As with the Group’s Code of Ethics and Sustainability Policy, the ERG Group Tax Strategy is inspired by the principles of legality, correctness, transparency, honesty, integrity, safeguarding of the company’s assets and creation of sustainable value for shareholders over the medium/long-term. More specifically, the ERG Group Tax Strategy seeks to:

• guarantee the correct and prompt calculation and payment of taxes due by law and the fulfilment of connected obligations (tax compliance);

• mitigate tax risk, understood as the risk of infringing tax regulations or abusing the principles and purposes of tax legislation (abuse of rights).

Tax Governance, Risk Control and Management

The Tax Control Framework (TCF) is an objective in our ESG Plan. It is an internal audit system for tax risk, namely the set of rules, procedures, organisational structures and measures aimed at allowing an effective recording, measurement, management and control of tax risk. In particular, we have adopted and implemented the TCF in Italy (FY 2021), France (FY 2023) and Germany (FY 2024).

The TCF is governed by specific regulations that, in addition to defining the governance rules, is based on the following key elements:

• a Risk & Control Matrix which describes the tax risks potentially applicable to company processes relevant for tax purposes and the relative risk mitigation controls in place;

• a system of data flows between the Tax organisational unit and the Group's other organisational units;

• a system of information flows between the foreign subsidiaries and the Tax organisational unit;

• a process of periodic updating and monitoring of the adequacy and effective application of the TCF;

• a process of periodic reporting to the Control, Risk and Sustainability Committee containing the results of the updates and monitoring activities carried out. The CFO is responsible for the implementation and operation of the TCF and is in charge of ensuring the update and monitoring of the TCF, as well as drawing up an annual Report.

The following are therefore prepared annually:

• plan for the testing, monitoring and assessment activities of the Tax Control Framework;

• the Annual Report, submitted for examination and opinion by the Control, Risk and Sustainability Committee. As part of the Tax Control Framework, an additional mechanism is envisaged to strengthen the Control System. In particular, a Tax Control Framework Committee with mixed competences was established:

• it performs preliminary analyses, and provides specific recommendations, on the testing, monitoring and assessment activities of the TCF;

• it analyses the annual report in advance, providing any specific recommendations;

• it monitors the actual implementation of the improvement plan for any shortcomings resulting from the testing, monitoring and evaluation of the TCF.

Involvement of stakeholders and management of tax concerns Our Group, even during audits by the competent authorities relative to companies of the Group or third parties, establishes and maintains a transparent and collaborative relationship focused on dialogue with the relative tax authorities, ensuring that the latter fully comprehend the company events underlying the application of tax laws.