2.4.European taxonomy of environmentally sustainable economic activities

The activity of co-generation of heat/cold and electricity from natural gas is eligible for the objectives of mitigation and adaptation to climate change, and the activity of manufacturing casings, films and bags obtained through the treatment of plastic polymers is eligible for the objective of transition to a circular economy, in the category of manufacturing plastic packaging.

In the case of co-generation, the technical alignment requirements need further development to facilitate the replacement of fossil fuels in line with the pioneering decarbonization work that the Group is carrying out in Spain.

For casings, films, and bags obtained through the processing of plastic polymers, and based on the analysis carried out, the value chain for this activity does not yet fully comply with the technical alignment criteria established in the regulations. However, Viscofan is working in this direction, emphasizing the development and promotion of casings with a percentage of recycled and natural-origin material.

Fundamentals

Regulatory evolution

In its statement of 8 March 2018, the European Commission presented its "Action Plan: Financing Sustainable Growth," thus marking the beginning of an ambitious and comprehensive strategy. The aim is for finance to play a key role as an engine for moving towards an economy that ensures compliance with the objectives of the Paris Agreement and the European Union's (EU) 2030 Agenda for Sustainable Development.

In this context, the proposed set of measures defines ten specific actions with the main focus of redirecting capital flows towards sustainable investments. As a result of the first of these actions, the Taxonomy Regulation was enacted, specifically Regulation (EU) 2020/852. This regulation aims to establish a classification system that, based on objective criteria, determines which economic activities are considered sustainable.

The Taxonomy Regulation establishes six environmental objectives:

• Climate change mitigation
• Adaptation to climate change
• Sustainable use and protection of water and marine resources
• The transition to a circular economy
• Pollution prevention and control
• The protection and restoration of biodiversity and ecosystems

This regulation has been modified gradually over several years to include the technical selection criteria for the 6 objectives.

First, on June 4, 2021, Delegated Regulation (EU) 2021/2139 on sustainable activities for the objectives of climate change mitigation and adaptation was published, establishing the technical selection criteria to determine the conditions under which an economic activity is considered to contribute substantially to these two objectives, and to determine whether that economic activity does not cause significant harm to

any of the other environmental objectives.

On 6 July 2021, the Commission adopted Delegated Regulation (EU) 2021/2178 supplementing Article 8 of the Taxonomy Regulation. This delegated act specifies the content, methodology, and presentation of the information that financial and non-financial undertakings must disclose regarding the proportion of environmentally sustainable economic activities in their trading, investment, or lending activities.

On 9 March 2022, the European Commission published Delegated Regulation 2022/1214 amending Delegated Regulation (EU) 2021/2139 as regards economic activities in certain energy sectors and Delegated Regulation (EU) 2021/2178 as regards the public disclosure of specific information on those economic activities.

On 27 June 2023 the Commission adopted Delegated Regulation (EU) 2023/2485 amending Delegated Regulation (EU) 2021/2139 establishing additional technical selection criteria to determine the conditions under which an economic activity is deemed to contribute substantially to climate change mitigation or adaptation and to determine whether that economic activity does not cause significant harm to any of the other environmental objectives.

Furthermore, on 27 June 2023, the European Commission adopted Delegated Regulation (EU) 2023/2486 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing technical selection criteria for determining the conditions under which an economic activity is deemed to contribute substantially to the sustainable use and protection of water and marine resources, the transition to a circular economy, the prevention and control of pollution, or the protection and restoration of biodiversity and ecosystems, and for determining whether that economic activity does not cause significant harm to any of the other environmental objectives. It also introduces amendments to Commission Delegated Regulation (EU) 2021/2178.

Regulatory update 2025

In July 2025, the European Commission adopted an amendment to the disclosure framework of the Taxonomy, set out in Delegated Regulation (EU) 2026/73, which introduces a general simplification of the reporting under Article 8 of Regulation (EU) 2020/852.

The reform updates both the reporting obligations of Delegated Regulation (EU) 2021/2178 and certain technical selection criteria of Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486 (related to the objective of pollution prevention and control), in order to reduce the administrative burden and improve the proportionality of the framework. Key changes include:

• The possibility of not evaluating as eligible and aligned those activities that are not material to the company (threshold of 10% of the KPIs of turnover, CapEx or OpEx) and their aggregate reporting as "activities not evaluated considered to lack significant relative importance".
• The simplification and consolidation of report templates of article 8.

For 2025, and in accordance with the transitional provision in Article 4 of Delegated Regulation (EU) 2026/73, Viscofan may choose to continue applying the version of Delegated Regulations 2021/2178, 2021/2139, and 2023/2486 in force as at December 31, 2025, instead of the amended regulations. This option is explicitly stated in the regulatory text, which allows companies to maintain the previous framework for the year whose accounting period begins between January 1 and December 31, 2025.

In this context, Viscofan has decided to take advantage of this transitional option and maintain its EU taxonomy reporting in accordance with the previous regulatory framework, thus ensuring comparability with previous years and preserving the methodological consistency of the key performance indicators (KPIs) while the internal adaptation to the new disclosure structure is completed.

Bases for classifying activities

In order to determine that an activity is “environmentally sustainable”, it is necessary to start from the distinction established by the regulation between two types of activities:

• Eligible activities: those that have a significant impact on the achievement of any of the six environmental objectives set out in the regulation, regardless of whether that economic activity meets any or all of the technical selection criteria set out in said delegated acts.
• Aligned activities: those that have a significant impact on achieving any of the six environmental objectives set out in the regulation and also:
  • It must not cause any harm to the other environmental objectives set out in the Regulation.
  • It conforms to technical selection criteria established by the Committee.
  • It shall be carried out in accordance with the minimum guarantees set out in Article 18 of the regulation.

Analysis of implications for Viscofan

Eligibility analysis: 6 environmental objectives

The Viscofan Group has conducted an analysis to identify the eligibility of the Group's activities with respect to the six environmental objectives:

The Traditional Business division, which accounts for 82.56% of the Viscofan Group's business volume (see note 19.1 of the consolidated report), encompasses the manufacture and distribution of cellulose, fibrous and collagen casings for sausages and other applications.

These activities have not been identified as having a significant impact on any of the six environmental objectives, and therefore are not eligible activities under the annexes of the regulations described above.

The New Business division represents 12.76% of the Viscofan Group's revenue and encompasses several activities. Of these, the manufacture of casings, films, and bags obtained through the processing of plastic polymers is included as an eligible activity under the circular economy transition objective, specifically as the manufacture of plastic packaging. The remaining activities of the division are either not eligible according to the taxonomy or are of little relevance.

Energy sales represent 4.68% of the Viscofan Group's revenue. This includes cogeneration activity in Cáseda, Spain, which involves selling electricity not used in the main activity to third parties. This activity is included in Annexes 1 and 2 of the Regulation as eligible for climate change mitigation and adaptation objectives. The remaining energy sales correspond to revenue from the sale of electricity transformed at the Zacapu, Mexico, an activity not eligible according to the taxonomy. See note 18 of the consolidated financial statements.

With the exception of those detailed above, no Viscofan economic activities have been identified that are directly linked to the specific activities included in the taxonomy annexes for the six environmental objectives. In certain complementary or support operations carried out at the main production plants, such as water or waste treatment, the following has not been implemented:

The analysis is flawed because these are not revenue-generating business activities, resulting in a zero turnover indicator. Furthermore, the investments and operating expenses related to these cross-cutting activities are sometimes included within the corresponding line items for the main activity's facilities, without sufficient detail, as they are integrated into general categories and lack the necessary evidence to allocate them to specific objectives and classify them as eligible.

Environmental objectives alignment analysis

Cogeneration

Viscofan has carried out the alignment analysis of the cogeneration activity based on the provisions of Annex I of Delegated Regulation (EU) 2021/2139, which includes the criteria that said activity must meet in order to be considered to make a substantial contribution to the mitigation of climate change.

The technical selection criteria for substantial contribution established in section 4.30 (High efficiency cogeneration of heat/cooling and electricity from gaseous fossil fuels) of this annex, set a minimum level of greenhouse gas emissions for a cogeneration activity to be aligned that is technically impossible to achieve with the use of 100% fossil fuel, making it necessary to mix non-fossil fuels and develop new technologies that would allow such consumption.

As part of its efforts to decarbonize its processes, Viscofan is leading the way, with cogeneration engines at its Cáseda plant capable of using green hydrogen as fuel. The company has successfully completed tests using this renewable energy source. Furthermore, an electrolyzer will be installed at the Cáseda plant in 2025 to produce green hydrogen, reinforcing its strategy to replace fossil fuels.

Although a regular, continuous supply of green hydrogen that materially replaces fossil fuel needs is not currently available, Viscofan is prepared for a rapid transition when such a supply becomes available.

Manufacturing of casings, films and bags through the treatment of plastic polymers

Viscofan has carried out the alignment analysis of this activity based on the provisions of Annex II of the Regulation, which includes the criteria that this activity must meet in order to be considered as making a substantial contribution to the transition to a circular economy.

Based on this, the activity of manufacturing casings, films and bags through the treatment of plastic polymers does not meet the established technical criteria of circularity and reuse.

However, as part of its commitment to promoting a circular economy, Viscofan offers eFAN packaging, which contains up to 95% recycled or bio-based plastic. While sales of this product are not yet substantial, Viscofan is seeking to increase its market share through marketing efforts and by improving its sourcing. Furthermore, the Group's main plastic extrusion and converting facilities hold ISCC PLUS certification, a sustainability certification program for bio-based and circular (recycled) raw materials.

Calculation of the indicators

The main key performance indicators have been calculated in accordance with the European Commission's Delegated Regulation, which supplements Regulation (EU) 2020/852 of the European Parliament and of the Council. This regulation details the content and presentation of the information that companies subject to Articles 19a or 29a of Directive 2013/34/EU must disclose regarding environmentally sustainable economic activities. It also specifies the methodology for fulfilling the disclosure obligation.

Calculation of the key performance indicator related to turnover and variation

In calculating the indicator, the accounts required by the Regulation have been identified in the denominator, being 100% of the turnover recorded under "net amount of turnover", which are detailed in the consolidated financial statements of the Viscofan Group in accordance with IFRS-EU (see note 19.1 of the Consolidated Report).

The amount of sales and provision of services from eligible activities has been used to calculate the numerator.

Calculation of the key performance indicator related to investments in fixed assets (CapEx)

In calculating the CapEx indicator, the denominator includes total investments in intangible assets, investments in tangible assets, and investments in right-of-use assets of the Viscofan Group, considered before depreciation, amortization, and any revaluations, including those resulting from revaluations and impairments, for the relevant period, excluding changes in fair value. The denominator also includes additions to tangible and intangible assets resulting from business combinations. See notes 5, 6, and 7 of the Consolidated Financial Statements.

For the numerator, the projects carried out during the year that can be considered within eligible activities for the CapEx indicator are taken into account, as indicated in Article 8 of the Regulation.

Calculation of the key performance indicator related to operating expenses (OpEx)

To calculate the OpEx indicator, the Viscofan Group's accounting accounts for research and development expenses, building renovation measures, short-term lease expenses, and maintenance and repairs or expenses that ensure the proper functioning of assets have been identified. The sum of these accounts is the denominator.

For the numerator, the details of the accounts by cost center have been extracted, analyzing the nature of the expenditure in order to identify whether it is associated with an eligible activity as indicated in Article 8 of the Regulation.

Main variations of the current year compared to the previous one

The revenue from eligible but non-aligned activities amounts to €153.3 million in 2025 (12.2% of the Group's total revenue) and corresponds to sales of co-generation electricity in Spain and sales of casings, films, and bags obtained through the processing of plastic polymers. The percentage decrease compared to 2024 (12.7%) is due to the faster growth rate of the other businesses not eligible for the environmental targets. Meanwhile, the denominator figure, Viscofan Group's total revenue, stands at €1,252.0 million (see explanation of the variation in the analysis of financial performance in the consolidated management report).

Capital expenditure (CapEx) for eligible but non-aligned activities amounted to €13.2 million (14.6% of the Group's total CapEx) and corresponds primarily to investments in the manufacture of casings, films, and bags through the processing of plastic polymers at various Group production plants. This figure remains stable compared to the previous year (14.6%).

OpEx for eligible and non-aligned activities is €4.4 million (11.4% of total Group OpEx), higher than the previous year's 10.0% due to increased maintenance spending at the co-generation plant.

Economic indicators

This section sets out the indicators for each economic activity regarding their eligibility and alignment with the Sustainable Finance Taxonomy. These indicators have been presented following the templates set out in Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021, as amended by Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023.

Turnover

CapEx. Investments in intangible assets, property, plant and equipment and rights-of-use assets

OpEx

Summary of eligibility scope and adjustment by environmental objective

Information on activities related to fossil gas

This information responds to the reporting requirements of Delegated Regulation (EU) 2022/1214 of 9 March of 2022 for the applicable key performance indicators for fossil gas-related activities. In particular, for Viscofan, the cogeneration activity referred to in section 4.30 of Annexes I and II of Delegated Regulation (EU) 2021/2139. Viscofan has no nuclear energy-related activities.