Taxation

Tax responsibility is an integral part of our commitment to sustainable and responsible value creation. We act in a way that contributes positively to the communities where we operate, ensuring transparent and ethical tax practices that are aligned with our values, our Code of Conduct, and our Corporate Responsibility strategy. Our tax practices are transparent and ethical and are supported by a well-defined governance framework.

Our approach in this area applies to all entities within the Group’s scope of consolidation and is based on four fundamental principles: (i) responsibility and governance, (ii) principles of action, (iii) transparency, and (iv) stakeholder engagement.

i) Responsibility and governance

Tax management is the responsibility of the Corporate Tax Department¹, supported by two Shared Service Centres – one in Portugal and the other in Poland – and by local Tax Departments or Divisions in the countries where the Group’s Companies operate. These structures ensure compliance with tax reporting and filing obligations and are directly connected to the corporate structure. The tax position of the Group’s Companies is shared with the Audit Committee each quarter and may cover legislative, administrative and/or judicial matters. The Tax Department reports to the Chief Financial Officer, who is a member of the Jerónimo Martins Group’s Managing Committee and who reports directly to the Chief Executive Officer.

Our approach to taxation is based on compliance with the laws and regulations applicable in the countries where we operate, and we therefore consider our appetite for tax risk to be low. Nevertheless, with support from our expert teams and tax advisers, we recognise that different interpretations of tax legislation may sometimes arise between the parties involved. In such cases, we act in the best interests of our stakeholders and may adopt a different interpretation from that of the tax authorities where we consider our position to be duly supported by the law in force.

We have established a set of mechanisms to ensure compliance with our tax obligations, promote the implementation of responsible tax practices, and align our approach with our business principles, sustainability strategy and Code of Conduct, including:

• Tax Control Framework – designed to assess and mitigate tax risks across multiple jurisdictions and tax categories, while ensuring effective coordination between local finance departments and business teams. It also ensures the preparation of tax compliance reports and the implementation of continuous training for teams;

• Whistleblowing and reporting channels² – we provide dedicated channels through which internal and external stakeholders can report ethical or compliance concerns, including tax-related matters, notably the Ethics Committee, Employee Assistance Services, Company Customer Support Services, and the Customer Ombudsman;

• Tax technology – we are actively involved in financial (tax) technology through a global approach focused on five pillars: insights, data, automation, risk management, and future readiness. One of the initiatives we highlight is the development of VAT application solutions.

ii) Principles of action

We maintain a physical presence in all jurisdictions in which we operate and follow internationally recognised standards and best practices, including the guidelines issued by the Organisation for Economic Co-operation and Development (OECD), the Base Erosion and Profit Shifting (BEPS) Action Plan, and relevant guidance from the European Union (EU).

Our tax decision-making and compliance process is based on responsible principles and practices, including:

• we do not operate nor transfer funds to jurisdictions included on the EU blacklist of non-cooperative countries for tax purposes or to low-tax jurisdictions listed in Ordinance No. 150/2004 of 13 February, published by the Portuguese Government, which approves the list of countries, territories and regions with clearly more favourable tax regimes;

• we pay taxes on profits in line with the jurisdictions in which the value is effectively created in the normal course of business;

• our transfer pricing policy complies with the arm’s length principle, meaning that all transactions are priced in accordance with market conditions;

• we do not use opaque corporate structures or low-tax jurisdictions to conceal relevant information from the tax authorities;

• we ensure transparency regarding our ownership structure;

• we do not engage in arrangements with employees, customers or suppliers that are solely intended to generate tax benefits inconsistent with the underlying intent of applicable tax rules;

• we ensure full compliance with tax obligations in accordance with local laws and regulations;

• we ensure a reasonable and responsible interpretation of tax legislation, aligned with both the letter and the spirit of the law;

• we request tax rulings only to confirm the appropriate tax treatment, supported by full and transparent disclosure of all relevant facts;

• we use tax incentives where they are aligned with operational objectives, explicitly provided for in law and available on a non-discriminatory basis to all entities that meet the established requirements.

iii) Transparency

Our compliance with tax obligations in the countries where we operate reflects our contribution to the economic and social development of the surrounding communities. We recognise that our total tax contribution, along with that of other private sector operators, makes a relevant contribution to the United Nations Sustainable Development Goals (SDGs).

While the fulfilment of tax obligations is a legal requirement, it merits particular attention given the diversity of taxes, contributions and charges applicable in the various countries in which our subsidiary companies operate. It is therefore essential to ensure that our teams are properly trained and equipped to recognise and address these jurisdiction-specific requirements.

In 2025, the Group paid a total of 1,079 million euros in profits tax, employer social security contributions, taxes and charges on the sale of goods and property ownership, and non-deductible VAT in certain countries, representing an increase of 6.4% compared to 2024. In addition to these taxes and contributions, we are also subject to a range of other taxes and levies arising from the type of activities we carry out in each country, which are often incorporated into the cost of the products or services obtained.

In 2025, our Effective Tax Rate (ETR)³ amounted to 28.0%, an increase of 4 p.p. compared to 2024, largely as a result of the temporary deferral of certain costs for tax deduction purposes.

As regards tax incentives – understood as measures introduced by governments to stimulate investment, promote economic growth, or stimulate business and economic transformation and modernisation – we adopt a selective approach, prioritising incentives that apply to activities that contribute to positive development in the areas in which we operate. The main tax incentives applied are listed in the table below:

iv) Stakeholder engagement

We seek to maintain relationships based on mutual trust and candid, transparent dialogue with tax authorities. Aligned with this commitment, we promote constructive dialogue with governments on tax matters and participate in legislative consultations that contribute to the development of sustainable tax frameworks. This approach also applies to other stakeholders, including investors, customers, business partners, employees and local communities.

Regarding our interactions with tax authorities, we provide the information requested, ensuring efficient compliance. Key areas of interaction include:

• In Portugal: Participation in the Large Taxpayers Forum and in sector working groups focused on tax transparency and the implementation of Pillar Two⁴. Regular communication with the Large Taxpayers Unit of the Portuguese Tax and Customs Authority (Autoridade Tributária e Aduaneira).

• In Poland: A constructive, transparent and compliance-focused relationship with the Polish tax authorities (Krajowa Administracja Skarbowa). Regular communication through official channels, email and telephone, ensuring timely and accurate responses to requests.

• In Colombia: Transparent, compliance-oriented communication and open channels with the Colombian Tax Administration (Dirección de Impuestos y Aduanas Nacionales – DIAN). Classified as a large taxpayer, our Colombian subsidiary is responsible for a range of tax obligations, both direct and on behalf of third parties.

• In Slovakia: A constructive, transparent and compliance-focused relationship with the Slovak tax authorities (Finančná správa Slovenskej republiky), with regular communication primarily through electronic channels, ensuring timely and accurate responses to requests.

As part of our approach, we also participate in several forums and working groups, such as:

• EuroCommerce, the European association representing the retail and wholesale sector, through participation in working groups dedicated to tax matters at European Union level, as well as through meetings with members of the European Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD);

• Local retail sector organisations on tax policy and compliance standards, including the Portuguese Association of Distribution Companies (APED), the Polish Organisation of Trade and Distribution (POHiD), and the Colombian National Merchants Federation (Fenalco). These organisations represent the sector in their interactions with the governments of the respective countries;

• National business associations representing the private sector, such as the Confederation of Portuguese Businesses (CIP) and Business Roundtable Portugal (BRP), through participation in working groups focused on taxation and identifying opportunities to simplify administrative and regulatory processes.

¹ More information about this department is provided in point 21 “Organisational Charts Concerning the Allocation of Powers Between the Various Corporate Boards, Committees and/or Departments Within the Company, Including Information on Delegating Powers, Particularly as Regards the Delegation of the Company’s Daily Management”.

² More information about these channels is provided in “Mechanisms and channels for raising concerns”.

³ The effective tax rate is determined based on the estimated tax for the year, without considering corrections to estimates from previous years and deferred taxes.

⁴ Pillar II is part of the GloBE (Global Anti Base Erosion Rules) set of rules designed under the OECD/G20 Inclusive Framework to ensure that large multinational groups bear a minimum level of taxation in all jurisdictions where they operate. In this context, Directive (EU) 2022/2523 was approved and subsequently transposed into Portuguese law through Law No. 41/2024, which establishes the application of a global minimum tax rate of 15%, ensuring adequate effective taxation in each jurisdiction.