Substantial Contribution and Do No Significant Harm - Jerónimo Martins Annual Report 2025

Once the eligible activities had been identified, the technical criteria defined in the Delegated Acts were analysed to determine whether those activities:

substantially contribute to each of the six environmental objectives defined in the Taxonomy;
do no significant harm to any of the other environmental objectives;

This analysis was performed for the countries in which we have operations. It is important to highlight that for the majority of our investments in Colombia and Morocco, it is not possible to verify alignment since the criteria defined in the delegated acts are applicable only to European jurisdictions, and there is no guidance from the European Commission for the application of these criteria to non-European countries. We also found that the technical criteria defined for some activities (e.g., 7.7 “Acquisition and ownership of buildings”) may not be applicable to the weather conditions in some regions of those countries. In light of these two factors, the alignment assessment regarding approximately 17% of the Group’s CapEx becomes unfeasible.

Some of the criteria analysed for the six activities identified as eligible are highlighted below.

Activity 6.5. Transport by motorbikes, passenger cars and light-duty vehicles

**Activity 6.5. Transport by motorbikes, passenger cars and light-duty vehicles**
Criteria	Description (non-exhaustive)	Alignment analysis
SC	Category M1 and N1 vehicles comply with the following requirements: By 31 December 2025, specific CO₂ emissions of less than 50g CO₂/km (light-duty vehicles with zero or low emissions). From 1 January 2026, specific CO₂ emissions are zero.	In 2025, we contracted service vehicle leasing in Portugal, Poland, Colombia and Slovakia. For the vehicles where it was possible to collect all the necessary technical information, we assessed and validated their alignment with the technical criteria. For the cases where all the information relating to their characteristics could not be obtained, we chose to consider these investments as not being aligned.
DNSH	Climate change adaptation: Appendix A.	See Appendix A application analysis below.
DNSH	Transition to a circular economy: Category M1 and N1 vehicles are both of the following: reusable or recyclable to a minimum of 85% by weight; reusable or recoverable to a minimum of 95% by weight; Measures are in place to manage waste both in the use phase (maintenance) and the end-of-life of the fleet, including through reuse and recycling of batteries and components, in accordance with the waste hierarchy.	Despite our commitments to promoting a circular economy and waste management, we were unable to collect the evidence needed to ensure that 85% (by weight) of vehicles are reused or recycled and 95% (by weight) are reusable or recovered. As such, we opted to adopt a conservative approach and acknowledge that we are not aligned with these DNSH criteria.
DNSH	Pollution prevention and control: The vehicles comply with the requirements of the light-duty emission type-approval with regard to emissions (Euro VI standard); The vehicles comply with the established emission thresholds for clean light-duty vehicles; For road vehicles of categories M and N, tyres comply with external rolling noise requirements in the highest populated class and with the rolling resistance coefficient influencing the vehicle energy efficiency in the highest two populated energy efficiency classes.	The data collected to check compliance with the requirements are still insufficient to guarantee their alignment.

Activity 7.2. Renovation of existing buildings

**Activity 7.2. Renovation of existing buildings**
Criteria	Description (non-exhaustive)	Alignment analysis
SC	Complies with the applicable requirements for major renovations or leads to a reduction in PED (primary energy demand) – the calculated amount of energy needed to satisfy the energy demand associated with a building’s typical consumption (in kWh/m²) – by at least 30%.	In 2025, we carried out major renovations in some of our stores in Portugal, Poland and Colombia. These comply with the major renovations classification criteria in these countries.
DNSH	Climate change adaptation: Appendix A.	See Appendix A application analysis below.
DNSH	The sustainable use and protection of water and marine resources: Appendix E.	The data collected to check compliance with the requirements linked to Appendix E are still insufficient to guarantee their alignment.
DNSH	Transition to a circular economy: At least 70% (by weight) of the non-hazardous construction and demolition waste generated on the construction site is prepared for reuse, recycling and other material recovery. Building designs and construction techniques support circularity (ISO 20887).	Despite our commitments to promoting a circular economy and waste management, we were unable to collect the evidence needed to ensure that 70% of non-hazardous construction and demolition waste on the construction sites is prepared for reuse, recycling or other material recovery. As such, we opted to adopt a conservative approach and acknowledge that we are not aligned with these DNSH criteria.
DNSH	Pollution prevention and control: Appendix C. Building components and materials (paints and varnishes, ceiling tiles, floor coverings, including adhesives and sealants, internal insulation and interior surface treatments, particularly for treating damp and mould) that may come into contact with occupiers emit less than 0.06 mg of formaldehyde per m³ of materials or components.	We regularly carry out indoor air quality assessments, namely for major retail and services buildings. In addition, during construction or maintenance works, we adopt appropriate measures to reduce noise, dust and pollutant emissions. However, the assessment carried out does not allow us to validate all the requirements set out in these criteria, namely those indicated in Appendix C. As such, we have chosen to consider that there is no alignment.

Activity 7.3. Installation, maintenance and repair of energy efficiency equipment

**Activity 7.3. Installation, maintenance and repair of energy efficiency equipment**
Criteria	Description (non-exhaustive)	Alignment analysis
SC	Complies with minimum requirements set for individual components and systems in the national measures and, where applicable, are rated in the highest two populated classes of energy efficiency in which a significative number of products are available.	It was not possible to obtain all the information regarding the technical characteristics, so we chose to consider these investments as not aligned.
DNSH	Climate change adaptation: Appendix A.	See Appendix A application analysis below.
DNSH	Pollution prevention and control: Appendix C. In case of addition of thermal insulation to an existing building envelope, a building survey is carried out in accordance with national law.	The data collected to verify compliance with the associated requirements is still insufficient to ensure their alignment..

Activity 7.5. Installation, maintenance and repair of instruments and devices for measuring, regulating and monitoring the energy performance of buildings

**Activity 7.5. Installation, maintenance and repair of instruments and devices for measuring, regulating and monitoring the energy performance of buildings**
Criteria	Description (non-exhaustive)	Alignment analysis
SC	Consists of the installation, maintenance and repair of energy management systems.	In 2025, we invested in the installation of energy management systems in our buildings.
DNSH	Climate change adaptation: Appendix A.	See Appendix A application analysis below.

Activity 7.6. Installation, maintenance and repair of renewable energy technologies

**Activity 7.6. Installation, maintenance and repair of renewable energy technologies**
Criteria	Description (non-exhaustive)	Alignment analysis
SC	Consists of the installation, maintenance and repair of solar photovoltaic systems where they are installed on-site as technical building systems.	In 2025, we invested in the installation of photovoltaic solar equipment in our buildings.
DNSH	Climate change adaptation: Appendix A.	See Appendix A application analysis below.

Activity 7.7. Acquisition and ownership of buildings

**Activity 7.7. Acquisition and ownership of buildings**
Criteria	Description (non-exhaustive)	Alignment analysis
SC	For buildings built after 31 December 2020, the buildings meet the SC of activity 7.1: Primary energy demand (PED) is at least 10% lower than the threshold set in the requirements for nearly zero-energy building (NZEB), the standard building concept used by EU countries as a value for minimum building requirements. For buildings built before 31 December 2020, the buildings have at least an Energy Performance Certificate (EPC) nor equivalent Class A or are within the top 15% of the national or regional building stock expressed as operational PED percentage, comparing the performance of the relevant asset with the performance of the national or regional building stock built before 31 December 2020.	For buildings built after 31 December 2020: In Portugal, within our exercise of ownership rights, we made investments in 2025 that comply with the SC requirements (validated by the existence of type A+, A and B energy certificates). In Poland, the criteria are certified using a methodology equivalent to the energy certificate, based on the energy performance of the stores. In Slovakia, we made investments in 2025 that fulfil the SC requirements (validated by the existence of energy certificates type A). In Colombia, we were unable to validate alignment due to the absence of guidance for transposing the technical criteria required by the applicable European Directives and Regulations. For buildings built before 31 December 2020: In Portugal, according to official databases, the top 15% of the national building stock built before 31 December 2020 have an EPC of B or higher, and so we have considered that the investments in buildings built before 2020 with an EPC of at least B, comply with the substantial contribution criterion; In Poland, according to the Polish Central Energy Performance Register, the value of the PED of the top 15% of non-residential buildings corresponds to 45 kWh (m²/year), and so we have considered that the investment in buildings built before 2020 with an EPC below that value, comply with the substantial contribution criterion; In Colombia, we were unable to validate alignment due to the absence of guidance for transposing the technical criteria required by the applicable European Directives and Regulations.
DNSH	Climate change adaptation: Appendix A.	See Appendix A application analysis below.

Application of Appendix A “Climate change adaptation”

We adopted the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) in 2020, now integrated into the International Financial Reporting Standards (IFRS), in response to the increasing challenge that climate change poses to society and businesses and the complexity of assessing the associated financial risks and opportunities. In 2025, we continued to update our assessment of climate-related risks and opportunities. The purpose of this assessment is to enhance supply chain resilience, reduce carbon emissions, and identify potential business opportunities in primary production and the use of low-carbon technologies.

Under this Appendix in particular, we included in our analysis more than 6,400 facilities (stores, distribution centres, head‑office buildings, central kitchens and industrial units) in Poland, Portugal and Colombia, as well as a high‑level assessment for the Czech Republic and Slovakia, having examined all risks set out in Table II of Appendix A of the Taxonomy. The risks identified and presented in this report already correspond to the outcome of that assessment and screening process. We prioritised the physical risks most common in our operations and the opportunities associated with the energy transition and the use of natural or low‑GWP refrigerant.

The assumptions made in this assessment – namely the risks assessed, climate scenarios used and time horizons considered – as well as the main conclusions and measures to be adopted are described in “Managing climate-related risks and opportunities”.

CapEx - Capital expenditure

The funds a company invests in acquiring, upgrading and maintaining physical assets such as property, plants, buildings, technology and equipment. These investments are often made to fuel growth, increase efficiency or launch new initiatives.

Global Warming Potential (GWP)

A measure used to compare the impact of different greenhouse gases on global warming over a specific period, usually 100 years. GWP indicates how much heat a greenhouse gas traps in the atmosphere compared to carbon dioxide (CO₂), which has a GWP of 1. For example, methane (CH₄) has a GWP of about 27-30 over 100 years, meaning it is 27-30 times more effective at trapping heat than carbon dioxide.

Refrigeration gases

Refrigeration gases, or refrigerants, are substances used in refrigeration and air conditioning systems to transfer heat and create cooling. These gases change phases from liquid to gas and back, absorbing and releasing heat in the process. Common types of refrigeration gases include chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), hydrofluorocarbons (HFCs), and natural refrigerants.

Task Force on Climate-Related Financial Disclosures (TCFD)

The Financial Stability Board (FSB), an international body tasked with monitoring and advising the global financial system, established the TCFD. The TCFD's mandate is to develop recommendations for corporate disclosures that enable investors, lenders and insurers to accurately assess and price climate-related financial risks.

Taxonomy

In the context of sustainable finances, the classification system identifying activities, assets, and/or project categories that deliver on key climate, green, social or sustainable objectives with reference to identified thresholds and/or targets.

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Annual Report 2025

Substantial Contribution (SC) and Do No Significant Harm (DNSH)