SOMFY // 2022 Annual Report

03 NON-FINANCIAL STATEMENT

METHODOLOGY FOR ASSESSING ACTIVITIES IN LIGHT OF TECHNICAL EVALUATION CRITERIA

Methodology for assessing generic DNSH and minimum safeguards criteria

Regarding minimum safeguards , the report of the Platform on Sustainable Finance published in October 2022 defined a set of minimum safeguards in the areas of human rights, corruption, competition law and taxation, and specified the criteria for non-alignment as well as the steps of due diligence to be carried out for alignment to be considered. Companies are now expected to demonstrate compliance with the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, and the International Bill of Human Rights. To meet the minimum human rights safeguards, the Group relies on the following: – signing of the United Nations Global Compact in 2021, thereby committing to ten universally accepted principles on human rights, labour standards, environment and fight against corruption; – a Group Code of Ethics specifying that each employee is expected to act in strict compliance with laws and regulations, to demonstrate loyalty and honesty and to behave with exemplary professional ethics (see paragraph Promoting the Group’s Code of Ethics in this chapter). In addition, the Code of Ethics and Business Conduct sets out the Group’s policy on business ethics and individual behaviour; – with regard to corruption, the Group has put in place a comprehensive system, in accordance with the requirements of the SAPIN 2 law, for identifying corruption risks, prevention policies, whistleblowing processes, etc., rolled out throughout the Group’s activities in France and internationally, and detailed in the Preventing corruption paragraph of this chapter; – in order to comply with regulatory obligations related to taxation, SOMFY puts forward a responsible tax policy, explained in the section “Putting business ethics into practice” of this document, respecting the recommendations issued by the Organisation for Economic Cooperation and Development (OECD); – in terms of fair competition, the Group has widely disseminated its Competition Law Compliance Code to each of its employees, who by signing it have committed themselves to adhering to it. This chapter details the actions taken in this regard in the “Ensuring Fair Competition” paragraph of the “Putting business ethics into practice” section.

As part of the assessment of the alignment of the Group’s eligible activities with the Taxonomy, SOMFY verified the compliance of their business model with the generic DNSH criteria and the minimum safeguards provided for respectively in Appendix 1 of the Climate delegated regulation of 4 June 2021 on the Climate Change Mitigation Objective, regulation (EU) 2020/852 and the report of the Sustainable Finance Platform (SFP). The Group meets all the generic criteria of the Taxonomy as described in the paragraphs below: – in order to meet the DNSH criterion relating to the Taxonomy’s objective of Adaptation to climate change , the Group has implemented a climate risk analysis for the most important production sites manufacturing the eligible products. This three-step approach is described in the section on Analysing resilience to climate risks in this chapter. This analysis will be continued and gradually extended to smaller industrial sites, distribution subsidiaries and, finally, to the entire value chain; – in order to meet the DNSH criterion relating to the Taxonomy’s objective of Sustainable use and protection of water and marine resources , the Group complies with local regulations as a matter of principle. As stated in the chapter “Conserving resources” of this report, SOMFY’s business involves assembly and does not use water in its production processes. Water consumption is solely linked to “non-industrial” uses (lavatories, showers, drinking fountains); to meet the DNSH criterion relating to the Protection and – restoration of biodiversity and ecosystems objective, the Group relies on European regulations to justify the alignment of all its projects in Europe, such as the EIA Directive (Environmental Impact Assessment of Projects in Europe). SOMFY’s activities do not fall within the scope of projects listed in Appendix II of Directive 2011-92-EU. In addition, the Polish production site, located near a Natura 2000 area, was exempted; to meet the DNSH criterion relating to the Taxonomy’s Pollution – prevention and reduction objective, the Group relies on compliance with European regulations on polluting substances to justify the alignment of its products. The FAQ published on 19 December 2022 provides additional information concerning this DNSH which, however, raises interpretation challenges on the method to be applied. The impacts of this FAQ and any subsequent clarification that would explain the provisions of Appendix C of the Climate Delegated Act will be taken into account and may alter SOMFY’s interpretation of the alignment.

Methodology for assessing the substantial contribution and specific DNSH criteria

The Group has analysed the criteria for substantial contribution as well as the DNSH criteria specific to the activities listed in the Taxonomy as described below. Activity 3.5: Activity Substantial contribution The activity consists of the manufacture of the following products and their essential components: – façade and roofing elements with a solar shading or solar control function – energy-efficient building automation and control systems – zoned thermostats and devices for the smart monitoring of the main electricity loads or heat loads for buildings, and sensoring equipment – products for smart monitoring and regulating of heating system, and sensoring equipment The analysis of the substantial contribution is carried out through analytical reporting of sales, derived from the financial statements without using distribution keys. 3.5 Manufacture of energy-efficiency equipment for buildings

71

SOMFY – ANNUAL REPORT 2022