Governance

Report page 73

03 Governance

Business Ethics

Interview - Making Ethics a Competitive Advantage Ethical Framework and Business Integrity Risk Management Framework Certifications and Data protection Responsible Value Chain

Report page 74

JADE ZHENG HEAD OF CSR COMMUNICATION SNF CHINA

Making Ethics a Competitive Advantage

WHAT ARE YOUR CURRENT COMMUNICATION PRIORITIES WHEN IT COMES TO SUSTAINABILITY?

Our current priority is localizing Group ESG framework into locally relevant narratives. This means translating carbon neutrality roadmaps and circular-economy milestones into context-relevant stories that resonate with local stakeholders.

Externally, stakeholders, particularly customers and regulators - increasingly focused on Scope 3 emissions, green energy transitions, national green factory certifications, product carbon footprint and local decarbonization roadmaps. Transparency on these topics is now table stakes for commercial conversations. Internally, decarbonization roadmaps and circular-economy pilot projects are generating strong engagement. Meanwhile, employees want clarity on how ESG connects to their daily work, so we emphasize operational linkages: how energy efficiency ties to production goals.

IN YOUR ROLE, YOU SUPPORT BOTH STRATEGIC MESSAGING AND OPERATIONAL TRANSPARENCY. HOW DO YOU MAKE SURE THAT SUSTAINABILITY COMMUNICATION STAYS CONCRETE AND IMPACTFUL?

In China, we integrate strategic messaging with operational transparency through three pillars: concrete storytelling, continuous engagement, and external validation.

Concrete storytelling: Through our local digital channel - SNF WeChat sustainability series, we

Report page 75

consolidate SNF’s brand story with data-backed storytelling - featuring carbon intensity reductions, circular-economy certifications, and verified water-management outcome. Each post transforms abstract ESG concepts into tangible business value for both internal and external stakeholders.

Continuous engagement: Internally, I align closely with sales and site teams to capture frontline market insights and regulatory shifts, ensuring group strategy lands with local relevance. Externally, regular touchpoints with key stakeholders especially key customers - proactively disclosing progress and challenges to build trust through transparency.

External validation: Over the past two years, we have actively pursued sustainability awards through platforms in China such as the French Chamber of Commerce and Industry in China (CCIFC) and Association of International Chemical Manufacturers (AICM). Meanwhile, SNF Taixing site obtained national green factory certification, earned consecutive recognitions from local authorities including "Advanced Environmental Protection Enterprise" "Zero-Waste Factory" and “Advanced Smart Factory” etc.. These recognitions go beyond endorsement - embedding SNF's solutions into industry discourse and leveraging third-party credibility to amplify impact and reinforce internal commitment.

YOU’RE CLOSELY INVOLVED IN INTERNAL ENGAGEMENT. WHAT TOOLS OR FORMATS HAVE BEEN THE MOST EFFECTIVE IN HELPING TEAMS UNDERSTAND AND EMBRACE OUR ESG COMMITMENTS?

Targeted, topic-specific engagement has proven most effective. I prioritize face-to-face, theme-based engagement with each audience. Regular exchange with EHS, operations, sales teams and beyond -ensure ESG resonate with their specific priorities.

In 2025, we organized dedicated workshops on national green factory certification, translating regulatory requirements into actional roadmaps for plant teams. During our annual China sales conference, I delivered a dedicated ESG session -equipping our commercial teams to articulate SNF's sustainability value to clients.

This thematic, audience-specific approach transforms ESG from abstract commitments into relevant, actionable priorities for every function.

WHAT DO YOU SEE AS THE NEXT STEP IN MAKING SUSTAINABILITY MORE VISIBLE - NOT JUST IN REPORTS, BUT IN DAILY DECISIONS AND OPERATIONS? The next step is embedding ESG into decision-making touchpoints through measurable KPIs that mirror real operational conditions. Building on our digital storytelling, stakeholder engagement, and cross-functional collaboration, we will integrate sustainability metrics into procurement scorecards, investment evaluations, and customer proposal templates-making carbon footprint and water stewardship visible factors in daily commercial and operational decisions.

By connecting ESG performance to functional KPIs and team objectives, we transform sustainability from periodic reporting into an embedded business capability. This approach makes ESG visible in regular performance dashboards and individual accountabilities, ensuring every team recognizes sustainability as integral to how we compete and create value.

FINALLY, WHAT DOES IT MEAN FOR YOU TO BE PART OF SNF’S ESG JOURNEY? Being part of SNF's ESG journey means bridging purpose and performance. My role is to craft compelling sustainability narratives that elevate our brand equity, while embedding ESG metrics into strategy and operations.

What drives me is seeing this dual impact in action-when a well-told water-stewardship story strengthens client trust, carbon targets shape procurement choices,. With customer expectations escalating and mandatory legislation on the horizon, I thrive on converting ESG from compliance obligation into competitive edge.

Report page 76

3.1 Ethical Framework

And Business Integrity

Ethics & anti-corruption

Ethical conduct forms the foundation of SNF’s business culture and guides the Group’s relationships with customers, suppliers, partners, and communities. SNF expects all employees and business partners to uphold the principles of integrity, fairness, and transparency in all commercial and operational interactions. The Code of Conduct outlines the standards that apply across the organization and defines the behaviors expected in areas such as ethical decision-making, respect for people, environmental responsibility, and compliance with legal requirements.

SNF maintains a zero-tolerance approach to corruption, bribery, and unethical practices. Employees are required to avoid situations presenting conflicts of interest and must not offer, request, or accept improper advantages. Regular communication, training, and internal controls reinforce these principles and help ensure that ethical expectations are understood and applied consistently across the Group’s global operations.

Fair competition

SNF is committed to competing fairly and transparently in the markets where it operates. The Group adheres to competition laws that prohibit anti-competitive behaviors, such as price-fixing, market sharing, or the abuse of a dominant position. Employees involved in commercial functions receive guidance on compliant practices and are expected to exercise vigilance when engaging with competitors, distributors, or industry associations.

The Group ensures that its commercial policies, marketing practices, and contractual arrangements are consistent with applicable legal requirements. This commitment to fair competition fosters trust with customers and partners while supporting a level playing field within the chemical industry.

Tax transparency

SNF manages its tax responsibilities in accordance with applicable laws and regulations in the countries where it operates. The Group seeks to maintain transparent and responsible tax practices that support long-term business sustainability. Tax contributions are managed in a manner consistent with commercial substance, operational presence, and local economic realities. While SNF does not publish detailed country-by-country tax reporting, the Group respects its fiscal obligations and integrates tax considerations into responsible-governance practices.

Lobbying & political engagement

SNF participates in public policy discussions related to its activities, particularly in areas such as chemical regulations, water management, the circular economy, transportation, and environmental standards. The Group engages in these discussions through recognized professional associations and industry organizations, ensuring that its positions reflect responsible-industry perspectives and align with regulatory expectations.

SNF does not engage in political financing and ensures that interactions with policymakers follow strict ethical standards and comply with relevant legal requirements. The company seeks to contribute constructively to regulatory development while maintaining transparency and integrity in all public-policy engagements.

Report page 77

Whistleblowing, cases & remediation

SNF maintains a confidential whistleblowing system that enables employees, contractors, and external stakeholders to report concerns regarding ethics, compliance, discrimination, safety, environmental issues, or potential legal violations. Reports are handled with discretion and investigated in accordance with formal internal procedures designed to ensure impartiality, confidentiality, and timely resolution.

When issues are substantiated, SNF implements corrective measures that may include disciplinary actions, strengthened controls, additional training, or changes to internal processes. The whistleblowing mechanism reinforces the company’s culture of accountability and provides a secure channel for raising concerns without fear of retaliation.

Litigation

SNF monitors legal and regulatory matters that may result in litigation or sanctions. The Group seeks to resolve issues transparently and responsibly, working with authorities as needed and taking corrective actions when necessary. While litigation is limited, the company maintains robust internal controls and compliance reviews to reduce exposure to regulatory or legal risks. This proactive approach helps protect the company’s reputation and reinforces SNF’s commitment to ethical and compliant conduct.

ESRS G1

GOVERNANCE All staff CSR e-learning course deployment in 2025

TARGET : 80% of employees will have completed a CSR e-learning course by 2026

Report page 78

3.2 Risk Management Framework

Identifying, assessing, and mitigating key risks.

Risk Governance Structure

SNF maintains a structured approach to risk management covering operational, environmental, social, and compliance matters.

Risk oversight is coordinated at the group level and implemented at the site level through defined internal procedures.

Significant risks are reviewed periodically and, where relevant, brought to the attention of senior management.

ESG Risk Identification & Assessment

SNF conducts regular assessments of ESG-related risks through regulatory monitoring, operational reviews, and internal reporting mechanisms.

Risks are evaluated according to their potential impact and likelihood.

The table below presents the main identified risks, associated policies, and monitoring indicators.

Report page 79

ESRS G1

Risk Mapping & Control Measures

PRIORITIES REASONS POLICIES RESULTS KEY INDICATORS

PEOPLE

Non-compliance risk

Official warning or criminal sanction Non-compliance with laws and regulations

Regulatory watch Antitrust and Competition Law Policy Business Partners Code of Conduct Conflict Minerals Policy Internal Code of Conduct Anti-Corruption Policy Conflict of Interest Policy

Site compliance with applicable local, national, and international laws and regulations Employees trained in the Code of Conduct and key policies

% of regulatory compliance EcoVadis assessment % of employees trained in the Code of Conduct and related policies

Workplace accident risk

Inadequate risk assessment Failure to analyze the risk Workplace accidents or occupational illness: - Insufficient knowledge of instructions - Non-compliance with instructions - Procedure not updated Unadapted equipment

Health and Safety Policy Major Accident Prevention Policy Professional risk assessment document; Annual update of professional risk assessment Registration, Evaluation, Authorisation and Restriction of Chemicals Chemical risk assessment Prevention and risk management actions and measures recorded; Initial training of new hires Continuous training for existing staff Audits and preventive inspections Analysis of all workplace accidents regardless of severity Recordings of all accidents and near-misses Analysis of all reported occupational illnesses Task-based risk analysis (work permit / Prevention plan/ safety checklist) Security Policy

Reduce the number of workplace accidents and occupational illnesses Knowledge and skills development and retention Corporate culture and staff engagement Compliance with health and safety instructions Procedures and documentation kept up to date Avoid repeat workplace accidents Avoid repeat occupational illnesses Conditions for the use of chemicals Emergency procedure Safety data sheet for all products used Strengthening of emergency drills Harmonization of facilities and equipment across production sites Ergonomic work environment and workstation

% of corrective actions completed % of initial training completed % of refresher courses completed Weekly publication of safety indicators % of planned audits completed Number of spot audits carried out % of workplace accidents analyzed Frequency rate for workplace accidents with lost time, without lost time and minor accidents WRIR Severity rate for workplace accidents with lost time Number of occupational illnesses reported Psycho-Social Risks Barometer Ecovadis assessment % of training hours dedicated to HSE Employee turnover rate

Human rights / Working conditions

Risk of employing staff under poor and non-compliant working and safety conditions Civil and criminal sanctions Damage to the Group’s image

ENVIRONMENTAL

Regulation

Regulatory non-compliance Loss of operating licenses Formal Notice Complaints

Joining the Global Compact Human Rights Policy Non-Discrimination Policy Recruitment Policy Social Commitment Policy Well-being at Work Policy Health and Safety Policy Responsible Care Policy Anti-Harrasment Policy

Regulatory monitoring Audit and action plan ISO 14001-certified sites

Health & Safety: results for working conditions and workplace safety better than the national average No convictions for non-compliance with laws in terms of human rights and working conditions Chief compliance officer yearly results Low employee turnover rate

Monitoring of regulations compliance Compliance with Environment, Climate, Water, and Biodiversity policies

EcoVadis assessment on this theme Audits carried out in high-risk countries (India, China) % of employees trained in the Code of Conduct and key policies % of employees above living wage in 2024 Number of discrimination incidents Social audit (SMETA) Certification great place to work" Employee turnover rate

Local site reporting % of sites certified ISO 14001 % of regulations compliance

Report page 80

PRIORITIES REASONS POLICIES RESULTS KEY INDICATORS

Industrial risks (SEVESO classification - upper tier or equivalent)

Consumption of resources (water, gas, etc.)

Industrial pollution risk (internal or external)

Climate change risk

Waste accumulation

Major industrial accident that could endanger the safety of surrounding communities and Group employees Chemical and environmental accidents

Resource depletion Shortage of supplies at our production sites Climate change

Chronic or accidental spillage or release of hazardous substances into the environment

No delivery (raw materials and others) or increase in delay Waste accumulation Water restriction Loss of efficiency on cold maintenance Loss of Utilities Risk of injury (flight)

No treatment available or possible Saturated treatment facilities Change of regulations

Accident Prevention Policy Safety Management System, risk analysis, process change management Harmonization of safety measures at Group level Processes at our facilities Periodic drills on internal and external emergency plans with the appropriate state/regional/country services (fire brigade, local, national and environmental authorities, etc.) Internal Operations Plan (intern fire brigade, operation Director, ...) Preventive maintenance of facilities and equipment

Energy saving policy Environmental Policy Sustainability Policy Water Policy Energy Policy Product Stewardship Policy ISO 14001-certified sites Environmental action plan Search for alternatives sources of energy

Environmental Policy Responsible Chemistry Policy Monitoring atmospheric emissions, effluents and waste production Action plan to reduce atmospheric emissions and effluents Installation of water and air treatment units Site containment Polluted water treatment Procedure for handling emergencies New sites designed with the best available technologies Preventive maintenance of facilities and equipment

Climate Change Policy Capacity of storage Supplier management Water and Utilities management Assessment of climate scenarios for each major production site location

No exclusivity, several waste treatment centers Exchange with the different sectors to adapt/change the treatment of waste Regular departures to treatment centers

No industrial accidents at Group level in over thirty years

Audits and inspectionss carried out with local authorities EcoVadis assessment Certificates of compliance for equipment and installations

Improved energy efficiency at production facilities On-site renewable energy production Reduction in the amount of wash water Optimization of utilities Increase in the amount of recycled waste Reduction in the amount of waste per ton produced Reduction in net water consumption

Reduction in the release of hazardous susbstances into water and air per ton produced No accidental pollution

Anticipation of climate change conditions Increased in storage capacity Global climate change study Industrial water management

Water consumption Energy consumption Natural gas consumption Steam consumption Scopes 1&2 indicators Net water intensity Ecovadis assessment % of employees trained on related policies

CO2 emissions Volatile organic compound (VOC) emissions Released water discharges Effluents with high chemical oxygen demand (COD) Effluents containing suspended solids Effluent nitrogen Dust emission Emissions of hazardous solid waste Emissions of non-hazardous solid waste Groundwater monitoring Ecovadis assessment COD reduction % vs. 2016 Certificates of compliance for equipment and installations

Storage capacity Stock update Sites redundancy Water monitoring

Waste management Waste indicator with mode of treatment Waste recovery

CORRUPTION

Responsible procurement Corruption

Risk of violation antitrust laws and anti-corruption rules in the Group's various operating countries Civil and criminal sanctions

Internal Code of Conduct EcoVadis assessment of the ethic, social and environmental performance of global supply chains Internal training for staff liable to face these risks Anti-Corruption Policy Conflic of Interest Policy Whisteblowing Policy Business Partners Code of Conduct Internal Code of Conduct Responsible Purchasing Policy Specific clauses in suppliers’ commercial contracts

No purchases are classified as presenting a serious risk. Our riskiest purchases are chemicals, due to their environmental aspects.

Risk map prepared by Ecovadis and used to assess product suplly and sales chain stakeholders. Ecovadis Assessment on this theme % of suppliers assessed for ESG Number of corruption incident % of our partners that are considered as low, medium and high risk

Report page 81

3.3 Certifications

& Data Protection

Confidentiality & data management

Protecting confidential and sensitive information is essential to maintaining trust with customers, partners, and employees. SNF applies rigorous data management practices to ensure that information on products, processes, employees, and commercial arrangements is handled securely. Access to data is controlled in accordance with defined authorization processes, and employees with data-handling responsibilities receive training to ensure compliance with internal requirements and applicable laws.

SNF continuously strengthens its cybersecurity posture and data-governance systems to minimize risks associated with unauthorized access, data loss, or misuse. Key measures include controlled user-access management based on role authorization, multi-factor authentication for critical systems, regular review of access rights, secure data storage and backup procedures, periodic vulnerability assessments, and employee awareness training on cybersecurity risks. These measures support the safe operation of the business and protect the integrity of both internal and external information.

Management Systems & Certifications

SNF’s management systems are structured around internationally recognized standards that support consistent quality, environmental performance and responsible sourcing across the Group.

The Group’s quality management system is aligned with ISO 9001. This framework structures product design, industrialization, and manufacturing controls to ensure that SNF’s polymers meet stringent quality, safety, and performance requirements. Regular internal audits, corrective

ESRS G1

action plans, and continuous improvement practices help prevent quality incidents and strengthen reliability over time.

Environmental management at SNF is supported by ISO 14001 certification at most major production sites. This standard provides a common structure for identifying and managing ecological aspects, monitoring emissions and discharges, and ensuring compliance with applicable regulations. ISO 14001 underpins the Group’s efforts in pollution prevention, resource efficiency, and reducing the environmental footprint of its operations.

In addition, SNF has implemented a certified mass-balance scheme for renewable feedstocks. Several product lines rely on ISCC+-certified mass balance to integrate bio-based or circular raw materials into existing chemical processes while ensuring full traceability and compliance with strict sustainability criteria throughout the value chain. This certification supports the Group’s sustainable-raw-materials strategy and contributes to the decarbonization of upstream Scope 3 emissions.

More broadly, SNF’s non-financial reporting and sustainability approach are guided by international reference frameworks, including the GRI Standards, the Task Force on Climate-Related Financial Disclosures (TCFD), the UN Global Compact principles, and the OECD and ISO 26000 guidelines. These frameworks inform the design of the Group’s management systems and indicators, but are not used as certification schemes.

Report page 82

3.4 Responsible Value Chain

& Sustainable Procurement

SNF is committed to aligning our procurement processes with our values of sustainability, social responsibility, and environmental stewardship. Our Responsible Purchasing Policy ensures that supplier selection and evaluation meet these principles, fostering a supply chain that reflects our commitment to ethical and sustainable practices.

Evaluation and Supplier Collaboration

We have developed supplier evaluation criteria prioritizing sustainability, social responsibility, and ethical sourcing.

Regular assessments of existing and potential suppliers ensure compliance with these standards, including risk mapping with the EcoVadis IQ platform.

SNF fosters open dialogue with suppliers to address challenges and drive continuous improvement.

Responsible Purchasing

SNF has implemented a Responsible Purchasing policy, based on the Global Compact principles, outlining the ethical and operational expectations we place on our suppliers. This includes:

Human Rights: Respecting international Human Rights Law, ensuring safe working conditions, and adhering to the Fundamental Conventions of the International Labour Organization (ILO).

• Ethical Practices: Combating corruption, forced labor, child labor, discrimination, and anti-competitive practices while maintaining impeccable business ethics.
• Environmental Responsibility: Mitigating environmental impacts and complying with all relevant regulatory requirements.

• Freedom and Equality: Guaranteeing freedom of expression, association, and information security.

SNF’s due diligence process includes supplier risk mapping, prioritization of high-risk regions or activities, and follow-up engagement when gaps are identified. Corrective action plans may be implemented, and progress is monitored through regular dialogue and reassessment.

Training and Awareness

SNF has provided extensive training to its purchasing teams to effectively manage corporate social responsibility (CSR) risks.

• Comprehensive Training: 100% of buyers, recruits, and employees involved in supplier relations have completed training covering responsible purchasing policies, tools, and the EcoVadis Academy.
• Supplier Education: We have also implemented programs to raise supplier awareness of CSR principles and expectations.

Supplier Risk Mapping

The SNF Group makes ESG risk management a top priority across its value chain, particularly with its suppliers.

Indeed, as part of its responsible purchasing strategy, the SNF Group has established a responsible procurement policy for all its partners.

Our policy requires our suppliers to strictly comply with our standards, which are based on the principles of the Global Compact and our code of conduct.

For these reasons, we ask our partners to adhere

Report page 83

to our values regarding environmental, social, and ethical matters.

To ensure this commitment, the SNF Group disseminates its responsible procurement policy to all its partners and has, for several years, conducted ESG risk analyses in collaboration with EcoVadis. This analysis aims to establish a risk mapping of its suppliers based on geographic and country-related risks, the partner’s activity, and the turnover achieved.

In 2025, SNF integrated 2,934 partners into the EcoVadis risk mapping process across 88 countries and 186 industries.

Among them, 157 partners were classified as undefined (non-assessable companies, unknown entities or conglomerates). The remaining 2,786 assessed partners showed the following risk distribution:

• 175 very low
• 1,236 low
• 749 medium low
• 437 medium high
• 164 high
• 25 very high

SNF subsequently engaged with high and very high-risk partners to develop corrective action plans and support improvements in their ESG performance.

Focus on CO₂ Emissions in Procurement

SNF addresses Scope 3 CO2 emissions in our supply chain as a top priority, particularly for raw materials, transportation, and packaging. For raw materials, SNF requests that all suppliers calculate their Scope 3 emissions.

ESRS G1

In 2025, our purchasing teams leveraged analysis software and simulations to collaborate with suppliers on reducing CO2 output. These efforts ensure a holistic approach to minimizing impacts while promoting transparency and sustainability across the supply chain.

RESPONSIBLE PURCHASING 2,943 Number of suppliers assessed for ESG risk mapping

TARGET 2026 : 100% of suppliers with an overall “very high” risk rating will be contacted in 2026

RESPONSIBLE PURCHASING

All Buyers Development of a responsible procurement training program to be deployed to all buyers in 2026.

TARGET 2026 : 80%

of buyers will be trained in responsible procurement by 2026.