-risk misconduct allegations warranting investigation by a central team.

The report does not provide specific breakdowns of corruption or bribery incidents within these overall misconduct figures, but indicates that all allegations are thoroughly investigated through established processes.

Investigation and response process

Where evidence of misconduct is detected, we take swift and appropriate action. Breaches of the Code of Ethics, policies, guidelines or local laws result in remedial, corrective or disciplinary action up to and including termination of employment.

Higher-risk cases that are substantiated undergo a central remediation process managed in close collaboration with our second line of assurance, the Corporate ERC Assurance team. This creates focus on ensuring that any remediation resulting from investigations is prompt, addresses the root cause, and is subject to follow-up.

Continuous improvement

We continuously evolve our compliance system based on many factors, including insights from internal and external sources and changes in the risk landscape. To measure the maturity and effectiveness of our compliance management system, we conduct regular evaluations of our program across more than 270 leading indicators.

Randstad tracks incidents of corruption and misconduct through its comprehensive reporting and investigation system.

Misconduct Reporting Metrics:

Reporting and Investigation Framework: While the company does not specifically break down corruption vs. other misconduct incidents in the available data, the misconduct reporting system captures all forms of ethical violations including potential corruption and bribery incidents.

Investigation Process: Of the 465 total misconduct complaints received in 2024, 70 were (partially) proven after investigation, representing approximately 15% of reported cases. This indicates a systematic investigation process for all reported misconduct.

Awareness and Prevention: The score awareness of misconduct reporting of 8.4 demonstrates that employees are well-informed about how to report potential misconduct, including corruption and bribery incidents.

Multiple Reporting Channels: Employees can report incidents through:

• Direct reporting to management
• Anonymous reporting through engagement surveys
• Formal misconduct reporting system
• Regular performance review conversations

UN Global Compact Compliance: As a signatory to the UN Global Compact, Randstad is committed to upholding anti-corruption principles and has established systems to monitor and address any violations.

Training and Prevention: All employees receive mandatory compliance training on business principles and anti-corruption measures as part of their induction and through regular refresher training, which helps prevent incidents from occurring.

Global Consistency: The reporting system operates across all 39 markets where Randstad operates, ensuring consistent standards for identifying, reporting, and addressing corruption and misconduct incidents worldwide.

The increase in reported misconduct complaints from 400 to 465 may indicate improved awareness and willingness to report rather than an increase in actual misconduct, as supported by the stable awareness score and systematic investigation process.

Political influence and lobbying activities

Amadeus engages in political influence and lobbying activities as part of its commitment to be a trusted advisor and promote transparent and competitive markets within the travel industry.

Strategic Approach: As part of the "Trusted advisors" strategic line within the "Be a reference for trust and integrity" commitment, Amadeus aims to: • Be a trusted advisor to guide public and private stakeholders in digitalization and transport and tourism policies • Promote more transparent and competitive markets through policy frameworks, association, and strong institutional relations • Maximize ESG reporting transparency and alignment with regulatory frameworks

Engagement Mechanisms:

Direct Government Engagement: • Direct contact with government authorities and regulatory bodies • Participation in related meetings, events and initiatives with regulatory authorities • Industry and Government Affairs Box email for formal communications • Expert feedback provision on travel and technology matters to regulators

Industry Association Participation: • Participation in main industry associations to influence policy development • Collaborative initiatives with industry partners on policy matters • Blog posts, bylines and media engagements to share views on trending industry matters • Multi-stakeholder panels and collaborative forums

Engagement Purposes:

Regulatory and Policy Influence: • Get updates from regulators and other relevant public authorities • Provide expert feedback on travel and technology matters • Influence policy development in digitalization and transport/tourism • Promote fair competition and transparency in travel distribution markets • Advance sustainable travel industry practices

Value Creation Objectives: • Regulatory compliance: Ensure Amadeus operates within legal frameworks across all markets • Risk mitigation: Proactive engagement to address regulatory risks • Market enhancement: Improve efficiency of industry regulation • Innovation support: Promote policies that support technological innovation • Sustainability advancement: Advocate for sustainable travel policies

Governance and Accountability:

Board Oversight: • Board of Directors oversight of political engagement activities • Integration with overall governance and risk management framework • Alignment with company values and sustainability commitments

Policy Integration: • Code of Ethics and Business Conduct: Guides political engagement activities • Anti-Bribery & Anti-Corruption Policy: Ensures ethical conduct in political interactions • Sustainability Policy: Aligns political advocacy with ESG commitments

Outcomes and Impact:

Regulatory Environment: • Enhanced regulatory compliance across global operations • Improved understanding of regulatory requirements and developments • Proactive risk management related to regulatory changes • Contribution to more efficient industry regulation

Industry Development: • Alliance creation to ensure shared value with industry stakeholders • Industry standards improvement through collaborative policy advocacy • Market transparency enhancement through policy framework development • Innovation ecosystem support through favorable policy environments

Stakeholder Relationships: • Government and regulatory relations: Strong relationships with key authorities • Industry partnerships: Collaborative approach to policy advocacy • Stakeholder trust: Transparent and ethical approach to political engagement

Transparency and Reporting: Amadeus maintains transparency in political influence activities through: • Public disclosure of policy positions and advocacy activities • Regular reporting to stakeholders on regulatory engagement • Integration with broader sustainability and governance reporting • Alignment with disclosure requirements and best practices

Amadeus' approach to political influence and lobbying reflects the company's commitment to ethical engagement with policymakers and regulators to promote a more sustainable, transparent, and competitive travel industry while maintaining the highest standards of integrity and compliance.

The Board approved the policy for the regulation of lobbying activities and political contribution during 2024.

Political influence and lobbying activities

Political Activities and Lobbying Approach

Crayon maintains a focused business approach that prioritizes customer service and technology solutions over political engagement or lobbying activities.

Limited Political Engagement

Business Model Focus

As a customer-centric IT consultancy, Crayon's primary focus is on:

• Technology procurement and optimization services
• Cloud services and AI solutions
• Software asset management and compliance
• Professional consulting and managed services

Market Engagement Approach

• Industry participation in technology sector forums and associations
• Customer-focused engagement primarily with private and public sector clients
• Vendor partnership activities with major technology providers like Microsoft, AWS, and Google
• Professional networking within the IT services industry

Regulatory Compliance and Engagement

Regulatory Environment

• Compliance-focused approach to regulatory requirements across 46 countries
• Transparency in regulatory reporting and disclosure obligations
• Adherence to local laws and regulations without active political lobbying

Industry Standards Participation

• United Nations Global Compact signatory since 2020 (principles-based engagement)
• CDP climate disclosure participation (environmental transparency)
• Ecovadis ESG performance assessment participation
• ISO certifications (14001 Environmental, 37001 Anti-bribery)

Corporate Governance and Political Activities

Board Oversight

• Board oversight of all significant external relationships and commitments
• Risk management approach to any political or regulatory engagement
• Transparent governance of external stakeholder relationships

ESG Integration

Corporate governance is identified as a focus area under our Governance pillar, ensuring:

• Appropriate oversight of any political or lobbying activities
• Ethical conduct in all external engagements
• Stakeholder transparency regarding political positions or activities

Business Ethics in Political Context

Anti-Corruption Framework

• ISO 37001 global certification includes provisions regarding political contributions and lobbying
• Zero tolerance for corruption including political corruption
• Clear policies regarding any political contributions or activities

Integrity Standards

• Crayon Integrity Handbook provides guidance on political activities and contributions
• Ethical conduct requirements for all employees in political contexts
• Conflict of interest management including political interests

Stakeholder Engagement vs. Lobbying

Customer Engagement

• Public sector customers engagement focused on technology solutions and services
• Private sector partnerships for business development and innovation
• Industry collaboration for technology advancement and best practices

Partner Ecosystem

• Technology vendor relationships for product development and market access
• Channel partner engagement for business growth and customer service
• Professional association participation for industry knowledge and networking

Disclosure and Transparency

Current Status

Based on available information in this reporting period:

• No significant lobbying activities identified or reported
• No political contributions disclosed
• No dedicated lobbying personnel or budget identified
• Focus remains on business operations and customer service

Future Disclosure Commitment

As part of our commitment to corporate governance and transparency:

• Clear disclosure of any significant political activities should they develop
• Board oversight of any future political engagement strategies
• Stakeholder transparency regarding political positions or lobbying efforts

Industry Representation

Technology Sector Engagement

Crayon's external engagement primarily focuses on:

• Technology industry forums and conferences
• Customer advisory groups and user communities
• Partner ecosystem events and collaboration
• Professional development and certification programs

This approach reflects our commitment to serving customers and advancing technology solutions rather than engaging in political advocacy or lobbying activities. Any future changes to this approach would be subject to appropriate governance oversight and transparent disclosure to stakeholders.

As part of our continuous training efforts, we issued a Competition Compliance & Trade Association e-learning course for a defined group of approximately 120 employees.

We have policies and procedures in place to manage our political influence and lobbying activities in accordance with applicable laws and regulations. Our approach to stakeholder engagement includes appropriate interaction with policymakers and industry associations.

Political influence and lobbying activities

Political engagement approach

We engage in dialogue with policymakers and other external stakeholders on relevant policy topics, including conditions for innovation in the life sciences and expanding access to medicine. Our aim is to represent the Novartis perspective by providing data and insights that enable informed decision-making.

We assess political, legislative and regulatory decisions that have a potential impact on patients and our industry. Furthermore, we participate in policy discussions with partners through various stakeholder dialogues and industry platforms.

Ethical standards and guidelines

The respective Novartis global guideline outlines the ethical standards that we follow in our engagements with policymakers and applies to employees as well as external partners working on our behalf. External partners are also subject to our anti-bribery due-diligence process as per our External Partners Risk Management Framework before they can be engaged.

2024 political engagement expenditure

2024 engagement focus areas

In 2024, our primary focus areas included advocacy efforts supporting various initiatives and policies designed to advance healthcare, drive innovation and enhance accessibility.

United States engagement

In the US, we engaged at both the federal and state levels to shape policies on drug pricing (e.g., the 340B program), the Inflation Reduction Act, and Pharmacy Benefit Managers reform. We emphasized engagement with policymakers, advancement of patient access, and efforts to uphold innovation and intellectual property protections.

European Union engagement

These efforts involved engagement with European Union institutions through EU institutional policymakers with special focus on the Critical Medicines Alliance, Corporate Sustainability Due Diligence Directive, EU Pharmaceutical Legislation, Urban Wastewater Treatment Directive, and the Patent Package. These efforts aimed to strengthen supply chains, advocate for regulatory and intellectual property protections, enhance EU competitiveness, and support environmental goals.

Industry collaboration

Engaging with trade associations also facilitates a collaborative approach to highlighting and solving issues that affect people with disease, and to ensuring an environment conducive to biopharmaceutical innovation. Our focus is on jointly creating solutions that help communities and society tackle the burden of disease.

Randstad engages in political influence and lobbying activities as part of its commitment to shaping fair labor market policies and promoting industry standards.

Social Innovation and Policy Advocacy: As part of the Partner for Talent strategy, Randstad aims to play a leading role in achieving necessary social innovation worldwide by voicing views in influential settings and taking part in dialogue with institutional stakeholders such as governments, policymakers, trade unions and employers' organizations at local and international levels.

Policy Contribution: Through position papers, Randstad contributes to societal debate on topics such as:

• Fair and quality work for all
• The future impact of AI on jobs and work
• Labor market flexibility and regulation
• Social protection for workers

Regulatory Engagement: Randstad continues to be an advocate of enabling a flexible, agile and diverse workforce while promoting fair and quality work for all. The company actively engages with regulators to:

• Improve global employment participation
• Align labor market regulation with the reality of today's world of work
• Provide unrestricted access to social security and skilling
• Remove unjustified restrictions on flexible work arrangements

Industry Leadership: Randstad's founder, Frits Goldschmeding, was the honorary chairman of the ABU (the Dutch industry association for private employment agencies) after serving on its board for many years. This demonstrates the company's long-standing commitment to industry advocacy.

International Standards Promotion: Randstad supports the ratification of ILO Convention 181 on Private Employment Agencies, which defines minimum standards for agency work and recruitment. The World Employment Confederation and ILO are continuously promoting further ratifications, with the aim of achieving 45 ratifications by 2025.

Social Dialogue Support: Randstad is in favor of strong social dialogue (negotiations and consultation between trade unions, employers and government representatives) and collective labor agreements where relevant and institutionalized. This includes active participation in policy discussions to fine-tune and customize employment arrangements.

Transparency and Ethics: All political influence and lobbying activities are conducted in accordance with Randstad's commitment to high standards of business ethics and as a signatory to the UN Global Compact principles on anti-corruption.

Multi-stakeholder Approach: Randstad's approach to political influence involves working with multiple stakeholder groups including governments, trade unions, employer organizations, and international bodies to promote balanced and fair labor market policies that benefit all participants in the labor market.

Political influence and lobbying activities include hosting 'Magnesia Cocktail' networking event in Brussels, engaging with EU Commission Director General, discussions with government representatives from various countries. Further details would be in the Sustainability Statement (pages 64-172).

Payment practices

While the report does not contain a dedicated section specifically labeled as G1-6 Payment practices, payment-related considerations are embedded within Amadeus' broader business conduct and governance framework.

Business Model Context: As a technology company serving the travel industry, Amadeus' payment practices are integral to its business operations: • Air Distribution: Generates revenues mainly from booking fees charged to travel providers • Air IT Solutions: Revenue from transactions processed and other IT services
• Global operations: Payment processes across 100+ offices and multiple currencies • B2B focus: Primarily business-to-business payment relationships

Governance Framework: Payment practices are governed through: • Code of Ethics and Business Conduct: Establishes principles for fair and ethical business practices • Anti-Bribery & Anti-Corruption Policy: Ensures integrity in financial transactions • Internal controls: Segregation of duties, authorization procedures, and documentation requirements • Audit oversight: Regular review of financial processes and controls

Supplier Payment Management: As part of supplier relationship management: • Group Purchasing Policy: Establishes procurement and payment principles • Vendor management: Through Amadeus Vendor Portal and direct engagement • Contract compliance: Ensuring payment terms align with contractual agreements • Risk assessment: Payment practices included in third-party risk evaluation

Internal Controls: • Financial controls: Part of broader internal control framework • Regular audits: Internal and external review of payment processes • Compliance monitoring: Ensuring adherence to payment policies and procedures • Risk management: Integration with Enterprise Risk Management framework

Stakeholder Considerations: Payment practices impact various stakeholders: • Suppliers and vendors: Fair and timely payment practices • Customers: Transparent billing and payment processes • Employees: Payroll and compensation management • Shareholders: Financial performance and cash flow management

Regional Compliance: With global operations across multiple jurisdictions: • Local regulations: Compliance with regional payment and financial regulations • Currency management: Multi-currency payment capabilities • Tax compliance: Alignment with local tax and reporting requirements • Legal frameworks: Adherence to local commercial and payment laws

While specific quantitative metrics on payment practices (such as payment terms, days payable outstanding, or supplier payment performance) are not explicitly detailed in the reviewed sections, these practices are embedded within Amadeus' broader commitment to ethical business conduct, financial integrity, and stakeholder relationship management.

Payment practices

Crayon maintains systematic payment practices as part of our financial management and supplier relationship management across global operations.

Payment Terms Management

Supplier Payment Framework

• Efficient management of payment terms with suppliers as a key business practice
• Timely and accurate payment processes maintained across 46 countries
• Working capital optimization through balanced management of payment terms
• Contract compliance monitoring and enforcement in payment arrangements

Centralized Financial Management

• Group Treasury oversight of payment practices and cash flow management
• Subsidiaries responsibility for local payment execution and supplier relations
• Multi-currency cash pool arrangements to improve payment flexibility across borders
• Systematic payment scheduling and approval processes

Working Capital Management

Payment Optimization Strategy

Working capital management was a key focus area during 2024, with strong improvement delivered:

• Strong improvement in working capital across all four quarters of 2024
• Balanced approach to optimizing both receivables and payables
• Efficient payment terms management with suppliers contributing to improvement

Credit and Risk Management

Payment Risk Assessment

• Credit risk oversight on centralized level through Group Treasury
• Credit check and control performed by subsidiaries for payment counterparties
• Risk assessment of payment terms and supplier financial stability
• Monitoring of overdue payments and collection activities

Dispute Resolution

• Dialogue-based approach to resolving payment disputes
• Balanced solutions considering all parties' interests
• Legal compliance in payment dispute management
• Escalation processes for complex payment issues

Technology Platform Integration

Automated Payment Systems

• Cloud-iQ platform integration for streamlined procurement and payment processes
• Automated payment processing where appropriate
• Digital payment capabilities across multiple currencies and countries
• Integration with vendor payment systems and marketplaces

Payment Practice Governance

Internal Controls

• Systematic approval processes for significant payments
• Segregation of duties in payment authorization and execution
• Regular monitoring of payment terms compliance
• Internal audit coverage of payment processes

ESG Integration

Enterprise risk management as a governance focus area includes:

• Payment risk management as part of overall risk framework
• Ethical payment practices aligned with anti-corruption policies
• Supplier relationship management including fair payment practices

Liquidity and Cash Flow Management

Payment Capability

• Strong cash position of NOK 1,654m at year-end 2024
• Liquidity reserve of NOK 3,518m including undrawn credit facilities
• Reliable payment capability to suppliers and business partners
• Predictable payment scheduling supporting supplier relationships

Financial Facility Management

• NOK 1,200m unsecured bond providing payment flexibility
• NOK 1,500m revolving credit facility for working capital support
• Overdraft facilities (NOK 300m with Danske Bank, EUR 10m with ING)
• Multi-currency capabilities supporting global payment requirements

Regional Payment Practices

Global Standardization

• Consistent payment practices across 46 countries of operation
• Local adaptation to comply with regional payment regulations and customs
• Cultural sensitivity in payment timing and communication practices
• Regulatory compliance with local payment and tax requirements

Supplier Relationship Impact

Payment Terms as Relationship Management

• Fair payment terms supporting long-term supplier relationships
• Transparent payment processes and communication
• Reliable payment execution building trust with business partners
• Flexibility in payment arrangements where appropriate and beneficial

Performance Monitoring

Payment Practice Metrics

• Working capital improvement demonstrates effective payment management
• Supplier satisfaction with payment terms and execution
• Cash flow optimization through efficient payment timing
• Risk mitigation through prudent payment practices

Crayon's payment practices reflect our commitment to maintaining strong supplier relationships, optimizing working capital, and ensuring reliable financial management across our global operations while supporting sustainable business growth.

Details of the payments made by the Group's fully consolidated Spanish companies to providers in the financial years 2024 and 2023 are provided in the following tables.

Information regarding invoices paid in a period of time less than the maximum established in the late payment regulation is shown in the accompanying table.

We are committed to fair payment practices with our suppliers and business partners. Our payment terms and practices are designed to support healthy business relationships and comply with applicable regulations.

Information on our payment practices is provided where required by local regulations and is included in our broader supplier relationship management approach.